Oregon Coastal Coho Federal Recovery Plan Comments

December 31, 2015

To: Mr. Rob Walton

National Marine Fisheries Service 1201 NE Lloyd Boulevard, Suite 1100 Portland, Oregon 97232

From: Native Fish Society 813 7th St, Suite 200A

Oregon City, Oregon 97045
Re: Comments on Proposed Recovery Plan for Oregon Coast Coho Salmon

Mr. Walton,

Thank you for the opportunity to provide comments on the National Marine Fisheries Service’s Proposed Endangered Species Act (ESA) Recovery Plan for Oregon Coast Coho Salmon. Native Fish Society (NFS) is a 501c3 conservation non-profit, dedicated to utilizing the best available science in order to advance the protection and recovery of wild, native fish and promote stewardship of the habitats that sustain them. NFS has 3,000 active members and supporters, and over 80 place-based volunteer River Stewards who help safeguard their homewaters across the Pacific Northwest.

Pacific salmonids, including the Oregon Coast coho salmon (Oncorhynchus kisutch) are composed of locally adapting populations to their natal rivers. In framing a Recovery Plan and future Management Plan, National Marine Fisheries Service (NMFS) should specifically address this fundamental organization of a biological species, such as the case with Oregon Coast coho salmon. A plan based on this foundation requires that each river and its native wild salmonid populations are managed as a distinct breeding and rearing environment, and river specific management would replace aggregate harvest management while preventing the transfer of fish and eggs among rivers. To accomplish this, river specific management would be based on an estimate of productive capacity, egg deposition criteria, and nutrient enrichment targets that are supported by quantitative evaluation, and management success would rely on measurable quantitative criteria rather than vague qualitative goals.

This Draft Recovery Plan, however, does not manage for Oregon Coast coho salmon based on the fundamental needs of the species as locally adapted populations. Native Fish Society is concerned that without this basis, and specifically if implemented under the current Draft Recovery Plan, the plan would likely not prevent the further depletion of the population, nor result in recovery of the species that could lead to a delisting status. At its core, this Draft Recovery Plan lacks objective quantitative and river specific management actions that can be used to inform fisheries and land managers on actions to be taken that will lead to the recovery of the Oregon Coast coho salmon, and relies heavily on vague qualitative goals.

Pacific salmonids are place-based wild animals. In order to reverse their decline, as evident in the Oregon Coast coho salmon’s current listing status as threatened under the ESA, there must be a change in the management structure. Sustaining the natural population must become the primary purpose, while harvest and artificial propagation should be defined by natural population management objectives. Habitat must be managed to provide the ecological requirements of the natural population so that their full life history diversity can be expressed. A departure from historic management priorities is necessary because the past management structure has failed to sustain natural production of locally adapting wild native salmonids. It is because of this management failure that wild coho salmon were provided protection under the Endangered Species Act in the first place.

Restoring the full life history diversity of Oregon Coast coho salmon, minimizing hatchery impacts and limiting harvest is absolutely critical to the long-term survival of the species. A final Recovery Plan that does not take these fundamental biological requirements into account could jeopardize the already imperiled species. We ask that you consider the following recommendations and incorporate this information when finalizing the Recovery Plan for Oregon Coast coho salmon.

Finally, we would like to state for the record that in addition to the comments submitted below, we are also strongly in support of the comments submitted by Wayne Hoffman from the Mid Coast Watershed Council, and those submitted by Paul Kampmeier on behalf of the Center for Biological Diversity, Northwest Environmental Advocates, Oregon Wild, and WildEarth Guardians.


Bill M. Bakke
Founder, Science and Conservation Director Native Fish Society

1.1 Purpose of the Recovery Plan

NMFS’ goal is to improve the viability of the Oregon Coast coho salmon ESU to the point that the species is self-sustaining in the wild and no longer requires protection under the Endangered Species Act.”

– (1.1) Proposed Endangered Species Act Recovery Plan for Oregon Coast Coho Salmon, NMFS.

To accomplish this requirement of the ESA, NMFS must control the impacts of harvest, artificial propagation, and habitat degradation that limit wild coho salmon viability, resilience, and their capacity to become and remain self-sustaining.

Accomplishing this goal requires institutional change among state and federal natural resource management agencies that manage fisheries, land and water resources so that action agencies are aligned with coho recovery and long term sustainability using quantitative and measurable criteria. Since natural resource agencies are organized to provide economic benefits to constituent user groups as well conservation of natural resources for the public good, the coho Recovery Plan must be an effective agent of institutional change in order to achieve the recovery goal, and maintain it over the long term.

Consequently, unless the aforementioned institutional alignments are made, the Recovery Plan, and the eventual decision to remove Oregon’s coastal coho salmon from protection under the ESA, would likely return to management conditions that resulted in their initial protection. The Recovery Plan should provide a full evaluation of institutional impediments to coho salmon recovery and suggest changes that would achieve the expressed goal of self-sustaining wild coho salmon in coastal rivers. Currently, however, the Draft Recovery Plan lacks specific directions for managers of fisheries, land and water resources that would help recover wild Oregon Coast coho salmon.

Recommendation: NFS recommends that National Marine Fisheries Service develop a strategy for institutional change that manages for river specific populations in order to achieve self-sustaining Oregon Coast coho salmon productivity.

Institutional change in the management of Oregon Coast coho salmon is required since there is no assurance that future management of coho fisheries, hatcheries and habitats by state and federal agencies and private landowners would prevent a repeat of conditions that lead to their initial protection through the Endangered Species Act. Unless these actions are taken, it is likely that the Recovery Plan will not result in the actions necessary to recover the Oregon Coast coho salmon.

History and Perspective (Page ES-2)

This brief historical perspective in the Recovery Plan does not evaluate why three previous plans to recovery Oregon Coast coho salmon failed.

There were three previous coho salmon plans 1982 (ODFW Coho Species Plan), 1996 (Oregon Plan for Salmon and Watersheds) and again in 2006. In order to fully understand the conditions that lead to the listing status of Oregon Coast Coho salmon, an analysis of previous coho management plans must be included to evaluate the current Recovery Plan.

These remaining questions include:

  1. What were the management objectives of previous plans? What were they planning to do?
  2. Do the authors of the new Recovery Plan demonstrate a working knowledge of previous plans, recognizing the positive and negative outcomes?
  3. Is the new Recovery Plan addressing problems identified in previous plans and proposing to correct them? According to Mullen (ODFW Information report 81-5) the Oregon Production Index

(OPI) ranged from 1.1 to 3.9 million wild coho salmon from 1926-1950, assuming a 40% exploitation rate. Assuming an exploitation rate of 20% the OPI abundance would be 6.2 million. During this period (1926-1950) the average abundance declined progressively.

Beidler et al (ODFW Information report 80-10) concluded that the “average production of wild coho on the Oregon coast during the 1920s and 1930s is estimated to be 981,000 fish.” The authors recommended an “escapement goal of 200,000 adult fish.” They recognized that high densities of spawners tended to produce fewer offspring than somewhat lower densities, but it has been suggested that “this phenomenon might be explained equally as well by environmental factors such as weather or ocean upwelling and that low production from higher spawner densities is simply an artifact of random environmental conditions. Even if this hypothesis were true, it would not alter the results of our analysis. Whether high spawner densities produce fewer progeny or whether they produce the same number is not of major importance to this discussion. Our objective in this paper has been to determine the minimum number of spawners required to produce the most coho over the long term.”

Recommendation: The Draft Recovery Plan fails to address previous efforts to recover the Oregon Coast coho salmon. NFS recommends an evaluation of these previous plans, and an articulation of why previous plans were unsuccessful at resulting in self-sustaining populations of Oregon Coast coho salmon.

Habitat Quality (Page ES-6)

The Recovery Plan focuses on habitat and in doing so minimizes the impacts imposed on wild coho from hatchery and harvest claiming they have been “greatly remedied.”

Beidler et al (ODFW Information report 80-10) says, “The problem is that habitat quality is very difficult to measure, especially half a century in the past, so we will never know exactly how the present or future habitat quality relates to that period. A more important consideration...is the accuracy of the numbers (wild spawners) that go into it. Ultimately, it will be necessary to establish an escapement goal for each river basin. These basin escapement goals will provide salmon managers with a reference framework to assess the distribution of the coast wide escapement.”

Since the 1980s coho life history research has pointed out that juvenile coho utilize more of the river habitat than just the areas of the river associated with spawning, including lower river reaches, off-channel alcoves, side channels, marshes, beaver ponds, low saline estuary marshes, and thermal refuge areas associated with tributaries in summer when river water temperatures are high. All these rearing environments need to be included when evaluating smolt production from a river and estimates of density dependent mortality. In the past these so-called “alternative rearing areas” were not included in measuring coho productivity from watersheds. These habitats where they exist need protection and watersheds that have had these habitats altered or lost to development need to be reclaimed to expand coho life history diversity, resilience and productivity.

Recommendation: NMFS must establish quantitative escapement goals, egg deposition targets, and nutrient load criteria for each river that correlates with the best-available habitat quality analyses, including all “alternative rearing areas”.

Additionally, NMFS needs to identify what existing habitats need protection and restoration that would result in improved life history diversity and recovery of self- sustaining populations, with specific actions to be carried out by fisheries, land and water resource managers at the state and federal level.

The response by Oregon Coast coho salmon to the reduction in harvest and hatchery impacts indicates they have been rebuilding from near extinction in the late 1990s. This suggests that while the habitat is not pristine and could be improved, it is not as limiting as proposed in the Recovery Plan. Other factors besides habitat have influenced the productivity of Oregon Coast coho salmon, and without recognition of these “alternative rearing areas” and discussion of how hatchery and harvest levels will remain at or below current levels, it is unlikely that the Draft Recovery Plan will result in the actions necessary to recover coho salmon.

Delisting Criteria (4-13)

The “ocean test” alternative for delisting criteria of Oregon Coast coho salmon in the Draft Recovery Plan lacks specific, objective and quantifiable metrics for evaluating this as an effective alternative for delisting. Furthermore, it seems that there is inappropriate circularity in defining “poor ocean conditions” along with “sufficient abundance, productivity, spatial structure and diversity.” Poor ocean conditions, by definition means that coho survival is diminished and thus other-delisting factors will also be negatively influenced.

The “ocean test” alternative de-listing factor should be removed from the Recovery Plan. NMFS must adopt objective, measurable criteria for evaluating all of the listing factors. Until these specific metrics are defined in the Recovery Plan, it is unlikely that the plan will not prevent the serious depletion of the population, nor result in the recovery of the species to the point that it would warrant a de-listing status.

Harvest Impacts

Graph 1. Adult Oregon Coast Coho Salmon Returns 1950 - 2013

Graph 1 illustrates: Time (1950 – 2013) with the average coho population size, Resiliency based on the largest return of coho for each group of years, Average Escapement and Average Harvest Rate.

As the graph shows from 1950 to 1998 the average population size, resilience, and escapement decline while the harvest rate changes little until 1994 - 1998 when it drops to a substantially lower rate. From 1999 – 2013 the average abundance, resilience and escapement increase substantially compared to 1994 - 1998, and the harvest rate is at its lowest level.

The resilience of the Oregon Coast coho salmon over this time sequence is relatively high compared to present conditions, but has increased in response to reduced harvest and hatchery impacts after 1998. Resilience is an indicator of productivity from existing habitat during this sequence of years with the highest in 1950 – 1960 and declining to its lowest point in 1994 - 1998. Resilience is the largest coho adult production for each group of years, indicating that while habitat is not pristine, it is still very productive. Over time the impact of hatchery and harvest impacts erode the resilience of coho, but once harvest and hatchery impacts declined average adult coho abundance and resilience increased from 1999 -2013. This suggests that habitat for coho salmon, while declining over this same time period, is not as limiting as harvest and hatchery impacts on coho salmon.

Habitat conditions in freshwater and estuaries need improvement while keeping harvest and hatchery impacts low so that the investment in habitat can produce the expected benefits for coho productivity, resilience, and recovery. The Recovery Plan places more emphasis on habitat than it does on harvest and hatchery impacts suggesting that those impacts will continue to remain low. That assumption does not conform to recent harvest of threatened wild coho in river fisheries and suggests that as coho adult population size increases that state fishery managers will increase harvest impacts on wild coho salmon with permission from NOAA Fisheries. The justification is based on an estimate of habitat capacity. When it is assumed that habitat capacity is low, excess spawners will be wasted therefore they should be harvested. When habitat capacity is based solely on stream spawning areas, 35% of the coho adult production can be missed (Jones et al. 2014, 2015). In other words an ecological management framework is missing for each watershed that includes the life history diversity associated with habitats utilized by rearing juvenile coho salmon including beaver ponds, alcoves, side channels, marshes and estuary habitats.

Using a conventional methodology underestimates habitat capacity and coho productivity in freshwater (Jones et al. 2014). Basing a decision to harvest threatened wild coho on a conventional habitat assessment is imposing a harvest limitation on wild coho recovery. So harvest impacts have not been “greatly remedied” (Recovery Plan page ES-6, line 164). This harvest of wild threatened coho also does not take into account nutrient enrichment of streams from salmon eggs and carcasses, and increasing genetic diversity from having more spawners and mate competition. Each river population requires management criteria that are based on the full rearing capacity of the habitat, including the so-called “alternative” rearing areas, nutrient targets from natural spawners, and gene conservation. These criteria are delivered to each coho river through adult spawner abundance and criteria for escapement must be based on an ecological and genetic foundation.

Recommendation: NMFS must incorporate the best-available science which identifies expanded habitat capacities for the full life history diversity of Oregon Coast coho salmon, including habitats utilized by juveniles for rearing such as beaver ponds, alcoves, side channels, marshes and estuary habitats.

Additionally, this past season has been emblematic of the difficulty managing the Oregon Coast coho. Scientists estimated 206,600 adult coho to return to the Oregon Coast ESU during the 2015 – 2016 spawning season using models adopted by the Pacific Fishery Management Council. Commercial fisheries were structured off of this pre-season forecast with little ability to adaptively modify harvest pressure in mixed stock ocean fisheries. In recreational fisheries, river specific quotas, present in previous seasons were abandoned for aggregate management of five fish per angler with an unlimited number of anglers who could seek out licenses. The resulting 2015 fishery on threatened Oregon Coast coho was unable to be reduced, even as adult spawner abundance returned at half of the pre-season forecast.

The Recovery Plan must provide specific directives for state and federal fisheries managers so that the harvest of wild coho salmon remains at or below current exploitation rates, and it should replace aggregate fisheries with terminal, population specific fisheries that use in- season adaptive management to appropriately adjust harvest levels.

Graph 2. Historical Oregon Coast Coho Salmon Abundance (1892 -2014)

Graph 2. Historical Oregon Coast coho salmon abundance (1892-1958) compared to recent (1958- 2014) estimates of 63 spawner abundance and pre-harvest recruits. Horizontal lines are the geometric mean recruits for 1892–1940 and 1960–64 2009. Analysis based on data from Cleaver 1951, Mullen 1981a, and Mullen 1981b; recent data from Wainwright et al. 65 2008, ODFW 2009a, and Wainwright 2015.

This graphic is informative: wild coho production has declined. However, harvest impacts on coho are not shown even though Mullen (1981) estimated harvest prior to 1950 at 20% to 40% while harvest the harvest rate 1950 to late 1990s were as high as 87%, nearly causing the near extinction of Oregon coastal coho salmon.

Since all natural resource management institutions serve the economic interests of their constituents and the market economy, they are reluctant to manage natural resources in the public interest. Unless the Recovery Plan for Oregon Coast coho salmon integrates all institutional impacts an effective recovery plan cannot be achieved and if wild coho are no longer protected through the ESA, they cannot be sustained under state management.

Recommendation: Because wild coho are locally adapting animals in their natal watersheds, integration of habitat protection and restoration with on-going control and refinement of harvest and hatchery impacts on coho productivity and resilience, must be specifically addressed in the Oregon Coast Coho Salmon Recovery Plan. In order to be effective the Recovery Plan needs to replace aggregated management of coho and adopt river specific management criteria for wild coho salmon breeding populations consistent with scientific information.

The Recovery Plan for Oregon Coast coho salmon must include hatchery impacts as a continuing limiting factor on wild coho recovery, and reduce or eliminate coho salmon hatchery production until NMFS has established specific criteria for hatchery management that would protect wild coho.

Additionally, the Recovery Plan for Oregon Coast coho salmon must include discussion of all hatchery impacts, not just the genetic interactions between hatchery coho salmon but also the ecological interactions as well from all Oregon Coast hatchery salmonid programs, including the STEP program hatcheries and hatchboxes.

The proportion of artificial influence should not be limited to intra-specific genetic interactions, but should include both intra- and inter-specific ecological interactions between hatchery fish and wild coho within the ESU, including the freshwater and marine environments.

Criteria should include a stray rate for hatchery fish into natural spawning areas for wild coho of less than 5%. This is justified based on NMFS report by Grant (1997) and Buhle et al 2009. The premise is that hatchery coho have diverged from wild coho affecting their reproductive success that is lower than for wild coho and therefore function as a non-native species in the ecosystem, causing lower reproductive success through interbreeding and competition with wild coho salmon.

Harvest Management and Spawner Escapement

In 1980, Beidler et al. stated: “Basin escapement goals should be based on 40 adults per mile of habitat (20 females per mile assuming a 1:1 sex ratio), with possible adjustments made on the basis of qualitative assessment of the available habitat...”

The authors are trying to establish spawning abundance criteria for wild coho. Spawner abundance criteria are affected by harvest impacts which in the late 1990s nearly caused wild coho to go extinct on the Oregon coast. Harvest subtracts spawners and when harvest is based on an aggregate of coho from all watersheds, locally adapting populations are at high risk because they are not as important as the harvest goal, especially when it is possible to backfill with hatchery product.

“Ultimately it will be necessary to establish an escapement goal for each river basin. These basin escapement goals will provide salmon managers with a reference framework to assess the distribution of the coastwide escapement (Beidler et al 1980).

Recommendation: Escapement goals must be established for each river basin rather than an aggregate coast wide goal, and the escapement goal needs to be expanded so that all rearing habitats are included.

4.2.2, Lines 151-152: “The TRT’s criteria focus on coho salmon status at the population level, and the combined status of the populations determines the status of the ESU.”

A river specific escapement goal has been recommended for 35 years, but the fishery management agencies have never adopted it even though it is a critical foundation for sustainable wild coho productivity. Using the TRT recommendation that recovery is based at the population level and that similar populations form a “strata” and those strata are rolled up to determine the status of the wild coho ESU, would implement the recommendation by Beidler et al 1980. However, the Recovery Plan must make sure the management agencies do not use the TRT spawner escapement approach to justify a continuation of aggregate escapement for the ESU and placing individual populations at risk of extinction.

The Oregon Department of Fish and Wildlife with NMFS’s approval have allowed harvest of wild coho in some rivers using the “wadable stream” evaluation of habitat capacity. As pointed out by Jones et al. 2015 juvenile coho are not confined to spawning areas for rearing but also use other habitats such as marshes, beaver ponds, alcoves, side channels and tidal habitats. Because these habitats are not included in agency assessment of coho juvenile production the carrying capacity of the stream is underestimated and the spawner escapement goal is lower than it should be based on density dependent mortality calculations using wadable stream habitat capacity estimates.

Harvest has been and continues to be conducted under Amendment 13 by aggregating the estimated coho adult abundance from all river basins on the coast. This approach causes harvest management to be insensitive to the status of populations in each river. Aggregate stock management nearly caused wild coho salmon to go extinct in the late 1990s and resulted in their eventual protection under the Endangered Species Act.

ODFW Response to Declining Wild Coastal Coho

This precipitous decline in coho productivity was not unnoticed by ODFW scientists. McGie (1981) reported: “Wild and hatchery stocks of coho salmon have exhibited alarming downward trends since the mid 1960’s. Since 1965, wild stocks have declined at an average annual rate of 9.3%/yr in coastal rivers. If the present rate of decline persists, wild stocks in coastal rivers will become virtually extinct in about 25 years (2006).” He was nearly correct in his prediction, it just happened 8 years earlier. McGie also noted, “The main drivers for this declining trend in coho salmon as increased hatchery production in the early 1960’s, intensive sport and commercial harvest, and poor upwelling on the coast affecting food available to coho salmon smolts.”

As the ODFW Harvest Manager, Jim Martin, said in 1984,“Control of mixed stock harvest to allow a continuing supply of natural spawners returning to coastal watershed...is an important component of why ODFW continues to support management of coho salmon for a mix of hatchery and wild populations.”

In 1990 in an article published in the Salmon-Trout-Steelheader, a sport fishing magazine, Mr. Martin said, “We must keep our finger on the pulse of our key wild populations and must respond with action when problems are identified.”

The Oregonian reported in 1995 that the Chief of Fisheries, Jim Martin, said, “His biggest disappointment was not identifying problems with coho salmon sooner.” Martin said, “In the past few years, biologists have discovered a significant error in the way they calculated upcoming coho salmon returns. The error compounded itself in a way that contributed to shortfalls in fish – a situation for which Martin assumes personal responsibility.”

In 1981 Al McGie had informed ODFW that coastal coho were headed for extinction by 2006 if changes were not made in hatchery and harvest programs. This was 14 years before Martin faulted ODFW biologists for their “significant error” in calculating coho salmon returns that lead to their protection as a threatened species under the Endangered Species Act.

This time line illustrates an important problem in fishery management. The problem is scientific evaluation is not being used by management to address emerging problems caused by historic status quo management policy to benefit constituents at the expense of the resources those constituents depend. The State of Oregon requires the ODFW “To prevent the serious depletion of any indigenous species,” and “The commission shall represent the public interest of the state and make decisions affecting the wildlife resources of the state for the benefit of those resources” (ORS 496.012 and 496.090(6). This means that ODFW is to manage for public benefit not just constituents, yet the degradation of public resources continues to plague natural resource management.

Recommendation: To be effective the Recovery Plan must require that harvest management of coho salmon is focused on wild coho salmon in each watershed rather than continue aggregate harvest management and establish quantifiable criteria for wild coho conservation and productivity by watershed.

The Recovery Plan must establish river specific quantifiable spawner escapement goals including all habitats used for juvenile rearing and manage harvest to deliver the escapement goal by population annually.

Nutrient Enrichment of Streams

Historic salmonid abundance on the Oregon coast was in excess of 4 million and may have been more than 6 million (Biedler 1980, Mullen 1981)) and progressively declined from 1926 to near extinction when coho salmon were first listed in the late 1990s. The historic abundance of wild salmonids in Oregon coastal rivers infused a tremendous amount of nutrients important to the ecological productivity of streams for salmonids and other species both aquatic and terrestrial.

Gresh et al (2000) estimated “...that just 6-7% of the marine derived nitrogen and phosphorous once delivered to rivers of the Pacific Northwest is currently reaching the streams.” They suggest that “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.”

The Recovery Plan does not discuss the ecological value of nutrient enrichment of streams derived from spawning salmon. Considering the extensive body of scientific studies relating marine derived nutrients to salmonid productivity in freshwater, the total absence of this factor in the Recovery Plan constitutes a major omission.

Providing an adequate marine derived nutrient infusion to watersheds to support their ecological productivity is an important factor in developing spawner abundance, productivity, distribution, and diversity criteria for coho salmon (and other salmonid species) in Oregon coastal streams. For example in Table 4.1 “Four spawners per mile in 80% of the stream reaches, on average, provide certainty that spawners occupy a high proportion of the available spawning habitat and meet this criteria.” The criteria is limited to spawners rather than their ecological function, and while that low spawner abundance can be argued as being inadequate for maintaining genetic diversity, it certainly falls way short of any reasonable nutrient enrichment target.

Nutrients From Salmon Carcasses Improve Stream Structure and Shade

Large wood debris (LWD) is a habitat objective in the Recovery Plan but sources for LWD are disappearing under state regulated industrial forestlands. This has reduced and eliminated ecological benefits on coho salmon streams. Riparian protection is not adequate for providing large conifer trees to increase stream structure or shade to cool streams.

Helfield (2001) conducted research on the effects of marine derived nutrients from naturally spawning wild salmon on riparian shrubs and trees, showing that salmon make their own habitat.

“Anadromous Pacific salmon (Oncorhynchus spp.) transport marine-derived nitrogen (MDN) to the rivers in which they reproduce. Isotopic analyses indicate that trees and shrubs near spawning streams derive 22-24% of their foliar nitrogen (N) from spawning salmon. As a consequence of this nutrient subsidy, growth rates are significantly increased in Sitka spruce (Picea sitchensis) near spawning streams. As riparian forests affect the quality of instream habitat through shading, sediment and nutrient filtration, and production of large woody debris (LWD), this fertilization process serves not only to enhance riparian production, but may also act as a positive feedback mechanism by which salmon-borne nutrients improve spawning and rearing habitat for subsequent salmon generations and maintain the long-term productivity of river corridors along the Pacific coast of North America.

“This enhanced growth rate corresponds to a requirement of ~82 years to attain a diameter at breast height of 50 cm (20 feet) at spawning sites, as compared with 307 years at reference sites.” In addition total annual growth per unit of forest was calculated. The authors found that total annual growth was “more than three times higher at spawning sites relative to reference sites.”

“In our study, trees near spawning streams reached this threshold diameter >200 yr earlier than their counterparts at reference sites.

“To the extent that taller, wider trees are more likely to enter and persist in streams, MDN subsidies to riparian growth enhance the beneficial effects of LWD on spawning habitat. By enhancing the growth of riparian trees and the production of LWD, MDN inputs to the riparian zone might therefore serve as a positive feedback mechanism by which spawning salmon help to enhance the survivorship of subsequent salmonid generations.

Recommendation: The Recovery Plan should address the ecological value of nutrients from naturally spawning salmon and establish criteria for an annual nutrient target (1.9kg wet mass/m2) from salmon carcasses of natural origin for each watershed and population based on the scientific literature.

*Reference Quotes from Scientific Literature on Nutrient Enrichment of Streams from Salmonids are in Appendix 1*

Juvenile Coho Salmon Life History

The Recovery Plan states: “Most juvenile coho salmon migrate to the ocean as smolts in the spring, typically from late April until early June, although migration strategies are important as a feature of life history diversity. Coho salmon smolts may be present in estuaries for a period of weeks to perhaps a month during their migration to the ocean. During their stay in the estuaries they seek low-salinity gradients to grow and slowly acclimate to saltwater. They reside in shallow areas and side channels, as well as deeper channels and plumes of freshwater extending offshore at varying times of the year” (Page ES5).

Recognition of life history diversity in juvenile coho salmon rearing is important to the Recovery Plan. Conventional concepts of coho reproduction is based on stream redd counts and estimates of stream habitat capacity, assuming there is a single yearling life history type. Recent research (Jones et al. 2014, 2015) identifies four life histories for coho juveniles contributing to adult returns.

“Estuarine-associated life-history strategies accounted for 20–35% of the adults returning to spawn in the four brood years, indicating that a sizable proportion of the total O. kisutch production is ignored by conventional estimates based on stream habitat capacity. Juvenile O. kisutch responses to the reconnection of previously unavailable estuarine habitats have led to greater life-history diversity in the population and reflect greater phenotypic plasticity of the species in the U.S. Pacific Northwest than previously recognized” (Jones et al. 2014).

“The time elapsed between marking and recapture (or detection) of PIT-tagged fish... and the otolith chemical patterns of unmarked juveniles... identified at least four juvenile life- history types within the Salmon River population: (1) yearling migrant, 1 year rearing in streams (non-tidal) before migrating to the estuary and ocean in the spring ( >80mm LF at estuary entrance), (2) fry migrant, enter the estuary soon after emergence in the spring or early summer (35–50mm LF), reside in the estuary summer to winter and enter the ocean the following spring, (3) fry migrant nomad, enter the estuary in the spring or summer ( <65mm LF), return to fresh water (streams) in the autumn and winter, and re-enter the estuary and ocean in the spring at age 1 years [defined by Koski (2009) as a nomad] and (4) parr migrant, enter the estuary in the autumn or winter ( >75mm LF), remain in the estuary during the winter and enter the ocean in the spring at age 1 years (Page 19 Jones et al. 2014).

“Estuarine-associated life-history strategies accounted for 20–35% of the adults returning to spawn in the four brood years, indicating that a sizable proportion of the total O. kisutch production is ignored by conventional estimates based on stream habitat capacity. Juvenile O. kisutch responses to the reconnection of previously unavailable estuarine habitats have led to greater life-history diversity in the population and reflect greater phenotypic plasticity of the species in the U.S. Pacific Northwest than previously recognized” (Jones et al. 2014).

Recommendation: The Recovery Plan must recalculate the actual habitat capacity of each watershed incorporating the findings of Jones et al 2014, and identify life history types in each watershed contributing to adult recruitment. Where life history diversity is limited in a watershed develop restoration plans to address the life cycle requirements of rearing coho salmon and fund projects.

Effects of Hatcheries and Stock Transfers on Wild Salmonids and Recovery

In 1986 ODFW scientist Tom Nickelson published a paper saying, “Hatchery coho juveniles are more abundant after stocking in streams but the result is fewer adult returns and fewer juvenile coho salmon in the next generation than in streams that were not stocked.”

The conventional wisdom held by state and federal fishery agencies about the value of industrial production of artificially propagated salmon is being challenged. This paper followed the 1982 Oregon Plan for Coho Salmon, an attempt to protect wild coho salmon while at the same time subsidizing the market economy with public funding of salmon for the market. But the wild salmon lost.

In 2003, Nickelson said in another paper concluding: “Hatchery programs designed for harvest augmentation should be removed from basins with habitat that has high potential to produce wild salmonids. To aid recovery of depressed wild salmon, the operation of hatcheries must be changed to reduce interactions of hatchery smolts with wild smolts. A program that reduces harvest, restores habitat, and reduces hatchery effects is necessary.”

Protection of Oregon coastal coho salmon was opposed by Governor Kitzhaber and ODFW, but they were protected as a threatened species through the federal Endangered Species Act in 2008. Oregon lost its management authority over coho salmon production and harvest. Agency scientists had been ringing the warning bell that coho were in trouble and had been declining since the 1920s, but the managers ignored the science. With ESA protection wild coho salmon emerged from the basement of official concerns and became a primary issue. Nickelson’s recommendations became the new management paradigm. Hatchery releases were reduced by 95% and harvest was reduced by more than 80%, and habitat restoration became the new coho salmon salvation. Wild coho began to rebuild. With relief from the ecological and genetic impacts of hatchery coho and excessive harvest rates, wild coho populations began to grow in uneven ocean productivity.

The Oregon Coast Coho Salmon Recovery Plan can continue this progress only if harvest and hatchery impacts continue to be controlled. A reliance on habitat restoration, while important, cannot offset a return to industrial production and exploitation of the past. Unfortunately, the Draft Recovery Plan assumes that Oregon will not return to past management practices once wild coho are “recovered,” for the plan fails to adequately address these two issues.

Recommendation: The Recovery Plan for wild coho salmon must include hatchery impacts as a continuing limiting factor on wild coho recovery and establish criteria for hatchery management that would protect wild coho. Criteria should include a stray rate for hatchery fish into natural spawning areas for wild coho of less than 5%. This is justified based on NMFS report by Grant (1997) and Buhle et al 2009. The premise is that hatchery coho have diverged from wild coho affecting their reproductive success that is lower than for wild coho and therefore function as a non-native species in the ecosystem, causing lower reproductive success through interbreeding and competition with wild coho salmon.

*Reference Quotes from Scientific Literature on Hatchery Impacts on Wild Salmonids are in

Appendix 2*

Stock Transfer Policy Needed

A stock transfer policy is needed to protect the life history and genetic integrity of wild populations in coastal watersheds. The TRT established biological criteria for recovery for coho salmon (4.2.2 page 4.5) that places an emphasis on the status of populations within strata and the ESU. Therefore the biological health and productivity of river specific populations is a fundamental metric for recovery.

The State of Oregon recently adopted the Coastal Multi-Species Management Plan (CMP) that removed the stock transfer policy for coastal chinook to provide an opening for private investment in chinook aquaculture in coastal rivers. This ended the application of the only stock transfer policy controlling the transfer of salmonids among watersheds in Oregon.

This chinook stock transfer policy was established by ODFW in the 1980s in response to biological concerns regarding chinook salmon transfers from the Rogue River to the Columbia River. This internal action was based on a biological concern about mixing locally adapting stocks among rivers that promoted straying as a function of management policy.

Straying of artificially produced salmon has been a long-standing concern in the scientific community because of its biological impact on locally adapting populations in watersheds. However, managers have long supported moving fish and eggs among hatcheries and rivers to accommodate production for fisheries even though doing so has a documented impact on wild locally adapting native wild salmonids. This management flexibility needs to come to an end in the Wild Coho Salmon Recovery Plan to protect and rebuild wild coho in Oregon’s coastal rivers in order to maintain healthy wild coho on the Oregon coast.

Recommendation: The Recovery Plan must include a prohibition on transfer of fish and eggs among watersheds on the Oregon Coast and seek adoption of this policy by the Oregon Department of Fish and Wildlife Commission.

*Reference Quotes from Scientific Literature on Stock Transfer on Wild Salmonids are in Appendix 3*

Hybridization Impact on Wild Salmonids

HYBRID DEFINATION USED BY ODFW: ODFW. 2005. Oregon Native Species Status Report. Volume 1, Species Management Unit Summaries

Hybridization Criteria: “Hybridization with non-native species is rare or nonexistent in three of the last five years for at least 80% of existing populations.”

“This criterion highlights specific cases where native species are threatened by hybridization. Hybridization involves interbreeding between related species (cutthroat vs. rainbow trout or bull trout and brook trout) and can lead to reduced productivity and loss of unique genetic characteristics. Hybridization is not typically an issue for anadromous species but can be significant between native and introduced species of trout.

ODFW does not recognize in its definition of hybridization the interbreeding between fish of the same species. This precludes outbreeding depression associated with interbreeding between wild salmonids with hatchery origin salmonids. The potential impact of hybridization between hatchery and wild salmonids has a biological effect on local adaptation and genetic diversity of wild populations affecting other criteria used to determine species status: distribution, abundance, productivity, and reproductive independence.

The ODFW uses six criteria for evaluating the status of native fish in the state. These criteria are 1) the fish still exist, 2) Distribution, 3) Abundance, 4) Productivity, 5) Reproductive independence and 6) Hybridization

Consequently, in evaluating the status of salmonids the ODFW definition of hybridization does not affect other criteria used in determining the status of a species. For example, the status review states: “Productivity is generally related to...high life-history and genetic diversity that allow a population to take maximum advantage of a variety of habitat and environmental conditions.” Hybridization between hatchery and wild salmonids has an impact on all criteria used to determine the status of a species (Araki and Schmidt 2010, Williamson and May 2005, Harvey et al 2015, McGinnity et al. 2003, Laikre et al 2010, Chilcote et al. 2013, Neff et al. 2015).

Neff et al. (2015) says, “Salmon produced by hatcheries have lower fitness in the wild than naturally produced salmon.” Harvey et al (2015) states: “The long term evolutionary effects of both intentional and unintentional releases of domestic conspecifics on wild populations are of growing concern. Successful interbreeding between domesticated and wild conspecifics may result in negative genetic effects such as loss of native population genetic structure, loss of genetic variation, and the breakdown of local adaptions. Fitness loss can occur when alleles important for local adaptation are replaced by maladaptive or non-local alleles through hybridization (observable in the F1 generation) and by the loss of locally adapted gene complexes through introgression...a mechanism of outbreeding depression.”

By confining the definition of hybridization to breeding between different species rather than including breeding within a species, the Oregon Department of Fish and Wildlife has eliminated by definition the effects recognized by science that compromise wild native fish viability and sustainability.

The ODFW definition of hybridization allows management for conservation, protection and recovery of wild native salmonids to ignore the biological effects of hatchery impacts, stray hatchery fish, and transfer of fish and eggs among watersheds.

Recommendation: The official definition of hybridization needs to include within species hybridization and its impact on wild salmonid genetic life history attributes of locally adapting wild populations. This change is necessary because it gives an inaccurate estimate of species status at the population level of organization leading to a biologically incompetent assessment of the species ESU. Hybridization as currently defined has a substantial impact on the regulatory effectiveness of the agency to recover endangered and threatened species protected by the Endangered Species Act.

Appendix 1.

Nutrient Enrichment of Streams:

Gresh et al (2000) states: “In streams where only coho are known to return, 93-155 salmon carcasses per kilometer of stream are thought to be needed in order to provide the maximum ecological benefit from MDN (R.E. Bilby, NMFS, pers. comm..)”

Bilby et al 1998, provided the following information on coho and steelhead response to MDN from salmon carcasses:

“Sixty to 96% of the material in the stomachs of juvenile coho and steelhead during the period when carcasses were present at the treated sites consisted of eggs and carcass flesh.

“Condition factor of juvenile coho salmon ...and age 0+ steelhead in Salmon Creek increased after addition of carcasses to these streams.

“...eggs are eaten preferentially to flesh
“By December the coho at the treated site were 44% larger than the coho at the reference site.

“Therefore availability of eggs and carcass tissue, and the resultant increase in body size of juvenile fish, may positively impact survival rates through the remainder of their life.

“Salmon eggs were the dominant item in the diet of age 1+ steelhead shortly after addition of the carcasses to A400 Creek, comprising over 90% of the material recovered from their stomachs.

“Our results coupled with information published over the last 7 years (Kline et al. 1990, 1994; Michael 1995; Bilby et al 1996; Johnston et al. 1997) make it increasingly apparent that adequate levels of spawning salmon are an important component of healthy stream habitat in the Pacific Northwest.

“It is likely that decreased numbers of returning salmon have decreased the capacity of the freshwater habitats where they spawn to support juvenile salmon and other aquatic biota.

“Distribution of salmon carcasses from hatcheries may be used to increase the availability of carcass material in watersheds where population levels are severely depressed. However, this technique cannot replace all the ecological functions provided by naturally spawning fish. Spawning fish remove sediment from streambed gravels (Montgomery et al. 1996) and alter the community composition and productivity of invertebrate populations (Piorkowski 1995; Minikawa 1997). Adult salmon also enter streams and spawn over an extended period of time. Therefore, carcass material would be present in the channel for a longer period than would be the case with hatchery carcasses added on a single date.”

According the Washington Department of Fish and Wildlife a natural spawning escapement level based on 1.9 kg/m2 (Wipfli 2003) and average weight of carcass at 4kg/carcass is needed to provide nutrients for 2.11m2 would require approximately 763 spawners per mile.

Achieving nutrient enrichment targets for streams requires management for spawner abundance (escapement) goals for each watershed.

Gresh et al 2000 stated: “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.”

IMST 2000. stated: “Recent studies of the role of carcasses in nutrient cycling demonstrates the need for production well above minimum viable populations to support ecologically healthy and robust stocks...there are no scientifically sound experimental measures of the effects of salmon carcasses in coastal streams for OCN coho salmon.

“Traditionally, the ecological role of adult salmon, particularly as nutrient source for freshwater communities and young salmon has been ignored in salmon monitoring.”

Shaff and Compton (2009) conclude: “Our study suggests that artificially placed carcasses at the levels added in the Oregon Coast Range may not directly mimic the role of natural carcasses in stream food webs. Our results also suggest that SDN assimilation is higher for natural spawners than for placed salmon carcasses. Washington places carcasses into streams with natural returns less than 1.9kg wet mass/m2...which is considered to be the amount needed to sustain minimum nutrient needs of aquatic systems with juvenile salmonids (Michael 2005).

Nutrients from salmon carcasses improve stream structure and shade:

Helfield (2001) stated: “In our study, trees near spawning streams reached this (large woody debris) threshold diameter >200 years earlier than their counterparts at reference sites.”

Appendix 2.

Reference Quotes on Hatchery Impacts to Wild Salmonids:

Bowles 2008: “Hatchery programs are not a substitute for, or an alternative to, achieving a viable wild population according to NOAA Fisheries' Hatchery Policy. Instead, any hatchery programs have to support natural production.”

“The threats to wild populations caused by stray hatchery fish are well documented in the scientific literature. Among the impacts are substantial genetic risks that affect the fitness, productivity and genetic diversity of wild populations. Genetic risks increase substantially when the proportion of the adult population that is hatchery fish increases over 5% (Lynch and O'Hely 2001, Ford 2002).”

“Hatchery programs also pose ecological risks to wild populations that can further decrease abundance and productivity (reviewed by Kostow 2008). The level of risk is related to both the proportion of the fish in a basin that are hatchery fish and to the source of the hatchery fish. Ecological risks due to the presence of hatchery adults (including adults of a different species) have been demonstrated when the proportion that is hatchery fish is over 10% (Kostow and Zhou 2006).

Buhle et al. 2009: “Our analyses highlight four critical factors influencing the productivity of these populations: (1) negative density-dependent effects of hatchery-origin spawners were ~5 times greater than those of wild spawners; (2) the productivity of wild salmon decreased as releases of hatchery juveniles increased; (3) salmon production was positively related to an index of freshwater habitat quality; and (4) ocean conditions strongly affect productivity at large spatial scales, potentially masking more localized drivers. These results suggest that hatchery programs’ unintended negative effects on wild salmon populations, and their role in salmon recovery, should be considered in the context of other ecological drivers.”

“We found that wild populations of Oregon coast coho salmon responded to changing hatchery practices during the 1990s. Productivity, expressed as the per capita growth rate in the absence of harvest, improved with reductions in the density of hatchery origin fish spawning in the wild and the numbers of hatchery smolts released into rivers. The strongest negative effects of hatcheries were associated with hatchery-reared adults breeding in the wild, precisely the pathway that might be expected to contribute most to population rebuilding.”

Chilcote et al. 2011, 2013: “We found a negative relationship between the reproductive performance in natural populations of steelhead, coho, and Chinook salmon and the proportion of hatchery fish in the spawning population. We used intrinsic productivity as estimated from fitting a variety of recruitment models to abundance data for each population as our indicator of reproductive performance. The magnitude of this negative relationship is such that we predict the recruitment performance for a population comprised entirely of hatchery fish would be 0.128 of that for a population comprised entirely of wild fish. The effect of hatchery fish was the same among all three species. Further, the impact of hatchery fish from ‘wild type’ hatchery broodstocks was no less adverse than hatchery fish from traditional, domesticated broodstocks. We also found no support for the hypothesis that a population's productivity was affected by the length of exposure to hatchery fish. In most cases, measures that minimize the interactions between wild and hatchery fish will be the best long-term conservation strategy for wild populations.”

Christie et al. 2011: “These results demonstrate that a single generation in captivity can result in a substantial response to selection on traits that are beneficial in captivity but severely maladaptive in the wild. We also documented a tradeoff among the wild-born broodstock: Those with the greatest fitness in a captive environment produced offspring that performed the worst in the wild.”

Christie et al. 2014: Here, we review recent studies on the reproductive success of such ‘early- generation’ hatchery fish that spawn in the wild. Combining 51 estimates from six studies on four salmon species, we found that

(i) early-generation hatchery fish averaged only half the reproductive success of their wild- origin counterparts when spawning in the wild,

(ii) the reduction in reproductive success was more severe for males than for females, and

(iii) all species showed reduced fitness due to hatchery rearing. We review commonalities among studies that point to possible mechanisms (e.g., environmental versus genetic effects).

Furthermore, we illustrate that sample sizes typical of these studies result in low statistical power to detect fitness differences unless the differences are substantial. This review demonstrates that reduced fitness of early-generation hatchery fish may be a general phenomenon. Future research should focus on determining the causes of those fitness reductions and whether they lead to long- term reductions in the fitness of wild populations.

Flagg and Nash, 1999: “The reviews conclude that artificial culture environments condition salmonids to respond to food, habitat, conspecifics and predators differently than fish reared in natural environments. It is now recognized that artificial rearing conditions can produce fish distinctly different from wild cohorts in behavior, morphology, and physiology.”

Fleming and M.R. Gross 1993: “The divergence of hatchery fish in traits important for reproductive success has raised concerns. This study shows that hatchery coho salmon males are competitively inferior to wild fish, and attained only 62% of the breeding success of wild males. Hatchery females had more difficulty in spawning than wild fish and hatchery fish had only 82% of the breeding success of wild fish. These results indicate hatchery fish may pose an ecological and genetic threat to wild fish.”

Ford, 2002: “Substantial phenotypic changes and fitness reductions can occur even if a large fraction of the captive broodstock is brought in from the wild every generation. This suggests that regularly bringing wild-origin broodstock into captive populations cannot be relied upon to eliminate the effects of inadvertent domestication selection.”

Ford 2010: “What is known from peer-reviewed scientific studies on the impact of hatchery salmonids on wild salmonids? Hatchery fish reproductive success is poor; there is a large scale negative correlation between the presence of hatchery fish and wild population performance; hatchery fish reproductive success is lower than for wild fish and this is true for both supplementation and production hatchery programs; there is evidence of both environmental and heritable effects; effects were detected for both release and proportion of hatchery spawners; negative correlations between hatchery influence and wild productivity are widespread; habitat or ocean conditions do not appear to explain the pattern; current science indicates that limiting natural spawning of hatchery fish is generally beneficial to wild populations; there is evidence that reducing hatchery production leads to increased wild production, and cumulative effects of hatchery could be a factor limiting recovery of some ESUs.”

Grant, 1997: “Based on estimates of gene flow from allozyme frequencies in natural populations, a value of 5% gene flow is much higher than that generally occurring between non-local salmonid populations. The panel found no genetic justification for allowing gene flow from non- native fish at levels as high as 5%.”

ISAB 2002. “We believe that available empirical evidence demonstrates a potential for deleterious interactions, both demographic and genetic, from allowing hatchery-origin salmon to spawn in the wild. Because it is virtually impossible to ‘undo’ the genetic changes caused by allowing hatchery and wild salmon to interbreed, the ISAB advocates great care in permitting hatchery-origin adult salmon to spawn in the wild.”

Knudsen et al. 2006. “Perhaps the most important conclusion of our study is that even a hatchery program designed to minimize differences between hatchery and wild fish did not produce fish that were identical to wild fish.”

Knudsen et al. 2008: “Consequently, in this project, on a per capita basis hatchery-origin females are a minimum of 6-7% less fit than wild fish owing to lower fecundity. This demonstrates that hatcheries do not produce fish that are identical to wild fish.”

Kostow 2004: “In conclusion, this study demonstrated large average phenotype and survival differences between hatchery-produced and naturally produced fish from the same parent gene pool. These results indicate that a different selection regime was affecting each of the groups.

Jones, Rob 2015: “They (hatchery fish) don’t act like and they don’t survive like wild fish do,” NOAA’s Jones said. “You’re putting the wrong fish in the stream, and that poses a risk to wild fish.”

The processes indicated by these results can be expected to lead to eventual genetic divergence between the new hatchery stock and its wild source population, thus limiting the usefulness of the stock for conservation purposes to only the first few generations.”

Lynch and O’Hely 2001: “Our results suggest that the apparent short-term demographic advantages of a supplementation program can be quite deceiving. Unless the selective pressures of the captive environment are closely managed to resemble those in the wild, long-term supplementation programs are expected to result in genetic transformation that can eventually lead to natural population no longer capable of sustaining themselves.”

McClure et al. 2008: “Continued interbreeding with hatchery-origin fish of lower fitness can lower the fitness of the wild population. Generally, large, long-term hatchery programs that dominate production of a population is a high risk factor for certain viability criteria and can lead to increased risk for the population. The populations meeting ‘high viability’ criteria will necessarily be large and spatially complex. In order to meet these criteria (spatial structure and diversity) there should be little or no introgression between hatchery fish and the wild component of the population. Populations supported by hatchery supplementation for more than three generations do not in most cases meet ICTRT viability criteria at the population level.”

“Artificial propagation does not contribute to increased natural productivity needed for viability, and appears in most cases, to erode productivity of wild populations.”

Miller et al. 1990: “Over 300 (hatchery) supplementation projects were reviewed and the authors found: 1) examples of success at rebuilding self-sustaining anadromous fish runs with hatchery fish are scarce (22 out of 316 projects reviewed), 2) success was primarily from providing fish for harvest, and 3) adverse impacts to wild stocks have been shown or postulated for every type of hatchery fish introduction to rebuild runs.”

Moran and Waples 2007: “...we show some compelling differences in reproductive success of hatchery and wild fish. Naturally spawning hatchery fish are less than half as productive as wild fish.”

Nickelson 1986: “Hatchery coho juveniles are more abundant after stocking in streams but the result is fewer adult returns and fewer juvenile coho salmon in the next generation than in streams that were not stocked.”

Nickelson 2003: “Hatchery programs designed for harvest augmentation should be removed from basins with habitat that has high potential to produce wild salmonids. To aid recovery of depressed wild salmon, the operation of hatcheries must be changed to reduce interactions of hatchery smolts with wild smolts. A program that reduces harvest, restores habitat, and reduces hatchery effects is necessary.”

NMFS 2010: “Hatchery production has been reduced to a small fraction of the natural-origin production. Nickelson (2003) found that reduced hatchery production led directly to higher survival of naturally produced fish, and Buhle et al. (2009) found that the reduction in hatchery releases of Oregon coast coho salmon in the mid1990's resulted in increased natural coho salmon abundance.”

ODFW 2010: “Chilcote and Goodson examined data sets on population abundance for 121 populations of coho, steelhead, and Chinook in Oregon, Washington, and Idaho. They found that population productivity was inversely related to the average proportion of hatchery fish in the naturally-spawning population, consistent with the findings of Buhle et al. (2009). The magnitude of this effect was substantial. For example, a population comprised entirely of hatchery fish would have one tenth the intrinsic productivity of one comprised entirely of wild fish. There was no indication that the significance or strength of this relationship was different among the three species examined (chinook, coho and steelhead). In addition, there was no indication that the type of broodstock (integrated with the local natural-origin population versus segregated) affected the significance or intensity of the response.” (Section 2: Updating the Scientific Information in the 2008 FCRPS BiOp May 20, 2010, Page 118 and Lower Columbia River Salmon Recovery Plan 9-2010 ODFW)

ODFW 2010a: “For example, the reduction in productivity between a population comprised entirely of wild fish and one comprised of equal numbers of hatchery and wild fish is 66 percent for steelhead, 76 percent for coho, and 43 percent for Chinook.”

RIST 2009: “Most information available indicates that artificially-propagated fish do have ecological impacts on wild salmonid populations under most conditions (e.g. a 50% reduction in productivity for steelhead in an Oregon population). To the degree that the trait distributions seen in wild salmon populations are adaptations to their environments, selection imposed by the hatchery environment could result in reduced fitness of hatchery fish in the wild.”

Theriault et al. 2011: “Supplementation of wild salmonids with captive-bred fish is a common practice for both commercial and conservation purposes. However, evidence for lower fitness of captive reared fish relative to wild fish has accumulated in recent years, diminishing the apparent effectiveness of supplementation as a management tool. To date, the mechanism(s) responsible for these fitness declines remain unknown. In this study, we showed with molecular parentage analysis that hatchery coho salmon (Oncorhynchus kisutch) had lower reproductive success than wild fish once they reproduced in the wild. This effect was more pronounced in males than in same-aged females. Hatchery spawned fish that were released as unfed fry (age 0), as well as hatchery fish raised for one year in the hatchery (released as smolts, age 1), both experienced lower lifetime reproductive success (RS) than wild fish.

Waples 1994: Hatchery captive brood stocks may shift genetic structure in natural populations.

Webster 1931: “To those of us interested in fisheries work, artificial propagation is never and should never be considered as replacing natural reproduction.”

Appendix 3.

Reference Quotes from Scientific Literature on Stock Transfer on Wild Salmonids:

Chilcote et al. 2011:

“In most cases, measures that minimize the interactions between wild and hatchery fish will be the best long-term conservation strategy for wild populations.

HSRG. 2015. Annual Report to Congress on the Science of Hatcheries. A report on the application of up-to-date science in the management of salmon and steelhead hatcheries in the Pacific Northwest July 2015

“Local adaptation of hatchery populations is achieved by using local broodstock (indigenous, in the case of integrated programs; locally returning in the case of segregated programs) and avoiding transfer of hatchery fish among watersheds.”

Hard et al. NOAA Technical Memorandum NMFS-NWFSC-2:

Emery Wagner April 1, 1988. Proposed steelhead study to protect wild steelhead. ODFW Intra-Departmental Memo.

“....there is increasing evidence that some stock transfers may result in fewer net benefits than expected. Problems have resulted from the transfer of disease organisms between stations, and from genetic alterations to the native stock. Managers are faced with administrative or operational needs to transfer stocks to efficiently operate individual hatcheries and to satisfy production requirements of several hatcheries, yet must avoid alternatives that may reduce the long-term productivity of hatchery and naturally reared populations.

Johnson, Marc A. & Thomas A. Friesen (2014) Genetic Diversity and Population Structure of Spring Chinook Salmon from the Upper Willamette River, Oregon, North American Journal of Fisheries Management, 34:4, 853-862

“The weak but significant genetic structure we observed among populations from different subbasins suggests that conservation and recovery efforts for UWR spring Chinook Salmon should be implemented through subbasin-specific management actions, as identified by ODFW et al. (2011).”

“Management practices involving widespread transplantation of nonlocal stocks may also further endanger listed species or contribute to the decline of unlisted species. Continued artificial propagation of unlisted species must minimize the potential for deleterious effects on both listed and unlisted species if it is to be consistent with the maintenance of genetic and ecological diversity in Pacific salmon.”

“Current restrictions on stock transfers among UWR spring Chinook Salmon populations should further preserve and possibly strengthen genetic structure among populations from different subbasins, thereby promoting adaptation to local conditions.”

Paul Reimers (ODFW) Intra-department memo to Jim Martin (ODFW) July 11, 1994 Regarding Stock Transfers and Use of Rogue River Spring Chinook.

“I have heard rumors that there is interest for a wider use of Rogue spring chinook along the coast of Oregon (Coos Bay and Yaquina Bay) and in the Columbia River, possibly spurred by what is being proposed in Coos Bay. I want to make it clear that I do not like stock transfers and believe that the Coastal Chinook Plan has defined wording about that issue for good biological reasons.

“Quite frankly, we have too many stocks of fish at risk to be considering this approach to quick- fix fisheries with foreign stocks that might further jeopardize any of our native stocks. We should first learn to make existing local hatchery stocks better contributors to fisheries and spend more time trying to figure out how to help our wild stocks to make recoveries so they too can provide more fishery benefits. These seem like higher priorities to me than entering an even bigger unknown world and thinking about wider use of stock transfers to derive new or lost fishery benefits.”

Waples. 1999. Dispelling Some Myths about Hatcheries. American Fisheries Society.Fisheries Vol. 24, No. 2.

“...clear evidence exists that stock transfers of fish can lead to the spread of exotic pathogen and parasites into natural fish populations well out of the historic range of the disease.”

“Programs that involve translocated stocks can lead to straying on a geographic scale much greater than would occur naturally.”

“Effects on natural populations are a function of the proportion of natural spawners that are hatchery fish, not the fraction of the hatchery population that strays.”

“Therefore, a hatchery program with a relatively low stray rate can still substantially affect natural populations, particularly if the hatchery is large and/or the natural populations are depressed (low abundance).”


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Bowles, Edward. 2008. Amended Declaration of Edward Bowles in Support of the State of Oregon’s Motion for Summary Judgment. Oregon Department of Justice.

Buhle, E. R., K. K. Holsman, M. D. Scheuerell, and A. Albaugh. 2009. Using an unplanned experiment to evaluate the effects of hatcheries and environmental variation on threatened populations of wild salmon. Biological Conservation 142:2449-2455.

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