0^ WATERSHED MANAGEMENT AND FISH HATCHERY r PRACTICES IN THE PACIFIC NORTHWEST Y 4. M 53: 103-3 =^=^~^= Uatershed naeajenent and Fish Hatch... llNvj THE SUBCOMMITTEE ON ENVIRONMENT AND NATURAL RESOURCES OF THE COMMITTEE ON MERCHANT MARINE AND FISHERIES HOUSE OF REPRESENTATr\^S ONE HUNDRED THIRD CONGRESS FIRST SESSION ON WATERSHED MANAGEMENT AND FISH HATCH- ERY PRACTICES IN THE PACIFIC NORTHWEST MARCH 9, 1993 Serial No. 103-3 Printed for the use of the Committee on J^erph^t Marine and Fisheries oniMerchant Marine anc '"' '0 m. U.S. GOVERNMENT PRINT^4/l)f ^ICE 68-158 ^ WASHINGTON : 1993 "^ *'»»». .^'^ "--""^gt^; For sale by the U.S. Government Printing Office Superintendent of Documents. Congressional Sales Office, Washington, DC 20402 ISBN 0-16-040956-X WATERSHED MANAGEMENT AND FISH HATCHERY PRACTICES IN THE PACIFIC NORTHWEST Y 4. M 53: 103-3 =^__ Uatsrshed nasagenent ani Fish Hatch... llNvT THE SUBCOMMITTEE ON ENVIEONMENT AND NATURAL RESOURCES OF THE COMMITTEE ON MERCHANT MAEINE AND FISHERIES HOUSE OF REPRESENTATIVES ONE HUNDRED THIRD CONGRESS FIRST SESSION ON WATERSHED MANAGEMENT AND FISH HATCH- ERY PRACTICES IN THE PACIFIC NORTHWEST MARCH 9, 1993 Serial No. 103-3 Printed for the use of the Committee oilt' i"; ;.Vi°LS'?^ i'LI.'rSi',;,'?:^.- Room 1334, lonntoortt) i^ouit ©flia Suiltnng •. w^ara. c*«C«sn* nO«ix CamOk'** f^l* ^ «MC M*w TO** T>«^L«1 •■ «MO«iWS HAMI tMCIXN euJ««LA50 yrs) and should include the entire watershed from headwater streams to 10 55 estuarine tidal marshes. Only at spatial and temporal scales of these magnitudes do the watershed hydrologic patterns, natural disturbances, and riparian forests become meaningful in the discussion of the restoration and management of naturally spawning fish populations. To accomplish watershed restoration a major shift in philosophy, assumptions, and strategies toward fish habitat restoration and management is necessary (Frissell 1992). The restoration of streams and riparian zones throughout a watershed is a formidable task requiring an unprecedented level of cooperation and willingness to alter current land use practices (Gregory et al. 1991, Sedell and Beschta 1991, Bisson etal. 1992). At present, there are no watershed-level restoration models applicable to the Pacific Northwest. However, river and watershed restoration approaches are beginning to emerge that focus upon reestablishing the key components of an ecologically healthy watershed (Sedell et al. 1990, Sedell and Beschta 1991, Frissell 1992). We have many of the technologies necessary to restore forested watersheds in the Pacific Northwest (e.g., horticultural, silvicultural, engineering, geologic, and hydrologic techniques). What we lack is the breadth of vision and cooperation necessary to apply these technologies appropriately in a context of watershed restoration and management. An ecosystems approach to watershed restoration and management will incorporate fundamental watershed physical processes and the natural biologic diversity of the landscape. For example, studies of the recovery of aquatic systems from natural disturbances have revealed the occurence of refugia, undisturbed habitats that function as a source of colonists to adjacent disturbed areas (Sedell et al. 1990, Frissell 1992). The ecologic properties of refugia throughout watersheds will be critical in the restoration of degrated rivers and streams. None the less, we lack restoration projects that are based upon the restoration of watershed ecosystem processes. Restoration at this scale is our only real hope for sustaining harvestable naturally-spawning fish populations. To accomplish this will take unprecedented cooperatton between public agencies, regional universities, Indian Tribes, and private industry. We propose the development of a Pacific Northwest Regional Initiative for Watershed Studies, Restoration, and Management. The goal of the initiative would be the development of solutions to our region's watershed problems. The scope of the issue is beyond the ability of a single state government or federal agency to solve. We suggest an initiative open to all federal and state agencies, regional universities, Indian Tribes, and private industry. Staff would include policy makers, economists, social scientists, and natural and physical scientists from across local, state, and federal agencies, regional universities, Indian Tribes, and private industry. The task would be to develop solutions to regional as well as watershed level problems. Components of such an initiative would include: 1 . Basic research into watershed science. 11 56 2. Establishment of a representative array of watershed reference sites throughout the Pacific Northwest. 3. Establishment of watershed restoration projects as demonstration sites for research and training. 4. Development of training programs for future professional watershed stewards. 5. Emphasis on watershed and regional consensus process. 6. Watershed restoration and management technical and policy information transfer. 7. New approaches to commodities extraction (e.g. riparian silviculture). V The Economic Benefits of Managing Rivers on a Ecosystem Basis - Compared to the Existing Piecemeal Approach Restoration and management of rivers and watersheds on an ecosystem basis is the only approach that will insure the sustainability of healthy native fish populations and watershed health, ocean han/esting levels not with standing. Without the active implementation of a region-wide watershed restoration initiative throughout the Pacific Northwest, potentially hundreds of native salmon stocks will go extinct bringing on a collapse of the regional fishing industry (Nehlsen et al. 1991). Concerning this crisis, proactive measures will save a significant part of our regional economy. Regional economic benefits resulting from ecosystem management of rivers and streams include: 1 . Sustainable harvest of native fish populations. 2. Development of a sustainable riparian silviculture. 3. Reduced litigation and downstream mitigation and clean-up. 4. Development of specialty tree crops for pulp and fiber (e.g. pibplar trees). 5. The export natlonaly and globally of watershed restoration and management expertise and techniques. 6. Improvement of human health through recreation. 7. A sustained ecological tourism industry. 12 57 CONCLUSION If we do not act now we will we stand to lose much of what makes the Pacific Northwest unique. We will lose a significant aspect of our region's sustainable economy. The Pacific Northwest salmon are an indicator of our regional watershed health. Their loss will surely be followed by a number of other less visible riverine and riparian organisms. If we do not act we will be mandated to action as a society by provisions of the Endangered Species Act. Salmon species will be listed as endangered and recovery plans will be developed and implemented to recover and restore their critical habitat. We can either go forward with a proactive plan or wait and find ourselves facing a more significant crisis. We will end with the loss of species, loss of jobs, and a loss to future generations. We do not have adequate scientific or management infrastructures to deal with the scale of the crisis at hand. We need a new interdisciplinary, inter-agency and inter-university regional initiative where watershed- level issues can be defined and solved. New professional resource stewards need to be trained. We have the collective expertise in our universities, local, state, and federal agencies, Indian Tribes, private industry, local, and state governments necessary to pursue a regional watershed effort. Our watersheds, if provided with adequate protection and nurture, will supply us with many ecological services into the future. We can leave our children a regional legacy of ecological health based upon ecosystem restoration and the sustainable use of our rivers, streams and watersheds. Finally, understanding and integrating human activities into the watershed management process must be achieved if the region is to attain any form of sustainability (Ruckelshaus 1989, Naiman 1992). Robert J. Naiman Director, Center for Streamside Studies Kevin L. Fetherston Center for Streamside Studies Address: Center for Streamside Studies AR-10 University of Washington Seattle. Washington 98195 Telephone: (206) 543-6920 FAX: (206) 543-3254 Acknowledgments. The authors would like to thank Dr. Rick Edwards and Jennifer Sampson for their constructive comments on this manuscript. 13 58 Acknowledgments. The authors would like to thank Dr. Rick Edwards and Jennifer Sampson for their constructive comments on this manuscript. Literature Cited Allendorf, F.W., N. Ryman, and F.M. Utter. 1987. Genetics and fishery management - past, present, and future. In Population Genetics and Fishery Management. University of Washington Press, Seattle, Washington. Allen, J.D. and A.S. Fletcker. 1993. Biodiversity conservation in running waters. Bioscience 43: 32-43. Beschta, R.L., R.E. Bilby. G.W. Brown. L.B. Hltby, and T.D. Hofstra. 1987. Stream temperature and aquatic habitat: fisheries and forestry interactions. Pages 1 91 -232 in E.O. Salo and T.W. Cundy, (eds). Streamside management: forestry and fisheries interactions. Contribution 57, Institute of Forest Resources, University of Washington, Seattle, Washington, U.S.A. Bisson, P.A., and J.R. Sedell. 1984. Salmonid populations in streams in clearcut vs. old- growth forests of western Washington. Pages 121-129 In W.R. Meehan, T.R. Merrill, Jr., and T.A. Hanley, (eds). Fish and wildlife relationships in old- growth forests. American Institute of Fishery Research Biologists, Juneau, Alaska, USA. Decamps, H., and Naiman, R.J. 1989. L'6cologie des fleuves. La Recherche 20: 310-319. Eley, T.J. and T.H. Watkin. 1991. The uncertain fate of the Pacific salmon - In a sea of trouble. Wilderness. Fall pp. 19-26. Everest, F.H. 1987. Salmonids of western forested watersheds. Pages 3-8 in E.O. Salo and T.W. Cundy, (eds). Streamside management: forestry and fisheries interactions. Contribution 57, Institute of Forest Resources, University of Washington, Seattle, Washington, U.S.A. Frissell, C.A. 1992. A new strategy for watershed restoration and recovery of Pacific salmon in the Pacific Northwest. Draft report for The Pacific Rivers Council. Eugene, Oregon. Grant, G.E. 1986. Downstream effects of timber harvest activity on the channel and floor geomorphology of western Cascade streams. Dissertation. Johns Hopkins University, Baltimaore, Maryland, USA. Gregory. S.V., F.J. Swanson. W.A. McKee, and K.W. Cummmins. 1991. An ecosystem perspective of riparian zones. Bioscience 41: 540-551. 14 59 MacLean, J.A. and D.O. Evans. 1 981 . The stock concept, discreetness of fish stocks, and fisheries management. Canadian Journal of Fisheries and Aquatic Science 38: 1889-1898. Meffe, G.K. 1992. Techno-arrogance and halfway technologies: salmon hatcheries on the Pacific Coast of North America. Conservation Biology. 6: 350-354. Naiman, R.J. (ed) 1992. Watershed Management - Balancing Sustainability and Environmental Change. Springer-Verlag, New York. Naiman, R.J., T.J. Beechie. LE. Benda, D.R. Berg, P.A. Bisson, LH. MacDonald, M.D. O'Connor, P.L Olson, and E.A. Steel. 1993. Fundamental elements of ecologically healthy watersheds in the Pacific Northwest coastal ecoregion. In R.J. Naiman (ed) Watershed Management - Balancing Sustainability and Environmental Change. Springer-Verlag, New York. Naiman. R.J. and H. D6camps (eds) 1990. The Ecology and Management of Aquatic- Terrestrial Ecotones. UNESCO. Paris, and Parthenon Publishing Group, Cranforth. United Kingdom. Nehlsen, W., J. E. Williams, and J. A. Lrtchatowich. 1991. Pacific salmon at the crossroads: stocks at risk from California, Oregon. Idaho, and Washington. Fisheries (Bethesda) 16: 4-21. Ruckelshaus, W.D. 1989. Toward a sustainable world. Scientific American. September: 166-175. Sedell, J.R. and R.L Beschta. 1991. Bringing back the "bio" in bioengineering. American Fisheries Symposium 10: 160-175. Sedell. J.R., F.H. Everest. F.H.. and D.R. Gibbons. 1989. Streamside vegetation management for aquatic habitat. In Proceedings of National Silvicultural Workshop: Silviculture For All Resources. U.S. Department of Agriculture. Forest Service, Timber Management. Sedell. J.R. and J.L Froggatt. 1984. Importance of streamside forests to large rivers: the isolation of the Willamette River, Oregon, U.S.A.. from its floodplain by snagging and streamside forest removal. Verb. Intemat. Verein. Limnol. 22: 1828-1834. Simenstad, C.A.. D.J. Jay. and C.R. Shenwood. 1992. Impacts of watershed management on land-margin ecocystems: the Columbia River estuary. In R.J. Naiman (ed). 1992. Watershed Management - Balancing Sustainability and Environmental Change. Springer-Verlag, New York. 15 60 TESTIMONY OF DR. JAMES R. KARR, DIRECTOR INSTITDTE FOR ENVIRONMENTAL STUDIES UNIVERSITY OF WASHINGTON, SEATTLE. WASHINGTON BEFORE THE COMMITTEE ON MERCHANT MARINE AND FISHERIES and SUBCOMMITTEE ON ENVIRONMENT AND NATURAL RESOURCES MARCH 9, 1993 Thank you, Mr. Ch«lmuin, for Inviting im to «pp««r b«for« this conmlttBe to cominent on the ctatue of watersheds In the Pacific Northwest and solutions to restore them, including naturally spawning aalmon populations. ^ What <« vour ss»e««m.nt of rh« eondltton of rtvar BYStene In Ch« Pacific Northwest und«r the present nanagentent reginte? Like rivers throughout North Anerica. the rivers of the Northwest have been decimated in the last century. The magnitude of degradation In river resources eclipses that of other resources that have received far more attention (e.g., wetlands). That degradation is manifest in alteration and destruction of stream channels, alteration of river flow patterns, speciee endangerment and extinction, introduction of contaminants, declines in commercial- and sport-fishery harvests, consumption advlsorlas due to contamination of fish and shellfish, and degradation of the aesthetic values of those river systems. An abundance of clean, productive streams and riparian corridors has been reduced to vestiges. Appendix I provides more detail on these points with quantitative Information and citations (Appendix II) for the Northwest and nationally. Although continuing degradation of aquatic systems is obvious, even to the untrained eye, concern by government agencies has been weak, inappropriately focussed, and largely ineffective at reversing resource declines. Failure to reverse the trend of aquatic degradation is xinacceptable on legal, scientific, economic, and ethical grounds. 2a. What are the essential arcribures of healthv vatershcdt nnd flab habitat? A watershed "can be considered healthy when its inherent potential is realized, its condition is stable, its capacity for self -repair when perturbed is preserved, and minimal oxcamal support for management is needed" (Karr et al. 1986). By any of these eriterle the watersheds of the Northwest cannot be considered healthy. Over 97% of the naturally spatming salmon runs of the Columbia River have been lost. Further, and perhaps of greater relevance, 100% of the production of major areas of the Columbia River watershed have been lost. The situation Is similar for salmon, trout, and steelhead throughout the region. How would we respond as a society if our agricultural productivity declined by over 90%7 All watersheds cannot be preserved in pristine condition. But we can and should seek to protect rivers and their watersheds from the more egregious 61 Influencea of huaAn soolsty. Spacial Attention chould ba p«ld to protecting the interests of individuals alive today (Intragenerational equity) and future generations (interganeratlonal equity). The ability to sustain a healthy biologioal ooomiinlty Is one of the best indicators of the potential for beneficial use (broadly defined) of a vater resource. Support of healthy asseablages of aquatic organisns requires the proper quantity and quality of water, a straan channel in relative equilibrium with its watershed (supply of water and sedlaent, geological substrate, and vegetation cover, etc.), riparian vegetation that buffers the Impact of terrestrial environments , and land use with nlnlnnim negative Impact on riparian and stream channel environments. In their natural state, watersheds contain an Interactive nosalc of environments that extend from headwater streaas and wet meadows at the upper limit of drainage basins to the ocean. This mosaic includes small streams and large rivers, riparian zones, the terrestrial watershed, groundwater (Including the hyporhelc zone), and neat coastal and estuarine areas. All are integral components of watersheds capable of supporting viable salmonid populations . Individual hxinans actions within the watershed may produce small effects, but when these Impacts are combined, they spawn more complex pr6blems that cascade across the landscape and down the river, resulting in considerable loss of natural resource values. The cumulative affect is often Ignored because most conventional aquatic resource evaluations consider only local water quality paranecers. Human actions degrade water resources by their Influence en five components of river systems (Table 1). Examples from Northwest watersheds are given for each of the five factors in Table 2 . Efforts to protect the aquatic resources of Northwest watersheds are doomed to failure, unless they explicitly Incorporate knowledge of these factors into a comprehensive planning process that integrates the Influences of local and regional human actions. 2SL. — What is the role chat riparian areas plav in promoting "ecosvstam health." as well as providing high quality fish habitat? Riparian areas serve as buffer zones between the terrestrial and aquatic components of regional landscapes (Karr and Schlosser 1978). Thus, riparian corridors are an important first line of defense because they have the capability of mediating the influence of landscape alteration on river resources. But the cumulative effect of activities In upland areas can overwhelm the effectiveness of rlpsrian buffer strips. Thus, riparian strips should not be oversold as cures for depressed fish populations. Beware of the quick fix I I Clean water, flood control and hatcheries have been the rallying cries of the paat, but they have failed to protact the resource. Habitat, riparian corridor protection, barging of Juvenile salmon, and bounties on squawflsh are today's rallying cries. Host are important tools in the restoration arsenal but none is adequate. 62 Table 1. Fiva major classes of envlrottiMntal factors that affect aquatic biota. ArrovE indicate the kinds of ef facts Chat can be expected from huaan acdvities (From Karr 1991) . ecological impact of human-induced alterations 1 .food (tnergyl source • lyat. tmowL ind OUKK sn ot Offinc mt^ilil tnemnq i mm !am n xsimn ton* otma VAiary praoueson in tn« MTMKi • ituaniloaiitmotaviilMK 2. water quality • Kfflpanon ■wMilY • «iwiv«d oiy^n • nuvitittt (pnminly nilragtn «n4 enattmonitl • wgwtG ano inaqtnie cntmlcU. ntunwdlywiwe • r«ivY ii<«(M vu isiie sibianai .pH 2 nabtat suucoire • juaimii fyp* • oaier aaon ana cunvrt v«Maly • seaomng, nwiwY. ind rxlinq suots • «v«nify (pools. nIAn. woaoy =>; i> ■ cai»> w« and tnio* !)ow regime . ■noon) dsinoueon ct IMOS and low tows £ ftics: iwe.'acscns • esnoetto" • oxoawn I^ BIOLOGICAL n^JTEGRTTY: A LONG-^fEGI_ECTED ASPECT OF WATER RESOURCE MANAGEME>a' James R. Kami oaocaiao eoani careeuui* o.'^arac .'Tiamr movaiad M ^aruu'ai* erganie nanir inenuad ai$ai erepjnon I tipinMa «nie*iaa«« aminas • mcituad i/tiarf • aJMfM dkimai cyoa ol diasolvee oiYgan • inenaaao nuaiana (npfoaty HkiM naoyao and ohoapnoAja) => ■ inoaaiad toxica • alarad aunty • oaenasad labitty ot luenaa and Urto dua (0 aroMn am uomsnann > mora unlann wanrdeoti • raducad tafiitai naaraganaily • dacraasad cnannai snuosty • (MuKd KaMat anas du* IS anonanad • daatascd nsream cover and itpaiian vagauHn • aiarad tow ainmas (botfi nuQnikida and Iraquaney cl lagli and im towai • Moraatad mtxavn now vaMuy • rteoEased nwMiun tow vaMity • iMucad i>««rwy o< mtcreratttat vataoKS • (ewer piptecttd «» • incraiiad iraguanCY ol diuawd Ush > alieitd pmiary and uoonoary produeaon ■ aiarad npne imjoiM ■ aiarao daoooieatiaan raias and amnq • Aaueoon M aaaaanai inymmi . iiMK m soaoai OOTipoaaon and raiaawa aoundancas f iWB in imafMoa kmcMiai group) (mcrtaaao taraoari and deaeasea vnaani) • tfluttinnpnie^tldslincraaiedamnnwas ana daeraasea pooueresi • ineiaaaad aaduaney el Ian nyenoaaaon • Mraasad >«quancr d aiooc taaoes 63 T«bla 2. Examplas of infliMncas on «ach factor r*pr«s«iitatlve of problems In Northwest vatershads. FACTOR Food (energy) source Water Quality Habitat Structure Flow Ragiine Biotic Interactions TYPTCAI. DRGRADATTQN IN NORTHWEST WATERSHEDS Supply of organic material from riparian corridor altered Nutrients from the carcasses of adult salmon after spawning reduced or not available Elevated tenperatures Oxygen depletion Chenical contanlnants Sedinentation and loss of spawning gravels Obstructions that Interfere with movenent of adult or Juvenile salmonlds Lack of coarse woody debris Destruction of riparian vegecadon and overhanging banks Lack of deep pools Altered abundance and distribution of constrained and unconstrained channel reaches Altered flows that limit survival rates during any phase of the saloon life cycle Increased predatlon on young by native or exotic species Overharvest by sport or commercial fishers These examples of best management practices are much like the best management practices defined by soil conservationists to protect soil resources. But like soil conservation BMP* , application of watershed planning processes requires replacement of the current fragmented approach to BMP use with development of integrative Best Management Systems (Karr and Schlosser 1978). The legacy of narrow planning programs can be seen In fish ladders and hatcheries, solutions chat developed to correct symptoms rather than problems. Like other BMP's. riparian corridors must be integrated into a watershed-level best management system. Only by integrating the planning process across landscapes can we protect river systems . 3a. Are existing mnnnyement regimes on state, federal and nrivatc land adequate to prevent further degradation of watersheds and fish habitat? NO! The decline in water resource quality, salmonlds populations, and Northwest watersheds continues because existing programs and the way they are Implemented are not adequate. The goal of the Clean Water Act, to "restore and maintain the physical, chemical, and biological integrity of the Nation's 64 waters" Is adwquat* but that goal is not claarly •stablishod by th« ioplenenting regulations and pollciss of th« aganclas rasponslbla for enforcing the Act. For years the Clean Water Act has been imp lamented as if crystal clear diatilled water flowing down concrete channels is the goal of the Act. The Endangered Species Act is inadequate beoauee, although it provides an energency room for treatment of patients (listed species) , it does not provide a hospital or a preventative care progran that prevents the need to list and the listing process fosters legal impasses and extreme social dislocations. The National Forest Management Act of 1976 states that "management prescriptions. . .preserve and enhance the diversity of plant and animal communities," a goal that is attained by few forest plans. Most past government programs have concentrated narrowly on issues such as prevention of chemical contamination (pollution), flood control, construction of fish ladders for adult passage, or harvest of wood. Often those programs have stimulated resource degradation due to aecondary influences or because they did not address all factors responsible for degradation. Rather than programs designed to maintain the natural regeneration capacity of these systems, we tried to substitute expensive, and usually unsuccessful, technological fixes. Indeed, technological fixes often contributed to the problem. Finally, current management programs require increasing amounts of societal energies and scarce funds to protect what remains and have little chance of succeaa . 3b. If not, are there anv statutory or admlnlstratlvB barriers that would hinder thanpes in the manafgnieTit regime for rivers? YES I Current statutory programs and administrative structures are too fragmented to allow anything but a piecemeal approach to the protection of water resources. Statutes narrowly focus on individual problems such as endangered species, soil erosion or water quality. For the past two decades, wetlands have been the focus of major attention while rivers have been deif^radcd by numerous human actions. Increased attention to old-growth forest has not adequately incorporated the water resource impact of forest alteration. Each habitat, species group (e.g. marine mammals), or resource (soil, water) is treated independently in different legislative initiatives and responsibilities are fragmented among agencies despite the broad connections among these resources and the values they provide for human society. Incentives for agencies to work In an integrative fashion at the watershed level are nonexistent. One can conceive of legislation such as a Top of the Mountain Act or Bottom of the Lake Act as we attempt to protect all environments important to human society. Rather, we need a broad societal policy that protects ecological integrity or health, and avoids biotic impoverishment, the progressive erosion of Earth's capacity to sustain living systems, including human society (Uoodwell 1990, Angermeier and Karr in review). 65 ■\^ Tn adrilfion .re ^K.r> nthmr barrlara faconoalc. BOcial ■ or PQlltical) that might alBo cr«fltg probl^M? Perhaps tha Boat important barriar ia tha lack of a aoclatal litaracy about the connactlona aaong raaourca systaaa and th* dapandance of human sociaty on thoaa raaoureaa. Aa a raault. we act aa if our ability to altar carrying capacity through technological innovation la unliaitad. But ve are subject to many eonatralnts because, although our cultura and technology changes rapidly, we are atlll dapandant upon alowly changing ecological syBtams. New policy goals and manageaant objectivea that clearly integrate biological, social, cultural, and econoaic perapactives are needed. The current predicaiaant is to a large axtant a by-product of the growth of economic models that Herman Daly (1991) characterizes as "boundless bull." Economics is an abstract science that. In Its most coimon form, distorts the relationship between the economy, society and natural resources (Daly and Cobb 1989, Costanra 1991, Karr 1993). In reality, the human economy is supported by an array of services supplied free by natural syatema. Thus, the concept of value must be extended beyond what "can be computed simply in terms of consumptive preferences" (Haskell et al. 1992). The failure to recognise the dependence of tha economy (the frosting on a layer cake) on a healthy society and a natural resource base (the upper and lower layers of the cake) is beat Illustrated by the simplistic but often cited environment vs. economy dichotomy . 4. What management techniQuea are available cc maintain and raatpre hi£h quAltrv watersheds that will «u«tain harvetable. naturally anawning fish populations? An organized program ia needed to restore these vital ecological systems to prevent extinctions, declines in valued resources (including consumptive and nonconsuaptive use of those resources), and an emerging water crisis (including water rationing in Seattle last yearl!). Comprehensive watershed- level, restoration programs should involve a fiv«-scep process: 1) Identify resource condition (status and trends); 2) Identify the components of ecological health or integrity that have been degraded; 3) Identify the human action(G) responsible for the degradation; 4) Establiah a watershed- level plan to reverse the degradation; and 5) Evaluate the success of protection and reatoration programs. The final step should involve direct assessment (step 1) of the condition of valued biological resources (e.g., salmon) to detaraine If program goals are being accomplished. The iaportance of avoiding sole dependence on use of water quality parameters or "habitat quality" as surrogates of biological Integrity or atatua of salmon populations cannot be overemphasized. Special care should be exercised to Insure that suceees Is 66 not roaasurad in tarns such as number of construction projacts, permits issued, or hatchery fish released. Procedures developed in recent years to protect the biological integrity of water resotirees (K^rr et al. 1986, Lyons 1992, Kerans and Karr in revlev) provide easily used and ecological sophisticated approaches to assess resource condition. Biotic integrity assessment can easily be Integrated with watershed- level planning at diverse apatlal scales. The principles required to plan protection and restoration prograos are similar across watersheds. But, bacauae hunuin influences and natural conditions vary among watersheds, watershed specific evaluations must' be undertaken to determine the cause of degradation. Then and only then, can plans be developed to correct local problems. General solutions (such as release of hatchery fish or habitat reconstruction) are not appropriate in the absence of careful problem assassment. Past approaches were often ill- conceived because planners proposed solutions as if ecosystem dysfunction could be reversed without broad understanding of those systems. Successful approaches should be based on a broad planning perspective and a planning effort based on evaluation of local ecological, aocial and economic conditions. The management techniques have been available for years but they have not been uaed in an integrative way. The window of opportunity to reverse this decades-long trend in declining water resources and salmon populations is closing because of the extant of loss of watershed processes upon which these salmon depend and, thus, the salmon themselves. This decline can only be reversed by substantive change In our actions and In the conceptual framework uaed to define those actions. Immediate short-cerm actions are essential to provide the opportunity for long-term restoration programs. These actions include: 1. Identification and protection of existing high quality sites, sites with healthy biological communities. Recent scientific workshops have concluded that immediate actions must be taken to preserve the few healthy watershed refuges that remain in the region. Those refuges hold most of the spawning and rearing habitat for salmon. Quick action Is needed to identify and protect those areas to safeguard existing salmon runs and provide viable populations that can recolonize additional areas to be restored. 2. Stabilize roads and other erosive or otherwise unstable areas In and near these protected areas 3. Move to restore nearby degraded reaches, taking advantage of the protected refuges as sources of colonists These mostly local scale activities must be Integrated with watershed level planning that produces Best Management Systems for regional landscapes. The cost of these efforts will not be high relative to the benefits to society. Environmental benefits Include Improved water resource quality, continued vitality of forest and river systems, protection of soil resources, more conservation minded uses of water, and protection of the aesthetic quallcy of the Northwest environment. 67 S Are there economic benefit* to manaylny rlvr« on *n •eoBVCaa ba.ty . eonmared to our currant placamaal appromch? Econonic b«n«£ltB will accru* from improving eha affaetivanass of programs to protact vacer raaourcaa . Jeba loat in tha aalaon fishing and tourism Industries will be reatorad; jobs will ba craatad and the eeonoiaic base and social structura of rural connunitiaa will ba praaarved. Uatar supplies (both quantity and quality) will be pcotactad for agricultural and urban uses. Dredging of rivers and harbors will ba raduead as the aaount of sediment transported to rivers declines. The Northwest has an opportunity to avert a disaster that has bafallen the Midwest . Tha pursuit of naximuB yiald and agrioultural profit in that region has had catastrophic effects on tha social fabric of agricultural comnunitias. We should work now to avoid further aeenomlc and social dislocation in the Northwest dua to ovarharvaat of natural resources and a lack of attention to tha fabric of society. CONCLUSIONS Rivers are in nany ways the lifablood of human sociaty. They provide water for donastic and industrial uses, they serve as transportation corridors, they provide food, recreation and scenic beauty. In addition to their direct importance to human society, their status is indicative of the health of the surrounding landscape in the same way that blood samples provide important insight about the health of humans. Our future depends on our ability to create positive, long- lasting solutions. The tiro most Important components of that effort will be 1) protection and restoration of natural resource systems and 2) diversification of the regional economic base Ue can no longer exploit and alter the landscape as if it is infinitely resilient to human actions. An initiative that combines a watershed planning perspective vlth a watershed restoration initiative provides the central organizing principles that are fundamental to long-term success. Uater'e Dobillcy, Integrative qualities, and importance to all biological systems makes examination of the status of water resources a practical approach for assessing the condition of the landscapes upon which humans depend for their long-term "health." 68 APPCKOIX I • nniMOMY Of JMCS R. KMR NMCH 9, 1993 TMLE 1. IXAMPUS TO ILLUSTRATC TIC CTATUt Of U.S. ttVIIS MO TNEIR FLOOOnAIM 1 Of 3.2 Mdlien alln of ri««r« in th* eontinantal Unitad ttatM, only a ar* haalttiy anough to ba e«naiderad high quality and tiorthy of protaetlon (Mnk* 1990). 1 Only ona laraa rivar (graatar than «00 ailaa long), ttia yaUatMtana, haa nat baan aavaraly alterad. 1 Of MdiiM aitad rivars (batiiaan 120 and 600 ailaa long), only «2 atudiad in tha Hatienai «. J. Aquatic and Fiahariac tcianea Colburn, T. I., A. Davidaon, ». U. Braan, ». A Nedpa, C. I. JaekaoB. and B. A. lirof*. 1990. Braat Lakas, Oraat Lagacyf Trw Conaarvation ^ecndatien, Uachington, DC. Coatanza, R. («!.) 1991. Ecelaoia livar: touard a holiatic undaretanding. Pp. 205 • in 0. P. OodBa (ad.). Proeaadir^ o* the Iktamatienal Larja Piwari Sya^soaiu*. Can. J. flah. and Aquatic Sctaocaa Naakall B. D. B. C. Morton, and R. Coatania. Uhat It ecoaystaa haalth and «hy ahould ue worry about It? 'pae«*3-20 InR. Coatania, B. C. Morton, and B. 0. Haakall (ada.). 1992. IcoeymtaB Haalthi Maw Goal a for Enviromantal Mtnaeamant. Itland Praas, Waahingten, DC. Haaaa L U at al. 1989. Niaaouri Rivar fiahary Raaoureai in Relation to Paat, Praaant, and Future Statue. Paaee 352- '" 6. P. Hodpe (ed.). Proeaedinflt of the Intarnetional Lerfle River* SyapMlue. Can. J. Fithertea and Aquatic Science*. Mwit, C. E. 1992. boun b/ the River: The Inpaet of fadaral Water Pr«jaeta and Pollciaa on Biological Diversity. Itland Praat, UaehingTan, DC. Jacobeon, J. L., S. U. Jacobaon, arvl M. E. B. Mimphray. 1990. Effeete of In utero axpoaura to polychlorlnated biphenylt ani related contasiinantt on cognitive fmetioning in young ehlldran. J. Padlatrica. 116: 38- 45. Janklna, R. E. ani k. M. Burkheed. 1993. The freshwater fithet of Virginia. Aiaarican Fiaharlaa Society, Betheada, MO. Jenkinaon 1981 Karr, J. R. 1991. Biological Integrity: a lorw-negl acted atpaet of water raaourea ManagaeMnt. Ecological Applications 1: 66-84. Karr. J. R. 1993. Protectirc eeologlcel integrity: en urgent eoeietal goal. Yale Journal of International Law. 18(1): in praat. Karr, J. R. wid I. J. Schloaaer. 197B. Water rctourcet and the land water Interfeee. Science 201: 229-234. Karr, J. R., L. A. Toth, end D. R. Dudley. 1985. Meh comiunities of nidueatem riverai A hiatory of degradation. BioSeience 35:90-95. Kerr. j. R.. t. 0. feuach, P. L. Anaermeicr, P. R. Yent, and 1. J. Schloaaer, 1986. AaaetaMent of biological integrity in rur«iif« weter: A aethod and It* retlonele. Illlnoia Natural Miatery Survey Speclel Publication No. 5, Cheapeign, 1L. 28 Pp. Kerara, B. L. and J. R. Karr. aa. bevelopaent end testlrv of e benthic Index of bletie Integrity (B-IBI) for rivara of the Terrweeee Volley. Ecologicel Applieattont. In review. 70 Lyons. J. 1992. U* 27S-2K. Nehlaan, U., J. E. UllllaM, and J. A. Liehatouieh. 1991. Pacific aalaon at th* croaaroadai atoeka at riak fron California, Oraoen, Idaho, and Waablngton. riaharia* i2-20. Woodw*tl, C. N. (ad.). 1990. Tha aarth In tranaltlon: pattama and proeaaa of blotle lapovarlahaiant. eaitorldga Unlvaralty Praaa, CaadBrtdoa. 71 A I / (American Fisheries 0( s F OCIETY HUMBOLDT CHAPTER P.O. Box 210. Areata, CA 95S21 March 1, 1993 Honorable Gerry E. Studds Chairman, Merchant Marine and Fisheries Committee U.S. House of Representatives Room 1334, Loncfworth House Office Building Washington D.C. 20515-6230 Dear Mr. Studds, It is an honor and a privilege to address your committee on the status of Pacific salmon stocks in northwestern California and how taking an ecosystem approach to river management might help to restore them. My comments are offered as those of the Humboldt Chapter of the American Fisheries Society for which I served as principal author of Factors Threatening Northern California Stocks With Extinction (Higgins et al. 1992). This work characterized the risk of stock extinctions of Chinook salmon, coho salmon, steelhead and coastal cutthroat trout in rivers from the Russian River north to the Oregon border, including the Klamath and Trinity Rivers and their tributaries. I also rely on my experience as a consulting fisheries biologist in helping to write the Long Range Plan for the Klamath River Basin Fisheries Conservation Area (USFWS 1991) . This plan takes a watershed approach to preserving biodiversity and guides your $40 million, twenty year effort to restore anadromous fisheries to that river (Higgins and Kier 1992) . I will offer comments only on river systems for which I have direct knowledge. The text will be in response questions that I received in preparation for my testimony on March 9, 1993 before your committee. 1) What is your assessment of the condition of the river systems in the Pacific Northwest under the present management regime? In my work for the U.S. Fish and Wildlife Service (1991) on the Klamath River, I characterized it as "severely ecologically stressed." The lower river has been filled in by 20-30 feet of sediment, flows have been reduced by dams which decreases the river's ability to flush itself, and river temperatures in late summer exceed 75 degree F. The source of the river in southern Oregon is Upper Klamath Lake which has deteriorated to the point that it has experienced massive fish kills and some of its endemic fish fauna are going extinct. The South Fork of the Trinity River is the largest Wild and Scenic River basin in California without a dam, yet it is in a similar condition to the Klamath. Chronic problems with high sediment delivery keep riparian zones from recovering, inhibit production of invertebrates which reduces available food for juvenile salmonids, and result in unstable spawning gravels. Maximum summer water temperatures in the lower South Fork Trinity in 1991 reached 81 degrees F, which is lethal for salmonids. 72 All other major river systems in our area, with the exception of the Smith River, have similar problems to those described above. The Eel River is the fourth largest salmon and steelhead producer in California, but there is some prospect that these species may be lost from the river. Erosion problems in the Eel watershed are immense, with an estimated 60 feet of material deposited over the old river bed from past flood events. According to U.S. Fish and Wildlife Service reports, the main stem of the Eel River as recently as 1959 could support 140,000 pairs of spawning salmon but today the main stem of the river is no longer suitable for spawning. The river relied primarily on its healthy tributaries to support anadromous fish after past floods, but those have recently been severely damaged by logging. All smaller coastal river basins in the region have had similar problems with sedimentation due to extremely unstable geologic conditions in our region coupled with disturbances related to industrial timber practices. The high sediment load of almost all northwestern California Rivers has caused estuaries to fill. The estuary of the Eel River for example has shrunk by over 50 percent since 1950 (Higgins 1991) . These important habitats serve as nursery areas for salmonid juveniles, such as Chinook salmon, and marine species such as Dungeness crab. The ecological changes in the rivers of our region result in conditions under which introduced exotic, warm water fish species may thrive. Green sunfish were found to be successfully reproducing in the South Fork of the Trinity River during the recent, prolonged drought. There is some evidence that these fish are predating upon juvenile steelhead. Sacramento squawfish were introduced to the Eel River a decade ago and have since spread throughout the entire river basin. These fish are predacious and have experienced almost an exponential cycle of growth. Plunging salmon and steelhead populations in areas of the basin first colonized by squawfish suggest that they have had a devastating impact. In areas further south or in interior river basins, impacts may come largely from agricultural activities. The Shasta River, which has always been a substantial contributor to Klamath Chinook salmon production, is now almost unsuitable for these fish. Lack of riparian cover and depletion of flows for irrigation have caused the river to rise to 90 degrees F in summer. Lack of riparian fencing also allows livestock direct access to the river resulting in excessive nutrient loading. Dissolved oxygen in summer has been measured at 2.4 ppm, which is lethal to salmonids. The Russian River to the south has a complex set of problems related to flow depletion for farming and vineyards, sub-urban development, and excessive gravel extraction. 2) What are the essential attributes of healthy watersheds and fish habitat? What is role that riparian areas play in promoting "ecosystem health" as well as providing high quality fish habitat? 78 since I will be addressing your committee with such scholars as Dr. James Sedell, I will only offer my assessment of what healthy watersheds remain in my region. Those rivers that flow from Wilderness or Roadless Areas on U.S. Forest Service lands such as Smith River, Wooley Creek, Dillon Creek, Clear Creek, upper Blue Creek, lower Hayfork Creek, New River, and the North Fork of the Trinity River are the only systems that possess high quality fish habitat at this time. The attributes that all these watersheds share are: no or few roads or if they are roaded then roads are well designed, diverse vegetative cover including lots of older age conifers, sufficient large woody debris adjacent to streams to provide for natural recruitment, and the absence of large numbers of livestock or heavy mining activity. I am sure that the role of healthy riparian zones in forested lands will also be covered by the testimony of Dr. Sedell, but I would like to make sure that such attributes are not overlooked on streams through alluvial valleys, such as the Shasta River. Undercut banks beneath root masses of riparian trees provide the best fish habitat in these valley streams which were once the most productive of fish habitats. Stream side trees provide shade to these rivers, moderating stream temperatures, and prevent bank erosion which preserves valuable agricultural land. Open access for cattle to stream side areas for over 100 years has destroyed riparian vegetation. This often leads to down-cutting of streams which can result in a drop in the local water table and a reduction in the productivity of the land. 3) Are existing management regimes on state, federal, and private land adequate to prevent further degradation of watersheds and fish habitat? If not, sure there statutory or administrative barriers that would hinder changes in management regimes for rivers? Are there other barriers (economic, social, or political) that might also create problems? Current management regimes have almost completely failed to prevent watershed and stream degradation and further damage is likely without fundamental change. Some barriers to sound management require administrative changes while others necessitate legislative action. Public Forest Lands: While the U.S. Forest Service has shown increasing recognition of the problems leading to decline of fisheries resources, implementation of meaningful change to prevent future damage varies from one forest to another. Six Rivers National Forest has been under scrutiny by an active environmental community and has therefore implemented some very progressive policies with regard to timber harvest on erodible terrain. Adjacent forests, where local communities were primarily interested in timber extraction, have shown less sensitivity in the past to fisheries and wildlife issues. All National Forests have been caught in the conflict of "getting the cut out" to generate revenue, knowing that the last 74 patches of merchantable timber are on Increasingly steep and unstable ground. Past practices have lead to over-cutting which means that a period of light timber extraction and re-investment in the productivity of the land must begin. The USPS must move away from token fisheries projects such as channel manipulations and move toward a more sound ecological approach. The primary barrier to better management on USPS lands seem to be administrative but the fundamental changes needed may be difficult without major changes in staff. Specific legislative protection of the best Pacific salmon refugia is necessary at this time, however. Private Forest Lands: Current logging practices on private land in California completely ignore concerns for cumulative effects. Recent disturbances on private timber lands have set the stage for substantial degradation to stream habitats which will be triggered by the next major storm event. While Six Rivers National Forest has withdrawn all its lands from timber harvest in Grouse Creek (South Fork of the Trinity) , all timber harvest plans on private land continue to be approved. Some watersheds with unstable geologic conditions have experienced disturbance levels from 60-80 percent in a decade despite warnings from scientists of extreme risk of soil loss associated with such practices. The California Department of Forestry has allowed clear cut timber harvesting in steep, inner gorge areas that pose greatest risk of sedimentation to stream channels. Large coniferous trees are often removed from riparian zones when steep slopes or deciduous trees provide shade to streams; only stream temperature was considered when current rules were formulated. Humboldt AFS has appraised the California Board of Forestry, both at hearings and in writing, about the potential loss of stocks of salmon in streams effected by industrial timber practices. Our requests that watersheds harboring stocks at risk be designated as Sensitive Watersheds under Forest Practices Rules have received no response. Other aquatic species in our region, such as tailed frogs (Asclepjus truei) and Olympic salamanders (Rhyacotriton olympicus) are also at risk of extinction but CDF has no plan to protect them. California Forest Practices Rules have failed several times over the course of a decade to be approved as Best Management Practices under the Clean Water Act. Currently, the EPA delegates authority over control of non-point source pollution to the California State Water Resources Control Board. Humboldt AFS additions of streams impacted by non-point source pollution to the list of impaired water bodies in 1988 showed that the system of delegation is not working. The SWRCB failed to include many of these water bodies in their data base without justification but the EPA then forced them to reconsider. Most of the streams were ultimately included. It seems that a stronger, direct enforcement role for the U.S. Environmental Protection Agency in oversight of timber harvest should be considered during the re-authorization of the Clean Water Act. 75 Private Agricultural Lands: Stream degradation due to agricultural practices and flow depletion have both administrative and statutory barriers. The California State Water Resources Control Board has the authority to prevent water users from wasting water but actions are only initiated when a complaint is filed. Any riparian land owner in California may begin to extract water without any permit from the SWRCB at any time. This antiquated water law needs revision if we are to maintain fisheries resources in the face of increasing development in the state. Ground water extraction is almost completely unregulated in the state, yet if aquifers are drawn down, streams may dry up and riparian zones may die. I am unaware of any statutes that prevent over-grazing that leads to stream degradation due to loss of riparian vegetation. Non-point source pollution from stock may be a violation of the Clean Water Act but no enforcement action has been initiated in our area. There is a misperception at present in rural communities that private property rights reign supreme over public trust resources. These local interests groups see only short term economic gains or losses and are reluctant to entertain more sustainable land use practices. Thinking people, however, are recognizing that we must change. A major economic engine for over-cutting of our forests is an almost unlimited international market for wood products. In the past, when markets were primarily domestic, recessions led to decreased demand for wood products and a slow down in the rate of logging on public and private land. Free market economics can no longer be relied upon as a moderating influence on forest harvest. 4) What management techniques are avaiiaJbie to maintain and restore high cfuality watersheds that will sustain hairvestable , naturally spawning fish populations? I support the watershed approach to fisheries and river restoration currently being advanced by Mr. Robert Doppelt of Pacific Rivers Council, who joins me on this panel. A similar approach is endorsed in the Klamath Plan (USFWS 1991) . The most cost effective method of restoring streams impacted by sedimentation is to stabilize upland areas and allow streams to flush during subsequent high flows. While implementation of such a strategy should move forward on public lands immediately, there is a great need for similar activities on private lands as well. No public money should be spent on private lands, however, until there is fundamental reform of timber harvest practices. Because the landscape is so fragmented at this point and rivers in such bad ecological health, I believe it is prudent to place the watersheds which serve as refugia for the last viable Pacific salmon populations in permanent reserves. No restoration will be possible in the future if the last gene resources that exist in lightly impacted or undisturbed watersheds are lost. We must also develop long term strategies based on desired future conditions of riparian areas so that stream health can be restored. 76 widespread implementation of water conservation measures is needed throughout California. Leaky irrigation ditches, often in use since before the turn of the century, lead to a tremendous waste of water. If efficiency of water use were increased by implementation of water conservation measures, we could maintain agricultural productivity and regain public trust resources such as fish and water equality. Riparian restoration in agricultural lands is essential if we are to restore salmon and steelhead. Although many times fish are spawned and rear in steep areas above alluvial valleys, they must successfully migrate through these valley reaches if they are to complete their life cycle. Restoring riparian zones only reguires cattle exclosures and tree planting. Federal programs should be made available to farmers and ranchers who willingly participate in such programs. The marshes surrounding Upper Klamath Lake must be restored if we are to reverse the condition of the lake and prevent the extinction of its fishes. If water quality problems in the lake are not reversed, the entire Klamath River restoration program is jeopardized. Water conservation measures and riparian restoration on tributaries feeding the lake also must be implemented. I am currently helping to put together a model program for the Klamath River basin, using the EPA Reach File, to make information on fisheries and water quality readily available to professionals as well as the interested public. When the Klamath EPA Reach file is complete, fisheries biologists from any agency will be able to access information in minutes before consultations on a land use project that now takes several hours or several days of research. Agencies or individuals will be able to access information on the history and problems in a watershed to better understand potential impacts of a project they are proposing. To succeed in restoring the ecological health of all our water bodies, we must begin to take a more systematic approach to managing and sharing information. 5) Are there economic benefits to managing rivers on atn ecosystem basis, compared to our current piecemeal approach? It is difficult to gauge the worth of preserving self- perpetuating salmon, steelhead and trout stocks. When these fish return to healthy watersheds, they reproduce at no cost to the public. Estimates by the Pacific Fisheries Management Council in 1983 showed that 1,225,000 Chinook salmon alone should be produced by natural spawning in the Pacific Northwest. If properly managed, this should lead to a harvestable surplus of twice that number of Chinook salmon annually in perpetuity. Because this economic pulse is sustainable, the value of all Pacific salmon species when one considers direct value of fisheries and tourism related to fishing is immense. Our large river systems suffered tremendous impacts in the past from hydraulic mining yet they were producing tremendous bounties of fish after recovery was allowed. 77 There is also economic benefits to making a transition to sustainable land and water management. Soil resources are the basis of all silvicultural productivity. By acting to prevent tremendous soil losses, we will maintain the future productivity of our forests. If we move to help farmers and ranchers invest in increased efficiency of water use, they can meet their water needs while allowing more water for fish and other public benefits. With the specter of continuing drought cycles, it is prudent that we make this investment regardless. Healthy riparian zones can reduce the risk loss of valuable agricultural land during future floods as well as playing an integral part in fisheries restoration. We are now faced with the very real prospect of widespread extinction of Pacific salmon stocks. As a nation, we are all concerned about our current budget deficit and what portion of that debt we will leave to our children. If we fail to act decisively to save Pacific salmon, what will be the economic and cultural deficit that we leave to future generations? Continuing our haphazard approach will most certainly lead to the demise of these fish. The public recognizes the value of Pacific salmon and healthy river systems and will support sound solutions. The time for leadership has arrived. Higqi^s, Chairman Environment^ Concerns Committee References Higgins, P.T. 1991. The Habitat Types of the Eel River Estuary and Their Associated Fishes and Invertebrates. Performed under contract for Oscar Larson and Assoc. Eureka, Calif. Higgins, P.T. and W.M. Kier. 1992. Using the Long Range Plan for the Klamath River Basin Fisheries Conservation Area as a tool for preserving biodiversity. In R. Harris (ed.): Proceedings of Conference on Preserving Biodiversity in the Klamath Bioregion. Univ. of Calif. Press. Berkeley, Calif. Higgins, P.T., D. Fuller and S. Dobush. 1992. Factors Threatening Stocks With Extinction in Northwestern California. Humboldt Chapter of the Amer. Fisheries Soc. Areata, Calif. U.S. Fish and Wildlife Service. 1991. Long Range Plan for the Klamath River Basin Fisheries Conservation Area. USFWS Klamath Field Office, Yreka, Calif. 78 Testimony of Bob E)oppelt Executive Director, Pacific Rivers Council before the House Merchant Marine Committee March 9, 1993 The degradation of The Pacific Northwest's riverine ecosystems and the extinction of safanon and odier forms of riverine-riparian biodiversity have reached alarming levels. Not one river system in the region has been spared. Fisheries, healthy water quaUty and quantity produced by watershed ecosystems, and entire aquatic food chains are at risk. For tbe past two years the Pacific Rivers Council has been involved widi a major project to assess Ae capabiUty of die region's (and nation's) riverine system and biodiversity conservation strategies and policies to address this crisis. The project has involved over 3S top scimtists, economists and community development specialists nationwide. We conclude that the region's eusting pohcies have failed. Entirely new strategies and poUcies must be established quickly to stave off the impoiding collapse of many riverine systems and to prevent wholesale biological extinctions. THE EXTENT OF THE CRISIS: To reahze the breadth of the problems one must first have a template of healthy ecosystems and biodiversity. Healthy river ecosystems in tiie Northwest are characterized by a number of factors including: 1) Water quality: All safanonids require high water quahty for spawning, rearing and migration. Cool, well oxygenated water (generally < 68 degrees F) free of excessive amounts of sedimentation and other pollutants is required year round, 2) Water quantity: adequate flows are critical at specific times in bfe cycles for q»wning, rearing and migration. A natural flow regime that includes high flows is necessary to maintain channel complexity and to tranqwrt sediments, 3) Channel Characteristics: The most productive stream systems for most sahnonids have gradients of < S percent These are lowland habitats composed of constramed canyons and gorges and unconstrained broad valleys which are generally sites of high fish densities. Good habitats maintain a balance between high quahty pools, riffles, gUdes and side channels. Cover features such as large woody debris, boulders, undercut banks, overhanging vegetation, deep water and surface turtnilence are abundant in good habitats. Substrates consist of a varied of particle sizes ranging from silts to boulders with low percentages of fine sediments to accommodate the spawning and rearing needs of all species. Channels are free of obstructions that interfere with migration of adult or juvenile fish; 4) Riparian Vegetation: Riparian areas regulate the exchanges of nutrients and materials from upland forests to ttie stream and maintain favorable microclmiates. Large conifers or a mixture of old growth and hardwoods are found in riparian areas along all streams in the watershed, including non-fish bearing streams. Root systems in stream banks stabilize banks and p>rotect them during high flows, S) The condition of the stream is a function of the characteristics of the entire watershed. Healthy watersheds have upland portions that are well-vegetated and free of chronic and catastrophic sedimentation and other forms of disturbances Aat affect flow regimes, water quahty and the deUvery of large wood to the stream. By the same token, healthy biodiversi^ requires a wide diversity and abundance of species and organisms, not just the presence of few key qxcies. However, whether measured by the health of riverine species, or by physical parameters, the current status of the Paciflc Northwest's riverine ecosystems and fisheries is one of widespread degradation. Loss of Fish Species: At least 106 populations of West Coast salmonids (sahnon, trout, steelhead and char) have been driven to extinction and over 210 salmon populations are currently at ri^ of extinction according to the American Fisheries Society. The Sacramento River winter chinook sahncn, and the sockeye and fall, qning, and summer chinook safanon of the Snake River basin are among the Pacific Northwest fishes listed as protected species under the Endangered Species Act Petitioas have been filed for sturgeon, bull trout Columbia River coho sahncn, Illinois River winter steelhead, and other fishes, whose listing could have widespread consequoices for the region. Himdreds of other freshwater and anadrcmous fishes probably qualify for, and could receive, federal protection in the near fiiture. However, more than just salmon are at risk. The endangered salmon are just symbolic of a range of riverine and rq>arian biodiversity losses occurring across the Pacific Nordiwest. For example, at least 132 species of riparian associated animals, including 3 birds, 4 mammals, 12 amphibians, 4S moUusks, 34 anthropods and over 700 out of 1 100 lutive fishes (estnarine, resident etc) on 348 streams were found to be at risk of extinction within the range of the Northern 79 Spotted Owl from the Cascade Mts. to the ocean (Northein Spotted Owl recovery Plan. Appendix D). Similar patterns and levels of depletion can be found m arid and semi-arid biomes throughout the region. The economic and social impacts of degraded riverine systems and lost fisheries and biodiversity are severe. Just a few examples are necessary to depict the impacts. Since 1910. annual salmon and steelhead runs of the Columbia nver system have decUned from approxmiately 10-16 million to 2-2. S million. Yet. die fishery still produces over $1 billion a year m income and supports 60,000 jobs regionwide (using 1988 figures). How many jobs and economic benefits could a healthy fisber>' produce? Further, diminished and polluted water suppbes produced by die regions watersheds are affecting irrigatioa and mumcipal water supplies and threaten public health. In short, almost every segment of society has been affected by and pays heavy direct and indirect ecological, fmancial. and job-related costs for the degradation of the regions riverine systems, fisheries and riverine biodiversity, whether they are aware of it or not. THE CAUSES OF THE PROBLEMS: Aldiough the media has generally focused the problems on mainstem Cohmibia dams, these types of broad ranging problems cannot be blamed exclusively on dams, nor on excessive fishing, or on predators such as sea Uons. Over 175 of the 214 at risk satanonids spawn outside of the Cohimbia basin, most in coastal rivers unaffected by dams. Most of these species are not subject to commercial harvest. Poor ocean conditions, dams and overharvest would not explain the vast number of r^Mrian species or resident fish such as Bull Trout ttiat are at risk. The cumulative degradation of watershed ecosystems and the loss of riverine habitat is the single most consistent contributor to the decline of the region's fisheries and riverine biodivetsity. The cumulative result of the many human impacts on riverine systems has been called "ecosystem simplification': huge reductioDs in the life-supporting complexity and diversity of watershed and riverine ecosystems and habitats. In brief, riverine ecosystem and habitat simplification relates to: 1) changes in water quantity or flow due to irrigatioa and odier withdrawals, 2) the modification of channel and rq>arian ecosystem morphology caused by damming, reservoirs, channelization, drainage and filling of wetlands, and dredging for navigation, 3) excessive nonpoint-source poDutioa, inchiding erosion and sedimentation caused by damaging land-use practices, including agriculture, forestry, and urbanizatioa. 4) flie deterioration of substrate quality or stability, S) the degradation of chemical water quality through die addition of point-source contaminants, 6) the decline of native fish and other species from overharvest and intentional or accidental poisoning, and, 7) the introductioD of exotic species. Loss of Physical habitat: Many scientists have linked the fiitiire of die region's native fishes directly to the changes in the managemoit of federal forests and other lands across the region. Loss of physical complexity in lowland rivers which primarily flow through private lands is extensive. Virtually all lowland rivers throughout the region have been umversally degraded dirough channdizatioa, diking, leveeing, revetting and riprapping and excessive water wididrawals, thereby disconnecting the rivers from their floodplains and groundwater systons. An estimated 70-90% of natural riparian (streamside) vegetatioa, vital to maintaining the integrity of riverine ecosystems and biodiversity, has already been lost due to human activities. Seventy perceot of the region's rivers have been impaired by flow alteration. Loss of private land lowland habitats has placed much of the burden of maintaining the healtti of both riverine ecosystems and biodiversity oo the federal forest lands in the region. While federal forest habitats have also been degraded, the best remaining habitats are found in the federal forests primarily in unloaded, steep watersheds dominated by old growth forests. Even on the federal forests river reaches are degraded. Recent research has documented that fish habitat on National Forests and other lands currently has fewer pools, higher fine sediments in spawning gravels and fragmented riparian vegetatioa than is heahhy. For example, die mimber of large deep pools in many tributaries of the Columbia river have decreased in the past SO years in resurveys completed between 1989 and 1992 by Forest Service researchers. Overall there has beeo a 30 to 70 percent reductioa in the number of large, deep pools ( > 6fi. deep and > SO yd sur^ce ai«a) on Natioaal Forests within anadromous fish in the past 50 years. A similar trend has been found in streams on private lands in coastal and eastern Oregon, Wasfamgtoa, and Idaho where large deep pools have decreased by 60-80 perceot Large pools are important for anadromous fish as holding areas for adults for spawning, refuge from drought and winter icing, maintenance of fish communtfy biodiveraity and jovenik fiafa rearing areas. 80 The primaiy reasons for lliese losses are increased sedimoits, loss of stream sinuosity by channelization and loss of woody d^nis and other pool forming structures. Only in a few watersheds are exceptions to diis trend: the Metfaow and Wenatchee rivers in Washington boA of which contain large roadless areas. THE NEEDS THAT MUSTT BE ADDRESSED THE ECOLOGICAL NEEDS: Numerous scientific panels have ctxifirmed that only a few pockets of healthy habitats and ecosystems remain regionwide (Scientific Panel on late Successional Forests, 1992 and American Fisheries Society, 1993 in press). These 'key waterdieds' act as physical refuges for fisheries and biodiversity and as a source of q>ecies to recolonize degraded areas once restored. These areas also are the key to maintaining die existing levels of healdi for the systons, and hoice are the 'anchors' for water^ed restoration programs. It is imperative that ttiese best remaining key watersheds be quickly idoitified and protected at (he watershed level to provide a basis to maintain and restore the region's riverine systrans and biodiversity. In additioi, ecologically based riparian and floodphun protections must be immediately implemented across the landscape on federal lands. Once protected, the key watersheds must be 'secured" which means threats to the remaining healdiy areas must be defused or eliminated. Watershed level restoraiioa plans should ttien be crafted and implemented. Each plan should be based on a watershed level analysis of die specific needs and varying conditions of the watershed. Long term monitoring is vital to msure that die restoration treatments are successful and to provide feedback for strategic changes in restoraiioa goals and strategies over time. It is important to note that there are no quick fixes available. Restoration is a long term process. What needs doing immediately is to stop the hemorrhaging of die systems by identifying, protecting and securing the remaining healthy watersheds and riparian areas. Restoration efforts will provide more effective if built around the healdiier areas. THE POLICY NEEDS: The National ProMem: In part, the problem is symbolic of problems nationwide. For example, die United Stales has no national goal to protect or restore riverine ecosystems or riverine-riparian biodiver8ity and no national policies dial 'fiK*'*'^ coordinated federal, state, and private management and conservadon of whole riverine systems. Traditioaal river assessments have been biologically ineffective. No policies require the identificalion and protectioa of the remaining healdiy riverine habitats. No effective riverine restoraiioa policies exist at any level of government. Finally, no poUcies effectively integrate riverine protection and restoration with local job creation and community revitahzation. Internal reviews by the Forest Service concede ttiat maintenance of physical riverine habitat on natioaal forest lands cannot be assured under current managemmt direction. Federal Land Management IHrtkics and Gmdelines are Inadequate: Decile die need to quickly identify, protect and secure die best remaining habitats, and to implement watershed level restoration strategies, current federal hmd managemeat policies, standards and guidelines fail to address these needs. A conqilete exposilioa on the faihues of federal land management bnvs to protect riverine ecosystems and fish habitat at the watershed level is beyond die scope of this testimony. Suffice it to say that die problem is not that federal land managers lack some of the authority to protect these resources. The majority of the problem is that existing audiority leaves too much to agency discretion. Some poUcy gaps do exist however, including legislative mandates to align agency missions, goals and management policies within watersheds. We know ttiat the agencies have not used the power diey clearly have to provide an adequate level of protection and to compel restoration. We conclude that they will not take decisive action wifliout stronger, clearer statutory guidance requiring specific actioDS to address die current crisis facing river ecosystems and fish habitat c« federal lands. A few examples of existing authority vtliich has not been fiiUy exercised follow: (1) The National Forest Managonent Act (NFMA) pn^bits timber harvest where 'watershed conditions' wiB be 'irreversibly damaged' or where 'water conditions or fish habitat' will be 'seriously' or 'adversely affected.' The Act also requires die idenlificalioa of marginal lands deemed 'unsuitable for timber prodiKtion,' such as where 'resource protectioa or reforestatioa cannot be msured. ' In practice, neidier of these provisions has prevented limber harvests which significanlly degrade water quaUty and fish habitat. 81 (2) NFMA also requires that the agency develop plaimiiig guidelines which 'provide for diversity of plant and mimal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives . . . ' a prx>visioa which has been interpreted in regulations to require: '[f)ish and wildlife habitat shall be managed to iniiinhlin viable populadons of existing native and desired non-native vertebrate species in the plannmg area.' 36 CFR V 219.19. The agency has acknowledged its general duty to maintain a level of biodiversity "at least as great as that which would be expected in a natural forest" where "appropriate" and "practicable", but has not derveloped a policy which requires the use of those indicator species most sensitive to land management activities on a regional basis. 36 CFR V 219.27(g). Nor has die agency failed to adequately distinguish between species and populations (stocks) in determining its viable populadons requirements. Litigahon is currently underway which could result in judicial clarification of the scope of the Forest Service's duties. The agency has also generally utilizes individual habitat criteria such as water tanperatures to evaluate the health of streams. These criteria are woefully inadequate. As previously stated, the health of a stream is determined by the combination of a multitude of factors. (3) The BLM's primary management statute, the Federal Lands PoUcy and Management Act, directs the BLM to "take any action necessary to prevent unnecessary or undue degradation of the [pubUc] lands,' but (here is no statutory definiboa of unnecessary and undue degradation, and it is left entirely up to the agency to determine what actions are 'necessary." Rather, the BLM may, but is not required, to protect biologically significant 'areas of critical environmental concern' in developing and revising land use plans. To date, this mechanism has not been widely used to protect critical rivenne habitat. (4) Both agencies are subject to 'multiple-use, sustained-yield principles,' which require that listed resources, including watershed and fish habitat, to be managed for long-term productivity. These principles give be agencies clear authonly to reject economic optimally as the primarily decision making critericm. These principles do not, however, provide any hard constraints on land managers, and require diat agencies merely give 'due consideration' to the various competing uses. (5) The Clean Water Act requires the maintenance and preservation of the biological integrity of the nation's waters, but, to date, the Act has failed to prevent the massive landslides and stream sedimentation associated widi logging in unstable watersheds — despite the use of 'Best Management Practices.* A Word On Enforceability: We do not overlook die fact that each of the agencies has developed guidance of various kinds which applies to the management of rivers and riparian areas. However, except for those few forests or districts with specific riparian management language in their land management plans, most riparian management guidelines which do exist appear as text m agency manuals and handbooks, provisions or technical guides, none of which is binding on the agency or legally oiforceable by affected parties. For example, the Willamette National Forest has promulgated a technical guide entitled 'Riparian Management Guide." This is generally acknowledged to contain the most contemporary, scientifically defensible riparian protection standards in the Forest Service. However, this document does not itself contain any directives which are binding on the agency. Rather, it is an informally promulgated document, not subject to the notice and comment procedures of the Administrative Procedures Act, and not, therefore, enforceable against the agency in a court of law. See e.g. Lumber Prod. & Indust. Workers Log Scalers Local 2058 v. United States, 580 F. Supp. 279 (1984) (forest service manual provisions not binding because not promulgated by Secretary of Agriculture under a specific statutory provision and APA procedures): United States v. Fifty-three Eclectus Parrots, 685 F. 2d 1131 (1982) (agency pronouncement must be legislative m nature to have the force and effect of law, and be promulgated under a 'specific statutory grant of authonty' m conformance with Congressionally imposed procedural requirements). Consistency: Not only do the BLM and the Forest Service have different riparian poUcies, die agencies are not internally consistent. For example, internal reviews in Forest Service Region 6 reported disparate standards and guidelines among forest plans for fishery resource protection, concluding that none of the plans reviewed ensure the continued viability of sahnonid populations. (Heller et. al., 1991). As one investigator discovered, 'planning criteria, indicators for measuring resource values, modeling assumptions, and analytic procedures varied substantially among forests, such that direct quantitative comparisons between plans are of only limited value.' (Frissell, 1992). Likewise, standards and guidelines for npanan management varied considerably anKmg forests: the Willamette (Oregon) and 82 Shasta-Trinity (Calif oniia) National Forests have adopted a no-cut buffer averaging 100 to 200 feet wide, and ranging up to 400 feet, on aU class I, II and ID streams, while the Mt. Baker-Snoquafanie and Olympic National Forests (Washington) aUow extensive logging in all riparian areas, with a few restrictions to prevent total stand removal. Few plans provide any protection at all for Class IV tributaries and fewer still protect riparian areas along headwater streams, despite dieir important contributicms to the downstream envinmment. An example of new authorities needed: 1) Inter- Agency Pohcy Consistency and Alignment to Manage at the Watershed level. Aldiough a number of federal statues speak to inter-agoicy coordination, agencies are still authorized to act based on Aeir own statutory goals and mandates and internal agency priorities. Legislation which defines common missions and goals, and aligns agency management poUcies of riverine-riparian ecosystems and biodiversity is needed to provide watershed level coordination and consistency. CONCLUSION: PRC beUeves Aat new poUcies is needed to provide tmiform watershed protection and restorati to standards.' Once the desired improvements have beea made, further habitat-disturbing activities in the waterdied can be allowed to proceed. The result of the "band-aid' strategy is predictable: disturbances are maximally dispersed across the landscape, and virtually all sites across the landscape are homogeneously degraded. The worst sites may be partially "fixed, ' but meanwhile disturbance-soisitive species have likely been lost through the eatae stream system. As road networks and logging units are diqjersed across the hatdscape, virtually every tributary and stream reach beccnnes vulnerable to management- accelerated disturbance from sedimenlatirai and other effects when the next large storm strikes. Because no effort is made to identify and protect key watershed refugia, the most productive and diverse habitats are subject to continued disturbance, v^iile the most severely degraded areas (inherently the least amenable to structural improvement, and therefore the most likely sites of project failure) receive all the restoration resources. In other words, this strategy is a recipe for the degradation of the remaining healthier watersheds and other kinds of secure ecological refugia— leading predictably to the cumulative extirpation of formerly abundant, but sensitive species over large areas. Past and present aj^noaches to the management of watersheds and riverine-riparian have not only allowed the present crisis to develop, they have indeed exacerbated it For example, the intense fidieries goierated during periods when hatchery stocks are productive have often driven wild stocks into decline and local extinction. Perhaps worse, reliance on increasingly costly, heavily subsidized artificial productirtiinities of our region's and nation's rivers that uphfi the human ^hriL It is in our self-interest to protect and restore the Northwest's and America's riverine systems and biodiversity. It is also our moral responsibiUQr. It 88 Written testimony for hearings on: "the recovery of watershed ecosystems and Naturally-Spawning Salmon populations in the pacifc northwest." March 9, 1993 convened by THE Subcommittee on environment and natural RESOURCES, U.S. HOUSE OF REPRESENTATIVES Submitted by: William k. Hershberger, Ph.D. School of fisheries, WH-lO University of Washington Seattle, wa 98195 89 Preamble: Before commenting on the role of hatcheries in the restoration of naturally spawning salmon populations, I would like to emphasize that hatcheries can only be a part of the answer to this problem. Since salmon utilize an entire waterway from the origin of a stream to the marine waters, they are impacted by events that occur within these all of environments. Salmon reproduce and grow in the freshwater environment during their early life stages; they travel through this environment to get to and return from the ocean and, consequendy, it must be of high quality and passable. The quality of the marine waters in which they spend the majority of their life growing must also be maintained. Finally, the salmon harvest must be reasonably managed if the naturally-reproducing populations are to survive. Thus, if we are to do an effective job at restoring the populations of this diverse and economically important natural resource, all factors must be considered when actions are taken that may have an adverse impact Question No. 1 Definition of a "best possible role" for hatcheries in the restoration of naturally- reproducing salmon populations is fraught with problems and contains a trap that has been opened and fallen into before. Simply staled, there is no single "best possible role" for hatcheries to accomplish this function. On a historical basis, this type of thinking has been a major factor in getting us into some of the problems we now face with naturally-reproducing salmon populations. To illustrate my viewpoint, I would like to cite two historical views of "the" purpose of the hatchery system with regard to Pacific salmon management and mention the problems they engendered. The original purpose for developing fish hatcheries, in general, was to aid the restoration of naturally reproducing populations in streams and rivers where fish production had decreased or ceased to exist However, during Uie latter part of the 19* century the prevailing view was that hatcheries were best used as a conduit for a stocking program to spread many species of fish across the continent Since the culture of Pacific salmon was getting started about this time, large numbers of eggs from these species (e.g., about 51 million chinook salmon eggs from the McCloud River in northern California) were used for stocking programs across the U.S., including such unlikely places as Kansas and Missouri. It should be pointed out that this opinion was not unanimously held. Spencer Baird, the first head of the U.S. Commission of Fish and Fisheries, felt that fish culture was a tool that should be used to restore viable runs of anadromous fish. In spite of this opinion, a lot of effort was expended by the U.S. Commission introducing Pacific salmon species across the continent While a few of the 1 90 programs led to the development of new and productive fisheries, most were failures. Pertiaps more important than the waste of salmon resources was the ecological and genetic damage caused by introduction of exotic species into native populations of fish. Later in the development of hatchery technology (1930's to the 1950's) intensive research led to the major improvements in fish nutrition and diets, fish disease diagnosis and treatment, and rearing techniques. The result was more effective and efficient hatchery operations that produced, apparently, healthier salmon. At the same time, there were increasing demands for the use of water in the Pacific Northwest for a variety of other purposes, e.g., irrigation and hydroelectric development The prevailing view on the best possible use of hatcheries was as a replacement for populations of Pacific sahnon displaced or destroyed because the water was needed for other purposes. The idea that hatcheries could simply replace the Pacific salmon to make up for production lost through destruction of freshwater habitat may have been in the back of the minds of the people who designed and built Grand Coulee Dam without fish passage. This single structure blocked salmon from more than 1,100 river miles of spawning and rearing habitat and, consequendy, destroyed many naturally-reproducing populations of Pacific salmon. The point of the above is not to place blame for the demise and the alteration of natural populations. In addition to limited views of the function of hatcheries, there was a lack of scientific knowledge about Pacific salmon biology and population structure; for example, it was not until the 1940's that it was accepted that these species "home" to a particular location to spawn. Irrespective of die explanations for past mistakes, single-minded and narrow definitions of the role of hatcheries in die dealing widi Pacific sahnon populations can be counter-productive and damaging. Further, such a view does not allow full use of the capabilities of hatcheries to assist in restoration of naturally-reproducing populations. A more productive approach would be to define individual roles for each hatchery facility based on the needs of specific populations and the capabilities of hatcheries to meet Uiese needs. As examples, I would like to use diree different approaches to restoration. First, and perhaps most serious, are populations diat are judged eidier "threatened or endangered". To attain tiiis "status" a population must be in fairly dire condition and in danger of not bemg able to reproduce itself in the namral environment. Incidentally, a published report indicates tiiere are about 214 populations of Pacific salmon close to diis status in the Pacific Northwest. In tills situation, die use of hatcheries as a temporary repository is die only option open to keep die population viable. Among die functions diat need to be performed are die reproduction of die remnants of die population in a manner to retain remaining genetic variability, expansion of the population to "reasonable" numbers, and die production of aduU fish to ensure die future reproduction of die population. This should be viewed as an emergency step diat would be 91 temporary until the environmental constraints on the population(s) are removed and it can be safely placed back into its natural environment A lot of current hatcheries should be able to meet this role, but special needs of handling and maturing adult fish must be considered. The second situation v^here hatcheries can be particularly effective is where a population exhibits "under-escapement" (less than the optimum number of adults return to freshwater to spawn) due to diminished production of young fish. This is often due to water quality deterioration (e.g., siltation) that negatively impacts the incubation of eggs in the gravel or the viability of young fish after hatching. The population may not be at the level of being threatened or endangered, but should be augmented before that stage is reached. Hatcheries can be most effective and have the greatest variety of approaches that can be employed. The job a hatchery can perform best is to increase the survival of eggs and young fish above that in the natural environment. This can be accomplished by a very high technology hatchery, or by a very simple streamside incubation box. Thus, in this case the needs of the population can be addressed with hatchery technology that best suits the situation until the constraints on natural production are removed. The final scenario is where there is under-escapement due to over-fishing. The most obvious and, perhaps, the best way to address such a problem is to decrease the fishing pressure by limiting catch, season, number of fishermen, or any number of other approaches. However, this can present many economic and sociological problems. An alternative might be to utilize hatcheries to produce salmon that do not interfere/interact with the naturally- reproducing population of interest and will relieve some of the fishing pressure from the population(s) of interest Although notable success has been achieved with this type of "enhancement" of localized salmon fisheries in Alaska and Washington by use of specialized hatchery technology, this approach is the one most fraught with potential problems in regard to interaction with natural populations. Consequendy, very careful control and monitoring are required. All of these situations are commonly encountered problems with naturally-reproducing Pacific salmon populations and each can be addressed by use of hatchery technology. The common denominator among all of these is the need for an understanding of what has led to the problem noted. This makes it possible to identify and formulate a solution that will maximally benefit the population. Hatcheries should work, in many ways, like a research and development enterprise. That is, the problems should be identified, potential solutions formulated and conducted, and the work accomplished in a manner to enable evaluation of the results. The most apparent deficit in current hatchery operations is a lack of follow-up to assess and evaluate the results of the operation. 92 Question No. 2 Currently, the hatcheries have better basic husbandry techniques and rearing technology than have ever been available before. Fish diets yield better growth, more efficient utilization of nutritional components, and less pollution than at any previous point in the history of fish culture. Disease diagnosis and treatment is effective and new developments are accelerating with the incorporation of molecular biological approaches. The major problem in this area is the slow development and approval of disease treatment materials. Finally, although our water resources are being more extensively utilized than ever before, there are a variety of treatment technologies that assure adequate quantities of clean, well-oxygenated water. All of this technological know-how can provide assistance for the restoration of naturaUy- reproducing populations of Pacific salmon. On the other hand, the major reason for its development is the more efficient and effective mass production of salmon. A close analogy can be drawn between these developments and those for the feedlot production of cattle, or for the modem production of poultry. While not inherently negative, some of the motivations behind these procedures are not necessarily compatible with the goals of restoration of naturally-reproducing populations. Emphases in the mass production of any animals include uniformity (both genetically and phenotypically), maximum efficiency, and standardization of the product In comparison, effectiveness in restoration of natural populations should emphasize genetic and phenotypic variability, perhaps some inefficiency, and variety in the end product The conflict between the need to efficiently mass produce large numbers of Pacific salmon and the biological requirements for the fish to be a viable part of the natural environment has been one of the major problems and conflicts in the use of hatcheries. There has been some recent experimentation with alternative approaches to raising fish in a hatchery environment that suggest some of the problems can be alleviated. A major criticism of fish released from the hatchery is that they have developed an array of behavioral traits that do not allow them to survive well in the natural environment Such behaviors as predator avoidance, antagonistic responses to other fish, feeding habits, etc., are lost or altered with standard hatchery practices. Alteration of feed dispersal methods and time of feeding, decreases in fish density, rearing in a more natural surroundings, and "training" in the presence of predators have all demonstrated the potential to yield fish more prepared to cope with the natural environment In addition, the development of techniques to satisfactorily raise adult salmon to maturity in marine net-pens has increased the potential to reproduce populations for restoration purposes. While it will never be possible to raise an exact replica of a natural fish under artificial conditions, initial results from research have revealed that some of the major problems can be altered with relatively minor modifications of husbandry procedures. d3 Raising Pacific salmon in a hatchery environment holds the potential to alter their natural life history traits and to decrease the genetic diversity of the population. This, too, can decrease the chances of "restoration" salmon "fitting" back into the natural environment and producing a viable population. One answer to these concerns is to be able to monitor changes and take corrective action. Life history traits are extremely difficult to monitor because of the nature of their expression. These traits result from a combination of the impacts of the environment which the salmon experience and their genetic composition. We have learned much about the genetic detennination of a number of these traits (e.g., timing of maturation, timing of smoltification, precocious maturation, and spawning and return timing) and can estimate the relative importance of genetic factors and the environment Avoidance of genetic changes can be accomplished by attention to reproductive and rearing practices. However, monitoring can only be achieved by keeping complete records and noting the occurrence of changes in a population. Such information is not routinely kept in most hatcheries. The best approach to eliminating potential problems with life history changes is to reproduce and raise fish without introducing selective changes or diminishing variability. While this easier said than done, it is important to make the attempt The importance of this factor can be illustrated by the fact that historically, there were probably salmon migrating in and out of the Columbia River almost the entire calendar year. Currently, due to changes in the river and to the procedural operations of the hatcheries on the river, most salmon move out of the river during a 6-8 week time frame. This overloads both marine and freshwater systems and causes interactions that previously did not occur. Objective measurement of genetic diversity can be a bit more easily accomplished. Although the tools for analysis of genie variability in salmon were developed relatively recendy, there are now a variety of techniques available and more are being developed. Protein electrophoresis is currently used to genetically identify and characterize populations of Pacific salmon. This technique has provided information to define population structures in Pacific salmon species, to identify problems with hatchery breeding procedures, and to define the population composition of harvested salmon. The Washington Department of Fisheries now operates a laboratory dedicated to the electrophoretic analyses of Pacific salmon populations within the state to assist in the management of these species. Molecular techniques utilizing nuclear and mitochondrial DNA have been very limitedly employed to this point but they promise to yield important additional information. Each of these provides a "snapshot" of the genetic variability within and between populations and each has been utilized to monitor genetic change. However, more consistent long-term and extensive use of available genetic analyses need to be employed to provide a basis for determining the meaning of genetic change in Pacific salmon populations. 94 Question No. 3 The current hatchery system, in my view, is capable of able to meeting the challenge of the restoration of naturally-reproducing populations of Pacific salmon. I am not as certain about other species offish, but my impression is that some extensive "retooling" and development of basic fish biology and culture information will be needed for some of the less extensively cultured species that are threatened or endangered. With regard to the salmon, there are a couple of active programs directed toward restoration of naturally-reproducing salmon populations. The Redfish Lake sockeye program on the Snake River is progressing as well as can be anticipated based on the information base that is available on this population and this species. A program operated by the Washington Department of Fisheries in cooperation with the National Marine Fisheries Service to restore a viable population of chinook salmon on the White River in the State of Washington is progressing rather well and has resulted in the development of captive broodstock procedures for this species. These two programs were, basicaUy, undertaken with current technology supplemented by some experimentation to develop workable procedures. There are, however, some important changes that are needed in the current hatchery system to facilitate restoration and to eliminate negative impacts from normal operations. The most important, in my mind, is to get away from the "narrow" approach to the use of hatchery facilities. A lot could be accomplished by setting individual goals for the hatcheries based on the most "pressing" salmon population problems and utilizing the fiill capabilities of the facility. Not every hatchery needs to be operated with a "feed lot" mentality to produce the maximum number of fish possible. Some "supplementation" hatcheries are needed to reseed streams and augment others with the most "natural" salmon that can be produced. This may, initially, involve using some expensive and inherently inefficient approaches; success in these endeavors will, however, eventually result in no cost Finally, some "conservation" hatcheries are needed that utilize non-traditional faciUties and rearing approaches (e.g., lower density rearing, fewer large containers for rearing fish and more small ones, analytical labs, permanent maricing facilities, etc.). Such facilities will provide the best chance for Pacific salmon hatcheries achieving success in what has been a non-traditional role. 95 TESTIMONY OF JEFFERY P. KOENINGS, Ph.D. DIRECTOR OF THE HSHERIES REHABILITATION, ENHANCEMENT AND DEVELOPMENT (FRED) DIVISION ALASKA DEPARTMENT OF FISH AND GAME BEFORE THE HOUSE SUBCOMMITTEE ON ENVIRONMENT AND NATURAL RESOURCES WASHINGTON, D.C. March 9, 1993 Mr. Chairman and Members of the Subcoramiuec, thank you for this opportunity to come before you today to discuss Alaska's fisheries program; in particular, our experience in culturing salmonids. I am Dr. Jeff Koenings, Director of die Fisheries Rehabilitation, Enhancement and Development (FRED) Division, Alaska Department of Fish and Came. First, before discussing Alaska's successful hatchery program, I would like to place it within the context of Alaska's highly successful fisheries management program. ALASKA'S SALMON MANAGEMENT PROGRAM 1. Earh E^fforu to Rationalize Fisheries Under Srat( Management Alaska was one of the first fishing regions to implement meaningful fishing restraints in the form of limited entry in salmon and herring fleets. We may not understand all of the efficiency consequences of these actions yet, but there is some evidence that these policies have slowed the growth of fishing fleets and allowed the industry to capture some profits. While these restraints were implemented swiftly by the State of Alaska, in contrast, it has been a struggle for the federal management agencies to consider and implement these types of mechanisms, even in the few cases where interest groups were in favor of them". 2. Recent Efforts to Assign Limiied Property Rights in Alaska If the central problem of coastal fisheries is an inability to assign sufficient property rights to promote efficient use of the resources, some decentralization of management may generate improved efficiencies. In Alaska, regional aquaculture associations and " Significant efforts to limit federally managed fisheries and implement measures such as ITQs did not occur until well after the creation of the Magnuson Act. -1- 96 regional planning teams have been formed to harness the collective interests of local fishermen. In these groups, fishermen have been granted some rights to determine (1) how many fish they may produce and of what species, and (2) how much to assess themselves for aquaculture activities. In many cases, regional aquacvilture associations are involved in the management of the stocks and frequently take actions to conserve stocks. It seems unlikely that a highly centralized approach to management would initiate a system like this. It appears to us that decentralization leads to determining production levels and inputs that react to economic conditions more quickly and more efficiently. 3. DcrouDlin^ Biological Management and Resource Allocation The Alaska Department of Fish and Game is the designated management authority for sustained-yield biological management. The Alaska Board of Fisheries has been given the authority and responsibility to allocate the available harvestable surplus between users. This arrangement effectively separates the local management biologist from pressures from different user groups, be they different commercial gear types or sport/commercial/subsistence interests. 4. Using Local Fishing Knowledge to Aid in Management In Alaska, local area fishery managers are given a great deal of management authority. In communities that arc close to the fishing grounds and have large numbers of participants in the fishing fieets, managers frequently find that local knowledge is an important aid in making preseason and inseason decisions. Decentralized management promotes use of this local knowledge. Additionally, laws of Alaska establish a "test fish fund" which allow fish captured during research activities and stock assessment activities to be sold in the name of the state and used to fund these projects, Without local fishermen support, it would not be politically possible for the state to operate in tliis manner since each fish caught comes directly from the potential catch of affected fishermen. 5. Benefits Associated with Public Involvement More centrally controlled fisheries might impose additional legal costs on management if the public is not adequately involved. In Alaska, the Board of Fisheries develops regulations that describe how fisheries will be conducted. The membership consists of a seven-member panel, with representation from interest groups and industry. Members from any and all interest groups may present regulatory proposals and testimony to the board. While the system is occasionally cumbersome, the open system is generally considered as participatory and "fair." and is believed to reduce the probability of litigation from private parties over other centrally controlled management options, 6. Importance of Keeping Management Close to the Fishen Overly centralized management of fisheries might not only lead to all biological but all economic analysis occurring far from the fisheries. Economists frequently must -2- 97 rely on focus sessions with fishermen and olher testimony to build econoinlc models. Resulting computations of the net benefits to society, which are generated far from the fishing grounds, have often been found to be out of touch with reality— excluding benefits derived from experiences of fishermen and processors. THE ROLE OF HATCHERY FACIUTIES IN THE RECOVERY OF NATURAIXY SPAWNING SALMON POPULATIONS As Alaska's fish management and habitat protection programs have proven very successful, the hatchery program, which I will detail below, has concentrated on the enhancement of salmon stocks rather than on wild slock restoration programs. Early on, it was stressed that hatchery production would supplement, not supplant, wild slock production; hence Ihe development of the rigorous genetics and fish health policies to guide the program. We are now applying the hatchery technologies we developed to ihe restoration of salmon populations. Question 1. Givtn the Ussons learned from past hatchery practices, what is the best possible role for hatcheries in the restoration of naturally spawning salmon populations? In my opinion, salmon hatcheries have been misused. The construction of a hatchery has been the common mitigation for fisheries habitat alteration or destruction. These large faculties were monuments to the good intentions of society toward the fish. People who might have otherwise questioned the loss of the salmon were convinced that hatcheries would more than compoisate for the loss of necessary habitat. The success of hatcheries was most often judged simply by how many fish were released, not by the condition of those fish; or, pcrhsq)S most important, not by the survival of hatchery-produced fish to adult. Unfortunately, this practice was often the rule and, perh^s equally unfortimaie, is the common stereotype of salmon hatcheries today that was generated from these activities. Some people now contend that the best possible role for hatcheries in the restoration of naturally spawning salmon would be to close the facilities, All hatcheries do not fit tliis stereotype. Some hatchery programs lived up to the expectations of those who designed the programs. We have also learned from failures in the past. I feel that tl-.e application of modern hatchery practices may be necessary for the timely restoration of naturally spawning salmon populations. Hatchery production can be used in several ways to assist in tlie restoration of naturally spawning salmon stocks: • To supplement the production of naturally spawning stocks of fish; • As a management tool to divert fishing pressure from stocks of naturally spawning fish; • As a subject of research designed to understand both the effects of environmental parameters and the activities of man on the survival of fish; and 98 • In extreme measures to prevent the immediate extinction of unique stocks of fish. Supplementation is the hatchery production of fish from selected stocks which are then placed back with the progeny of naturally spawning fish. Successful supplementation requires the application of fish culture practices to minimize the domestication of fish as they pass through the hatchery and are returned to their natural habitat. The role of supplementation in slock restoration is to add needed numbers to declining stocks of fish. In some instances, this may ensure the existence of that stock until habitat is restored and resource management is adjusted so that the stock becomes self-sustaining. Supplementation is also used to enhance self-sustaining stocks to support increased harvest. There are also situations when hatchery programs can be designed to add fish to traditional common-property fisheries. These programs provide a tool for resource management and divert fishing pressure from selected naturally spawning stocks of concern. In order for this strategy to be successful, the hatchery fish must not alter or significantly compete with the wild stocks. At harvest, the hatchery fish must be separated from the wild fish by either space or time. A secondary benefit of this strategy is maintenance of selected fisheries and associated economics while, at the same time, diminished populations of naturally spawning salmon are protected. We have far greater control of hatchery-produced fish than of naturally spawned fish. Hatchery fish are used in controlled situations to help fisheries scientists understand and identify ^ose things tJtat affect the survival of naturally spawning salmon. Identifying factors detrimental to wild salmon as well as modeling the optimal situation for the survival of members of a given slock of fish is critical to the restoration of naturally spawning salmon stocks. In Alaska, we have determined such things as the specific relationship of yearling sockeye salmon smolt size, or the liming of smolt migration to the sea, with the chance the fish will survive to return as adults. This knowledge is used to evaluate the health of a wild population. It can also be used to predict the impact of habitat alteration, eiUier correction or degradation, associated with the activities of man on wild salmon stocks. Hatcheries can be used to sustain severely threatened salmon stocks until sufficient numbers of fish and appropriate habitat are available. The hatchery may be used to "bridge over" life history voids: too few aduh spawners to sustain a slock in natural conditions, inaccessible or altered spawning ground.s, impassible migration corridors, or inaccessible or altered freshwater rearing habitat. In the summer of 1990, only one female sockeye salmon successfully migrated up the Columbia and Snake Rivers to Redfish Lake in Stanley Basin, Idaho. There was virtually no chance this single female could have naturally spawned and produced a sufficient number of offspring to perpetuate the Redfish Lake sockeye, Extreme fish culture practices, including developing a hatchery-reared, captive brood stock, were used to perpetuate this stock that had been reduced to several thousand eggs in a single female. In summary, it is my opinion that there is no single, best way that hatcheries can assist and speed the restoration of naturally spawning populations of fish. As many of 99 these stocks are unique, so are the habitats that support them. Though many salmon stocks have been diminished due to general common problems, in fact the situation of most of these individual populations today is unique. Specific hatchery practices, similar to those generalized above, can be designed and used to assist in the restoration of most unique stocks of naturally spawning salmon. Question 2 A. What artificial production techniques and systems are available to assist in the restoration of naturally spawning salmon populations? • eyed-egg plants from hatcheries • fry plants from hatcheries • smolt plants from hatcheries • lake enrichment B. What monitoring systems are available to preserve life history and genetic diversity? • Many monitoring systems are available, but their implementation will not preserve life history and genetic diversity. One has to control, through policy development and regulations, the manner in which the business of salmon restoration is conducted if one hopes to maintain genetic diversity. Simply put, the behavior of humans with regard to the fish has to be controlled. In Alaska, we accomplish this with a permit system that controls the movement of fish used for aquacultural purposes and with rigorous policies on fish disease and fish genetics that are backed with modem laboratories and highly skilled scientists. C. Where are such techniques in use and what has been the extent of their success? I have used the term before, but in the Pacific Northwest, I believe the word "supplementation" is used to describe the process of artificially adding to the number of individuals in a naturally spawning salmon population. For clarification, let's make sure what exactly we are talking about. In Alaska, when we conceive of rehabilitating the fish in River X, we are speaking of performing an egg take on River X, talcing the eggs back to a hatchery for incubation, and releasing the resultant juveniles back into River X. The objective is to bypass the heavy mortality that Mother Nature usually inflicts upon eggs laid in the gravel in tlie wild. We use, as a rule of thumb, that only ten percent of the eggs in River X will produce juveniles, but 90 percent of tliose taken to a hatchery will produce juveniles. The ultimate goal is to boost the number of fish in the system to a higher level and that this lugher level will be self-sustaining. Clearly, and this is extremely important, self-sustainment will not be achieved if whatever factor causing the population to decrease in the first place is allowed to remain operative: declining habitat, overharvest, unusual predator concentration, and some shifts in tiie carrying capacity of the environment. Some people in tlie Pacific Northwest have concluded that supplementation docs not work. I would be very careful about concluding that. Certainly, there are cases to 100 point to that have not worked. In most Instances, it Is very popular and therefore easy, to make and release fish, but to correct the mechanism that made the natural populations decline in the first place can be exceedingly difficult. I can give you several examples from Alaska that have fit the definition of supplementation and have worked; • Upper Thumb River (Karluk Lake) sockeye salmon, Kodiak (completed) • Farragut River Chinook salmon, Southeast (ongoing) • Chilkat River Chinook salmon, Southeast (ongoing) To date, we have had no experience at rehabilitating salmon stocks on big rivers analogous to the Columbia. But we are about to get our feet wet on the Yukon River: • Toklat River chum salmon (ongoing) • Chena River Arctic grayling (ongoing) Also important is our successful experience in establisWng self-sustaining runs in previously fishless habitats: • Frazer River sockeye and Chinook salmon (completed) Other examples can be cited, but I must add that, despite our successes, Alaska does not consider hatcheries as a substitute for careful management. In fact, tlie Alaska Legislature mandated that fish stocks shall be managed consistent with sustained yield of wild fish stocks. Question 3. Is [Alaska's] hatchery system presently able to perform the tasks necessary for the survival and restoration of naturally spawning fish populations? If not, what changes are necejssary? Hatcheries have various purposes: one being wild stock supplementation or restoration, the other being enhancement. Hatcheries (or various artificial propagation techniques) arc a functional tool for restoring naturally spawning fish populations, but strict guidelines governing diis use should be established prior to the implementation of any restoration project. Ecosystem recovery must be based on a holistic approach. Overfishing, loss of spawning and rearing habitat, prolonged competition from introduced species or hatchery-produced fish of the same species, and barriers to migration are common problems leading to tlie decline or loss of naturally spawning fish populations. Fortunately, these occurrences are relatively rare in Alaska; unfortunately, they are common in the Pacific Northwest. The first step in the restoration process involves identification and correction of causes leading to the decline or loss of a naturally spawning fish population. As I have stated before, there is no point in initiating a restoration project if these causes persist. 101 If a naturally spawning fl«h population has been lost or cannot be brought back to a viable population strength through stricter management protection or habitat restoration, then supplementation will be required. A sound rule of thumb is to go in, get the job done, and get out. The use of hatcheries or artificial propagation techniques should be limited to one or two life cycles of the affected species. Prolonged supplementation using hatchery-produced fish will only result in the replacement of wild fish with hatchery fish, which really defeats the purpose of restoration. In cases where a naturally spawning fish population has been completely eliminated, a donor stock will have to be used. Local or genetically similar stocks should be used for replacement. The keys to the performance of successful hatchery programs in Alaska include the following: • The design and adherence to extensive fish culture protocols maximize the survival of the fish while at the same time mimicing the natural situation for those fish as much as is reasonable. There has often been extensive, creative interaction between fish culturists, fisheries scientists, and resource managers in the planning of all fisheries restoration and enhancement activities. That planning is brought to fruition through the application of these restoration and enhancement protocols, including the aiq>ropriaie fish culture practices, • The consistent evaluation and reevaluaiion of all critical procedures, coupled with the flexibility that allows rapid revision of those procedures is essential. We make very few assumptions. Everything that is done in the most successful hatcheries is consistently evaluated. The ultimate evaluation of fish culture procedures is the survival of hatchery-produced fish to adults. The evaluation of restoration activities would include accomplishing the intended, overall program goals. • We realized that many restoration projects are unique, and we accepted both the risk and failures associated with the willingness to sometimes design unique, one-of-a-kind protocols for specific situations. The successful culture of sockcye salmon was a result of this willingness. Alaska now has the largest and most diverse sockeye salmon restoration and enhancement program in the world. Finally, Alaska's hatchery program began in 1971 after harvests of wild stocks of salmon fell to around 20 million fish. Presently, the wild stock harvests have reached nearly 150 million salmon, with an additional 20 million catch contribution from the enhancement program. This is consistent with the original goal of the program to supplement wild stock production, not supplant it. Wild stocks remain the backbone of the salmon industry, and it is the intent of the Alaska Department of Fish and Game to keep it that way. Thank you for this opportunity to come before you today to discuss Alaska's salmon fisheries management and development programs. 102 UKUWHE Restoring Board of Directors Chairman Jim Youngren Real Estate Developer S Private Hatchery Owner William R. Allen Chatrman Jamestown Klallam Tritx G. Ross Heath, Ph.D. Dean. College ol Ocean i Fisheries Sciences University at Washington Doug Henderson Executive Director Western States Petroleum Association Jerry Hermanson President The Hermanson Corporation Jack Larsen Vice President Office of the Environment Weyerhaeuser Company William G. Reed Chairman Simpson Investment Company Bugene Schermer Vice President. Instruction Grays Hart>or College Holland Schmitten Northwest Regional Director National Marine Fisheries Service Robert H. Schultz President Schultz Furniture, Inc Executive Director John A. Sayre Testimony of John A. Sayre, Executive Director of Long Live the Kings, given at a hearing in Washington D.C. on March 9, 1993 before the U.S. House of Representative's Subcommittee on Environment and Natural Resources. The subject is the potential role of hatchery facilities in the recovery of naturally spawning salmon populations. The following comments should address most of the specific questions the Subcommittee members asked. RESTORATION PROJECTS FOR NORTHWEST SALMON If the Northwest is to once again have a bounty of salmon, restoration of damaged runs and habitat must be a priority for all salmon advocates. The hard facts are: . most of the rivers are dammed, . most of the watersheds are logged, . most of the water is appropriated While it is essential to continue efforts that protect remaining pristine habitat and save wild salmon stocks that are in danger of disappearing, the future lies in restoration. We need to fix a system that is broken biologically and mismanaged politically. Development of a restoration strategy requires a vision of what we want. Considerable damage has been done to Northwest salmon. But we forget that they are one of the world's greatest renewable resources, one that has displayed remarkable hardiness, survivability, and adaptability over the centuries. Only 15 years ago these fish supported a regional fishery that attracted anglers from around the world. Salmon were the llfeblood of thriving coastal communities. Long Live the once, again be return to a fl annual ly bring the area and r the Northwest and rebuilding hatchery progr commercial , tr hurting wl Id f Kings (LLTK) believes that salmon can restored to such levels. Our goal is a ourlshlng year-round fishery that s hundreds of thousands of visitors to eturns hundreds of millions of dollars to economy. This can be done by protecting wild runs, and by applying Innovative ams that can support viable Ibal, and sports fisheries without ish. 19435 184th Place N.E. • Woodinville, WA 98072 • (206) 788-6023 • FAX (206) 788-3594 103 Page 2 Wild fish don't need human help to spawn. Left alone, they produce the hardiest offspring, and that reproductive process doesn't cost the taxpayers a dime. Ideally, the best ways to restore salmon are: 1) make sure that enough of them escape fishery pressure to fill the available spawning habitat and, 2) increase the amount of that habitat. Unfortunately, we're several million people too late. Too much habitat has been destroyed and too many wild salmon stocks need major help to reach even minimum escapement numbers, let alone to produce enough fish to maintain existing fisheries. This is where LLTK comes in. When LLTK was established in 1986 It was then the only private group in the Northwest given permits to do "hands-on" work with wild salmon runs. As a result, we now have six years' experience in: . wild salmon brood stocking--capturing wild adults to take their eggs, . supplement at ion --rearing wild fish in captivity to increase their survival from egg to smolt and then releasing them back into their native river to increase the numbers of naturally spawning adults, . habitat restoration-- opening up old gravel pits along rivers to provide new spawning areas for wild fish, . techniques to maintain wild characteristics of . fish in capt ivi ty--providing shade and hiding places, letting vegetation grow around ponds to provide natural feed and volitional release of fish so they migrate out on their schedule and not the hatchery manager's schedule. This work has gained LLTK credibility with fishery agencies, tribes, fishermen, and helped lead to the passage of a state law establishing 12 regional groups in Washington state to enhance salmon runs. The program has a dedicated fund from surcharges on sport and commercial fishing licenses that raises $700,00 annually. Many of these groups base their programs on techniques developed by LLTK. While the development of restoration efforts was important six years ago, today they've become critical ly important because of the potential impact of the Endangered species Act. Long Live the Kings operates three problem-specific restoration projects, all in cooperation with Native American tribes, state and federal fish agencies and local community salmon enhancement groups. . At Lilllwaup, on the Hood Canal, we are experimenting with captive broodstocking--rearing depleted wild stocks to sexual maturity in captivity. This technique holds on to 104 Page 3 threatened gene pools until factors limiting their survival are addressed. . Our Wishkah/Wynoochee River project, near Grays Harbor, focuses on how to supplement wild fish populations in logged areas until they can re-establish themselves through natural spawning, and creating new spawning and rearing habitat. . Our project on Orcas Island, in the San Juan Islands, demonstrates how hatchery salmon stocks can be totally separated from wild stocks, thus allowing fisheries that don't conflict with wild fish. Let me elaborate on these projects: 1. HOOD CANAL WILD COHO RESTORATION LLTK's Wild salmon facility at LiUiwaup, Washington, will be completed this month. It is a "state of the art" hatchery and rearing facility built with $600,00 of private funds from foundations, corporations and individuals. The project is a cooperative effort between LLTK, the National Marine Fisheries Service, the Washington Department of Fisheries, the U.S. Fish and Wildlife Service, the Point No Point Treaty Council, the Skokomish Indian Nation and the Hood Canal Regional Salmon Enhancement Group. This facility will be a "captive broodstock" site for Hood Canal's wild Coho salmon. These stocks were so depleted last year they caused an unprecedented two month's fishing closure. A small number of eggs and fry from wild salmon will be captured in Hood Canal Rivers and reared at Lilliwaup. They will be held in captivity in freshwater until sexual maturity. Some fish will also be reared in saltwater net pens for comparison of survival. The eggs and progeny from these fish will then be placed back into their native rivers, thus dramatically increasing the number of juvenile fish going out to the ocean. A series of techniques will be used to learn how best to re- introduce the juvenile fish back into the rivers. This project offers the opportunity of restoring depleted wild fish faster than any other method and will be usable throughout the Northwest. In addition, two spring fed streams that flow through the hatchery have had weirs and spawning gravel added to increase natural spawning areas for wild fish. This fall 105 PAGE 4 some 60 wild salmon spawned in the middle of the hatchery site. A similar program is underway with wild Chinook on the Dungeness River in Washington state. 2. WISHKAH RIVER/WYNOOCHEE RIVER WILD SALMON RESTORATION This project experiments with supplementat ion--capturing wild adult salmon and taking their eggs into a hatchery to increase survival. The Wishkah River water shed is almost all logged off. This summer, the last remaining timber around the LLTK facility will be clear cut. Instead of pulling out, LLTK is working with the company doing the logging to build a new series of ponds for wild-fish restoration. These ponds will be for spawning and over- wintering wild fish. LLTK will make the Wishkah an example of how to bring back wild fish and their habitat in a logged area. The first Chinook that were tagged and released--in June 1988--returned this fall as four-year old fish (weighing in the mid-20-pound range) to spawn naturally in the Wishkah River. We know this because we captured several of the tagged fish in our brood stocking program, and observed many more spawning. This clearly indicates supplementation is working. In addition, we had the highest returns yet of wild Wynoochee River Chinook offspring to our joint program with Washington Department of Wildlife at Lake Aberdeen. The Chehalis Basin Fisheries Task Force has also had great success with it's wild Coho and Chinook supplementation program in the Satsop River. When the minimum escapement goals for naturally spawning fish is these rivers are met three years in a row, LLTK will cease using the hatcheries to supplement wild fish. LLTK is also working with timber company gravel pits on the area rivers to demonstrate they can be restored as valuable natural spawning and rearing habitat for wild fish. We've also dug new ponds in small watersheds that fill up in winter flows and provide over-wintering habitat for thousands of juvenile wild fish. 3. ORCAS ISLAND GLENWOOD SPRINGS SALMON RESTORATION PROJECT LLTK has recently taken over a privately owned hatchery on Orcas Island in Washington state's San Juan county. This facility has operated as one of the most productive, cost- effective fish-rearing facilities in the state. State budget cuts eliminated the funding for this project. LLTK will assure funding through a cooperative effort with the 106 Page 5 commercial, tribal, and recreational interests that benefitted from these fish. It will be an to hatcheries on rivers that harm wild fish. This facility has a spring water source with no wild fish, a direct release site into salt water with no negative impact on wild fish, and a terminal area fishery with no mixed-stock fishing with potential impacts on wild fish. The sale of excess eggs and carcasses could cover the operating costs. If this operation were duplicated in similar sites with adjacent water sources, it would greatly benefit fishermen and relieve pressure on wild fish. In addition, the site will also be used for captive broodstock rearing of North Puget Sound depleted wild stocks. The Glenwood Springs Salmon Enhancement Project began in 1978 as a private non-profit effort to enhance depleted stocks of Coho and Chinook salmon in the northern Puget Sound area. The initial stocks of Coho and Chinook came from the Samish River hatchery near Burlington and were transferred as "eyed" eggs for the initial three years, after which the program became self-sustaining. The original coho rearing and release program resulted in returns of up to 10 percent to Eastsound area and justified the state opening a terminal net fishery. The Chinook program was even more successful. We had excess eggs after three years. In 1988, Glenwood Springs generated a surplus of over three million eggs in addition to filling its own rearing capacity needs of 400,000. This was all in addition to a commercial purse seine and gillnet fishery in Eastsound Bay that allowed a catch of approximately 5000 adult fish averaging 20 pounds. LLTK believes hatcheries can play a major role in recovering wild salmon and in maintaining viable fisheries economies. Without hatcheries, wild fish alone could not maintain existing sport, commercial and tribal harvests. It is desirable to restore wild fish to the maximum extent possible and to maintain hatchery production to serve existing fish constituencies. The challenge is to restructure hatchery operations to minimize conflicts with wild stocks. If we truly start restoring watersheds to wild productivity, then the hatchery role should be diminished. 107 University of Minnesota rvM Cion Caaaus Dtpanmunl ofFishtries and WiUUft 200 Hodson Hall 1980 Folwell Avenue Collfgf of Natural Resources ^, p^^, ^^ i}iOH-6l24 6I2-624-J6O0 Fax: 6I2-625-529V Testimony of ANNE R. KAPUSCINSKI, Ph.D. before the Subcommittee on Environment and Natural Resources Committee on Merchant Marine and Fisheries U.S. House of Representatives on Role of Hatcheries in the Recovery of Naturally-spawning Salmon Populations in the Pacific Northwest March 9, 1993 The Honorable Gerry E. Studds, Chairman Mr. Chairman and members of the Committee, my name is Anne Kapuscinski. I am an Associate Professor of Fisheries and of Conservation Biology in the Department of Fisheries and Wildlife, and an Aquaculture Extension Specialist with Minnesota Sea Grant and the Minnesota Extension Service at the University of Minnesota. In addition to direct experience in operation of salmon hatcheries. I have conducted research for 16 years on fish culture and fish genetics with an emphasis on salmon and trout, and have been involved in several Columbia River Basin efforts to improve genetic conservation in hatchery programs. In 1991. 1 conducted a genetic analysis of hatchery policies and guidelines used by fisheries management agencies in the Columbia River Basin (Kapuscinski 1991 ). Currently. I am on a Yakima/Klickitat Fisheries Project scientific team which is developing genetic hatchery guidelines, genetic risk assessment protocols, and genetic monitoring tools for hatcheries used to rebuild salmon populations. My comments below will apply to salmon and steelhead trout populations; for brevity, the word "salmon" will refer to both groups. Thr Itrpunmenii'l hthrnrMinJMiUhh i. //,< htmir Jrpiinmeni of the L'.S Fish and Wildlife Service. Miniu-\*>ui I i-'i- ftiinr f-i\h anj )iildhlr Research Unit 108 APPROPRIATE ROLE OF HATCHERIES Two guiding principles should be applied to all uses of hatcheries for restoration of naturally-spawning populations. Use hatcheries only as part of a comprehensive restoration strategy. A hatchery program should be only one component of a comprehensiye rebuilding strategy designed to remove or significantly reduce the human-induced causes of the population's decline (Kapuscinski et al. 1991). Different salmon populations in the Pacific Northwest have experienced different causes of decline, with several causes often acting in concert (Nehlsen et al. 1991). A major problem has been habitat deterioration or loss due to barriers to passage (dams), reduced or altered stream flows, poor water quality, water diversions, destruction of spawning or nursery habitat, increased exposure to competition and predation fi-om native species, or effects of introduced species (Li et al. 1987). Some natural populations which produce relatively low amounts of harvestable surplus have been further depleted by overharvest. Sole focus on a hatchery, no matter how well designed and managed, cannot compensate for all root causes of decline and will not result in sustainable restoration of naturally- spawning populations. This principle echoes the approach recently recommended by the Northwest Power Planning Council (1992) in its Strategy for Salmon. A medical analogy illustrates the value of this principle. The patient is a salmon population, the symptom is decline, and lack of treatment could lead to death, or extinction. Before even prescribing a treatment to rebuild the population, a good doctor makes a diagnosis consisting of the best possible assessment of causes of decline. Although the diagnosis may not answer all questions about what went wrong, it guides the doctor in choosing the most effective treatment from available options. Effective treatment might include a hatchery program in some cases and not in other cases. Prescription of a hatchery program as part of a comprehensive restoration effort is reasonable under three scenarios: 1 . a temporary hatchery program to increase a depleted population or reestablish an extinct population to self-sustaining status while root causes are being reversed (e.g.. while habitat is being restored); 2. a long-term hatchery program where habitat is irreversibly damaged or lost, provided that negative impacts of hatchery fish on other natiually-spawning populations are negligible; and 109 3. a long-term hatchery program to augment harvest above levels supported by existing freshwater habitat, provided it is feasible to separate hatchery fish from naturaily-spawning fish in freshwater habitats and in the fishery. The first scenario is the best possible role for hatcheries because: (a) hatchery expenses can be terminated when self-sustainability is achieved; and (b) restoration of a self-sustaining population also is a good indicator of iniproved health of the overall watershed ecosystem. Temporary and less expensive hatchery facilities may woric for this scenario. Conditions required for the third scenario, harvest augmentation, will be hard to meet in many cases and would require changes in harvest methods and management. Section 5 of the Strategy for Salmon proposes testing of alternative harvest methods for selective harvest of hatchery fish (Northwest Power Planning Council 1992). Another potential use of hatcheries for restoration involves release of hatchery fish with the expectation that they will interbreed with the depleted, naturally-spawning population and that the resulting mixed population will be managed as one unit. This scenario is sometimes called "supplementation." The merit of this approach is still an open question because such programs ha.ve not yet been fully implemented and evaluated. This approach, for example, is planned for new hatcheries in the Yakima subbasin of the Columbia River Basin. To maximize learning about risks, benefits, and desirable modifications, a strong commitment to monitoring and evaluation of this program is imperative. My recommendation is to allow learning to proceed in a small number of carefully chosen cases, such as the Yakima, before considering widespread adoption of this approach. All hatchery programs must adopt the poal of maintaining existing generic resources in naturally-spawning and hatchery salmon populations. Genetic diversity exists among and within salmon populations. It is imponant because it allows salmon populations to evolve and thus persist far into the future. Sustainable restoration and maintenance of salmon populations can only be achieved if these generic resources are maintained in perpetuity (Riggs 1990. Kapuscinski 1991). Adherence to this goal vnl\ require revision of many current hatchery policies and practices in addition to proper hatchery monitoring and evaluation. General recommendations for revisions and improved coordination among salmon management programs appear in Kapuscinski (1991) and Kapuscinski et al. (1991). Recently, an "bitegrated Hatchery Operations Team" initiated development of a uniform hatchery policy for all Columbia Basin fisheries programs (Jerry Bauer, Bonneville Power Administration, Portland, OR. personal communication). The final draft policy must undergo rigorous and independent scientific review to ensure that it is genetically sound and practicable. no Then, all fisheries management agencies operating salmon hatcheries in the Pacific Northwest should be encouraged to adopt the final policy. ARTinCIAL PRODUCTION TECHNIQUES AND SYSTEMS, RISK ASSESSMENT, AND MONITORING Traditional methods and physical facilities for sahnon hatchery production need to be revised in order to be compatible with the twin goals of (a) restoring naturally-spawning populations and (b) maintaining existing genetic resources in all affected hatchery and naturally-spawning populations. Hatchery systems should aim to reduce the major limiting factor in freshwater habitats. In many Pacific Northwest cases (outside of Alaska), the major freshwater Umitation appears to be depressed production and downstream survival of smolts due to habitat loss and damage. Therefore, appropriate hatchery systems for most restoration cases should involve artificial propagation from fertilized eggs to the smolt stage. Geneticallv-sound revisions are needed in hatcherv techniques and operations. My current work on the Yakima/Klickitat Fisheries Project is to develop specific and feasible genetic guidelines for all possible phases of hatchery operations, including aduh collection and mating, offspring rearing, fish releases, and related activities (Kapuscinski and Miller in prep., table of contents attached). Scientific peer review and appropriate revision of these draft guidelines must occur before they are implemented and evaluated in new Yakima hatcheries. Some elements of these guidelines, such as how to best mate males and females, are based on well documented biological principles and data. They are immediately and generally appropriate for all hatcheries used in sustainable restoration of namrally-spawning populations. Incenrives for their general and coordinated application in the Pacific Northwest are needed. Captive broodstock programs, where fish are maintained in caprivity for an entire life cycle, are expensive and involve increased biological risks compared to traditional salmon culture programs, where only part of the life cycle is in captivity (usually from fertilized egg to sub-adult smoh). They are appropriate as a last resort when a population is dangerously close to extinction (Hard et al. 1992). For example, a captive broodstock program was recently initiated for the endangered Snake River sockeye salmon. Ill Some revisions of physical hatchery faciliries mav be needed to accommodate restoration and genetic goals. Although I am not directly involved with revision of hatchery facilities, I am aware that some changes are necessary to accommodate the twin goals of restoration and genetic conservation. Designs for the Yakima Basin hatchery program, for instance, include (a) improved separation of genetically distinct populations in incubation, fry and smolt rearing units; and (b) establishment of streamside smoh acclimation ponds. Smolt acclimation ponds are intended to improve survival of released smolts and adult homing to desired natural spawning sites. Application of these and other facility modifications requires careful evaluation before considering them for widespread use. Genetic risk assessment should be conducted on all proposed hatcheries and comprehensive, coordinated monitoring systems implemented for all functioning hatcheries. Risks of damaging (a) existing genetic resources and (b) long-term persistence of naturally-spawning populations should be assessed during early plarming of hatchery programs and before large amounts of money have been spent. Proposed actions with high risk should be identified and altered in order to remove or substantially reduce these risks. The Pacific Northwest currently lacks a uniform protocol for genetic risk assessment of all planned hatcheries. The first review draft of a generic protocol, however, will soon be available from work under the Yakima/Klickitat Fisheries Project. Following revision based on independent scientific review. I recommend creation of incentives for application of the final risk assessment protocol to all plaimed hatcheries in the region. Currently, no comprehensive system is in place to monitor salmon hatchery programs (both individually and collectively) for (a) restoration of natiu-ally- spawnmg populations, and (b) reduction of all genetic risks. To reduce costs and increase learning, a uniform and comprehensive monitoring program should be developed and its implementation coordinated among all Pacific Northwest fisheries agencies with junsdiction over the same or interacting salmon populations. This recommendation echoes the calls in Section 6.2 of the Strategy for Salmon (Northwest Power Planning Council 1992) for performance standards, independent audits, and unpact assessment for all Columbia Basin hatcheries. Finally, results from hatchery monitoring must be regularly evaluated to make appropriate mid-course corrections, even when this may mean termination of a hatchery program because major problems cannot be corrected. Some pieces of a comprehensive hatchery monitoring system exist or are under development. The Columbia River Basin is rapidly moving towards marking of all hatchery fish, although several concerns must be resolved. This 112 would make it possible to selectively harvest hatchery fish from mixed stock fisheries, identify stray hatchery fish, and evaluate homing of hatchery fish to desired natural spawning grounds. Under the Yakima/Klickitat Fisheries Project, genetic monitoring guidelines are being developed that will be generally appUcable to salmon hatchery programs. Hie most commonly used monitoring tool is a method of identifying genetically distinct populations, called protein electrophoresis, lliis method is increasingly used by state and federal fisheries management agencies to assess catches of different Pacific salmon stocks in mixed stock fisheries. Unfortunately, it cannot distinguish hatchery fish from depressed naturally- reproduced populations in a mixed stock fishery (Craig Busack, Washington Department of Fisheries, Genetics Program, Olympia, WA, personal commimication). It is also used to inventory the distribution of distinct populations in fi^shwater habitats. An example is the 1992 Washington Salmon and Steelhead Stock Inventory, jointly produced by Washington Department of Fisheries, Washington Department of Wildlife, Northwest Indian Fisheries Conunission, and Washington Treaty Indian Tribes. Such inventories are required to identify depleted populations and to properly design restoration programs. Overhaul of the present hatchery system is needed to assist restoration. A recent genetic analysis of hatchery policies and guidelines in the Colimibia Basin (Kapuscinski 1991) revealed tremendous variabiUty among fisheries management agencies in thoroughness and biological quaUty of their approaches. This finding, which is probably also true for hatchery programs outside of the Columbia Basin, makes it highly unlikely that the present system can successfully restore many naturally spawning populations. In addition to structural and operational changes mentioned in my comments above, two major system-wide changes are needed. First, all fisheries management agencies must improve the biological quality and consistency of their hatchery policies and practices because these have major impacts on sustainability of naturally-reproducing populations. Second, improved coordination is desperately needed among agencies with overlapping responsibilities for the same or interacting natural populations. Coordination should focus on planning, risk assessment, monitoring, evaluation, and mid-course corrections of all hatchery programs. 113 REFERENCES Haid, J. J., R. P. Jones. Jr., M. R. Dclann, and R. S. Waplcs. 1992. Pacific salmon and artificial propagation under the Endangered Species Act U.S. Dcp. Commcr., NOAA Tech. Memo. NMFS-NWFSC-2. 56 p. Kapuscinski, A. R. 1991. Genetic analysis of policies and guidelines for salmon and stcelhcad hatchery production in the Columbia River Basin. Prqpared for the Northwest Power Planning CouncU [Agreement 90-037], March, 1991. 35 p. Kapuscinski, A. R. , C. R. Steward, M. L. Goodman, C. C. Krucger, J. H. Williamson, E. Bowles, and R. Carmichael. 1991. Genetic conservation guidelines for salmon and steeihead supplementation. Report from a Northwest Power Planning Council Workshop, convened January 1991. 56 p. and figures. [Fishery Bulletin: in preparation.] Kapuscinski, A. R. and L. Miller. Genetic hatchery guidelines for salmon and steeihead in the Columbia River Basin, in Preparation for Yakima/Klickitat Fishery Project, Washington Department of Fisheries and Bonneville Power Administration. Li, H. W., C. B. Schrcck, C. E. Bond, and E. Rextad. 1987. Factors influencing changes in fish assemblages in Pacific Northwest streams. Pages 193-202. In W. J. Matthews and D. C. Hein (eds.). Community and evolutionary ecology of North American stream fishes. University of Oklahoma Press, Norman. Nehlsen, W., J. E. Williams and J. Lichatowich. 1991. Pacific salmon at the crossroads: stocks at risk from California. Oregon. Idaho, and Washington. Fisheries (Bethesda) 16(2): 4-21. Northwest Power Planning Council. 1992. Strategy for salmon. Vol. H., Northwest Power Planning Council, Portland, OR. 98 p. Riggs, L. A. 1990. Principles for genetic conservation and production quality. Results of a scientific and technical clarificanon and revision. Prepared for The Northwest Power Planning Council, [Contract No. C90-0051. March 1990. 20 p. and appendices. 114 GENETIC HATCHERY GUIDELINES FOR THE YAKIMA/KLICKITAT FISHERIES PROJECT Preliminary Draft Prepared by Anne R Kapuscinski. Ph.D. Loren M Miller. M.S. Co- Aqua 2369 Bourne Ave. Si Paul. MN 55108 December 31. 1992 115 GENETIC CONCEPTS RELEVANT TO SUPPLEMENTATION 2 1 . 1 Types of Genetic Risk 2 1 .2 Genetic Processes Driving Genetic Risk 2 1.3 Relationship Between Genetic Risk and Rate and Scale of Supplementation 3 BROODSTOCK COLLECT ION 4 2.1 Choice of Donor Population for Use in Hatchery Propagation ^ 2.1.1 Restoration - priorities for choice of donor population 5 2.1.2 Augmentation- priorities for choice of donor population ^ 2.1.3 Augmentation of critically small populations- special considerations 8 2.1.4 Changes in priorities for donor stock sources 8 2.2 Collecting Broodstock Years Before Hatchery Returns Are Present 8 2.2.1. Collecting from moderate-sized populations 10 2.2.2 Collecting from small populations 1 1 2.2.3 Special attention to sex ratio 1 1 2.2.4 Special attention to age structure 12 2.3. Collecting Broodstock Years When Hatchery Returns Are Present 12 2.4 Captive Broodstock Programs 14 2.4.1 Captive broodstock program based on adult collections 1^ 2.4.2 Captive broodstock program based on juvenile collections - 15 2.5 Kelt Reconditioning (sieelhead only) 16 SPAWNING PROTOCOLS 20 3.1 Maximizing Effective Number 20 3.1.1 Maximize Ne for hatchery broodstock in hand 20 3.1.2 Maximize Ne for total h»u' population (Ryman and Laikre issues) 20 3.2 Mating Schemes - we will add figures to help explain mating schemes 20 3.2. 1 One by one 20 3.2.1.1 Male use - single 21 3.2.1.2 Male use - pair 21 3.2.2 Factorial 2 1 3.2.2.1 Least numerous sex - female, male use - single 22 116 3-2.2.2 Least numerous sex - female, male use - pair 23 3.2.2.3 Least numerous sex - male, male use - single with repeat 23 3.2.2.4 Least numerous sex - male, male use - pair with repeat 24 3.2.3 Diallel 24 3.3 Partial Spawning 25 33. 1 Evaluation of partial spawning 25 3. 3.2 Egg planting a possible alternative to partial spawning 26 Daily operational guidelines (addressed under other subheadings?) 26 Surplus of one sex (covered under mating schemes) 26 4. REARING PROTOCOLS 29 4. 1 Incubation 30 4.1.1 Incubation density 30 4. 1 .2 Substrate 30 4. 1 .3 Light 3 1 4.1.4 Temperature and oxygen 31 4.2 Juvenile Rearing 3 1 4.2. 1 Rearing densities 3 1 4.2.1.1. Culling excess juveniles 32 4.2.2. Container hydraulics 32 4. 2. 3. Habitat complexity 33 ,^ 4.2.4. Feeding conditions 33 4.2.5. Feeding and predator avoidance behaviors 34 4.2.6. Fish size and nutritional status at. release 34 5. RELEASE PROTOCOLS 38 5.1. Number of Hatchery Fish to Release 38 52. Life Stage at Release 38 5.3. Release Procedures 40 5.3.1 Smolt releases 40 5.3.2 Pre-smoli releases 4 1 54. Residualized Juveniles 41 6 GLOSSARY 43 7, BIBLIOGRAPHY 43 117 GENETIC ANALYSIS OF POLICIES AND GUIDELINES FOR SALMON AND STEELHEAD HATCHERY PRODUCTION IN THE COLUMBIA RIVER BASIN EXECUTIVE SUMMARY Prepared for The Northwest Power Planning Council [Agreement 90-037] Prepared by Anne R. Kapuscinski, Ph.D. Department of Fisheries and Wildlife University of Minnesota March 15, 1991 118 GENETIC ANALYSIS OF POLICIES AND GUIDELINES FOR SALMON AND STEELHEAD HATCHERY PRODUCTION IN THE COLUMBIA RIVER BASIN EXECUTIVE SUMMARY Purpose This report presents a genetic analysis of existing agency policies, guidelines, rules, or plans i related to hatchery production of salmon and steelhead in the Columbia River Basin. Agencies covered in this analysis include the U. S. Fish and Wildlife Service (FWS), Idaho Department of Fish and Game (IDFG), Oregon Department of Fish and Wildlife (ODFW), Washington Department of Fisheries (WDF), and Washington Department of Wildlife (WDW). Features of the Analysis Policies and guidelines were evaluated primarily for their effectiveness in conserving genetic resources found in naturally reproducing stocks. Evaluations were based on three related concerns: 1. Improperly managed hatchery programs may alter the genetic resources and life history patterns of hatchery stocks. 2. For many hatchery programs, direct or indirect genetic interactions between hatchery and naturally reproducing stocks are possible. 3. Alterations of genetic resources and life history patterns of hatchery stocks may threaten their fitness and the long-term perpetuation of naturally reproducing stocks with which they genetically interact. 1 For brevity in this report, "policy(ies)" refers to policies, rules, or plans; "document(s)" refers to policies, rules, plans, or guidelines. 119 Agency documents were compared for their treatment of five factors. These factors include: 1. definitions of key genetic terms and stock categories; 2. genetic goals of hatchery programs; 3. hatchery broodstock and rearing guidelines; 4. indirect genetic impacts of hatchery fish; and 5. genetics research and monitoring. Comparisons of Agency Documents Foremost protection of genetic resources in naturally reproducing populations appears to be the intent of all agencies. Most agencies h^ve a written statement of such a goal. Achievement of this goal, however, is greatly threatened by the tremendous variability among agencies in thoroughness and quality of their treatment of the five factors listed above. Conserving genetic resources of both naturally reproducing and hatchery stocks is highly dependent on proper handling of these factors. Yet no agency has considered them all in its written policies and guidelines (Table 1). Factors which are considered are treated with different degrees of completeness. A number of specific policies or guidelines may be inconsistent with the goal of conserving genetic resources in fish stocks. The body of this report presents a case-by-case examination of each factor in the suite of documents for each agency. Recommendations for Improvement of Agency Policies and Guidelines General recommendations are made for the five factors affecting conservation of genetic resources in salmon and steelhead stocks. A common theme of these recommendations is the paramount need for greater consistency in approaches of different agencies. Recommendations are summarized below. Definitions of Key Concepts A. Append definitions of genetic resources that are affected by management actions to all written policies and guidelines regarding salmon and steelhead hatchery production in the Columbia Basin. Specifically address polygenic variation for life history traits because long-term perpetuation of fish stocks is largely dependent on maintenance of this type of genetic variation. 120 B. Append biologically sound definitions and practicable assignment criteria for stock categories to all written policies and guidelines on salmon and steelhead hatchery production in the Columbia Basin. C. Define other frequently used terms in order to clarify the intent of a particular policy or guideline. D. Develop consistent definitions and assignment criteria for agencies whose actions impact the same or genetically interacting stocks. Genetic Goals A. Initiate all documents addressing hatchery production with a direct commitment to the following genetic conservation goal (Riggs 1990): maintain genetic resources of salmon and steelhead in native, naturalized, and artificially propagated populations with no avoidable and irreversible losses of genetic diversity resulting from management interventions or inactions. B. Consistent with this goal, make conservation of existing wild populations a first priority (AUendorf et al., 1990). C. For agencies whose actions impact the same or genetically interacting stocks, establish a consistent approach to meeting this genetic conservation goal by adoption of the production framework delineated in Riggs (1990) and clarified in AUendorf et al. (1990). Hatchery Broodstock and Rearing Guidelines A. Establish written guidelines for maintaining similar genetic resources and life history patterns in hatchery broodstocks and wild or natural stocks with which they may genetically interact. B. Establish consistency in guidelines of different agencies managing stocks in the Columbia River Basin. C. Provide written direction on donor stock source, adults mated, fertilization protocol, rearing practices, and size of donor stock remaining for natural reproduction: 1. Donor stock source: Hatchery stocks should be founded from carefully chosen donor populations which have genetic resources and life history patterns similar to the wild or natural stocks with which they may genetically interact (AUendorf et al. 1990). 121 2. Adulls mated: Prevent founder effects by ensuring that hatchery founders represent a statistically significant sample of the donor stock's gene pool. In every breeding season, maintain the largest effective population size possible under the operating constraints of a particular hatchery by: breeding as many parents as is feasible; mating at least one male per female in daily matings; whenever possible in daily matings. splitting gametes of the least numerous sex into subsets and crossing each subset with gametes from a different individual of the more numerous sex; and minimizing variation in family size at the time of mating. Avoid intentional and unintentional artificial selection in collection of parents from donor stock and from adults returning to the hatchery. 3. Fertilization protocol: Maintain high effective population size and minimize hatchery-induced variation in family size by using the milt from an individual male to fertilize the eggs of an individual female (Withler 1988). In cases where effective population size can be increased by breeding more than one male per female, use the milt of a different male to fertilize each separate subset of eggs from an individual female. In situations where egg supply is severely limited or male fertility is highly variable, pool tlie milt from overlapping pairs of males (A and B, B and C, C and D, etc.) and immediately fertilize eggs of individual females (Gharrett and Shirley 1985). 4. Rearing practices: Reduce artificial selection during incubation, rearing, and in fish releases. If artificial selection programs are planned or practiced, evaluate if they are consistent with genetic conservation goals. 5. Size of donor stock remaining to reproduce naturally: Ensure that numbers of individuals remaining to reproduce naturally are sufficiently large to prevent loss of genetic variation in the donor stock. Prevent selective removal of adults to ensure existing life history patterns of the donor stock are conserved in individuals remaining to breed naturally. Indirect Genetic Impacts of Hatchery Fish A. Institute policies and guidelines on indirect genetic impacts of hatchery stocks on wild and natural stocks. Consider impacts due to: ecological interactions, such as competition for limited resources in natural habitats; and reproductive overfishing in mixed-stock fisheries. B. Develop guidelines for case-by-case determination of allowable numbers of hatchery fish released in order to minimize indirect genetic impacts. 122 Genetics Research and Monitoring A. Develop evolutionarily valid criteria for assigning wild or natural stock status to naturally reproducing fish populations. B. Monitor levels of genetic variation for life history traits in hatchery stocks. C. Monitor genetic resources and life history patterns of wild or natural stocks with which hatchery stocks may genetically interact. D. Determine susceptibility of naturally reproducing stocks to indirect genetic impacts from hatchery stocks due to ecological interactions. E. If intentional selection programs are used, undertake carefully monitored small-scale experiments before considering operational implementation. F. Develop a database of life history patterns, genetic variation, and population dynamics of naturally reproducing and hatchery stocks. 123 Table 1. Comparison of agency documents reviewed for presence (+) or absence (-) of factors influencing conservation of genetic resources in fish stocks. Presence does not implv uniform qualitv nor appropriate approach in handling of these factors. Factor Genetic Definitions Stock Definitions Presence or Absence in Agency Documents FWS FWS-3I nDPG CO=W + + WW WDW Genetic Goals Stated -/+■ Broodstock and Rearing Guidelines: - Donor stock source - Adults mated - Fertilization protocol - Rearing practices - Size of remaining donor stock Indirect Genetic Impacts of Hatchery Stocks Research & Monitoring ./+■ + + -/+■ ./ + 3 -/ + ■ •I*' + + + ■/ + ■ 1. FWS-3, a "Fish Gene Resource Protection Policy" is considered separately because it is currently in draft form (see Appendix I). 2. This factor doesn't appear directly in the policies reviewed but is implied (see section 2.5 of main report). 3. Aspects of this factor appear in some but not all documents which should address it. 4. Handling of this factor is problematic (see section 3.3.3 of main report). 124 GENETIC ANALYSIS OF POLICIES AND GUIDELINES FOR SALMON AND STEELHEAD HATCHERY PRODUCTION IN THE COLUMBIA RIVER BASIN Prepared for The Northwest Power Planning Council [Agreement 90-037] Prepared by Anne R. Kapuscinski, Ph.D. Department of Fisheries and Wildlife University of Minnesota March 15, 1991 125 TABLE OF CONTENTS Purpose 2 Documents Included in the Analysis 2 1. DEFINrriONS 2 1.1 Genetic Definitions in Agency Documents 3 1.2 Improvement of Genetic Definitions 4 1.3 Stock Definitions in Agency Documents 5 1.4 Improvement of Stock Definitions 6 1.5 Improvement of Other Definitions 7 2. GENETIC GOALS OF HATCHERY PROGRAMS 7 2.1 Genetic Goals in Agency Documents 8 2.2 Genetic Goals in FWS Documents 8 2.3 Genetic Goals in IDFG Docimients 9 2.4 Genetic Goals in ODFW Documents 9 2.5 Genetic Goals in WDW Documents 9 2.6 Improvement of Genetic Goals 10 3. BROODSTOCK AND REARING GUIDELINES 11 3.1 Broodstock and Rearing Guidelines in Agency Documents 11 3.2 Guidelines in FWS Documents 11 3.3 Guidelines in IDFG Documents 13 3.4 Guidelines in ODFW Documents 14 3.5 Guidelines in WDF Documents 15 3.6 Guidelines in WDW Documents 17 3.7 Improvement of Hatchery Broodstock and Rearing Guidelines 17 4. INDIRECT GENETIC IMPACTS OF HATCHERY HSH 22 4. 1 Agency Policies on Indirect Genetic Impacts 23 4.2 Policy in FWS Documents 23 4.3 Policy in IDFG Documents 23 4.4 Policy in ODFW Documents 23 4.5 Policy in WDW Documents ,.24 4.6 Improvement of Policies on Indirect Genetic Impacts 24 126 5. GENETICS RESEARCH AND MONITORING 24 5.1 Research and Monitoring Needs in Agency Documents 25 5.2 Research and Monitoring in FWS Documents 25 5.3 Research and Monitoring in ODFW Documents 25 5.4 Research and Monitoring in WDF Documents 25 5.5 Improvement of Genetics Research and Monitoring 26 APPENDICES APPENDIX I. Agency Documents Analyzed 29 APPENDIX n. Agency Definitions of Stock Categories 30 APPENDIX in. Undefined Key Terms in Agency Documents 32 APPENDIX IV. Glossary 33 APPENDIX V. References Cited 35 127 GENETIC ANALYSIS OF POLICIES AND GUIDELINES FOR SALMON AND STEELHEAD HATCHERY PRODUCTION IN THE COLUMBIA RIVER BASIN Purpose The purpose of this report is to present a genetic analysis of existing agency policies, guidelines, rules, or plans' related to hatchery production of salmon and steelhead in the Columbia River Basin. The analysis addresses definitions of key concepts, genetic goals of hatchery programs, hatchery broodstock and rearing guidelines, indirect genetic impacts of hatchery fish, and genetics research and monitoring. Direct genetic interactions of hatchery fish with wild and natural fish, and effectiveness of hatchery programs in meeting a genetic conservation goal are considered throughout the analysis. Agency documents are compared for similarities, differences, and omissions. Recommendations are made for improvements, particularly to achieve greater consistency in approaches of different agencies. Documents Included in the Analysis Appendix I lists the documents reviewed and their abbreviations. Documents were provided by the Northwest Power Planning Council (except for FWS-3, FWS-4, FWS-5, FWS-6, and FWS-7, which were solicited directly from the agency). Agencies covered in this analysis include the U.S. Fish and Wildlife Service (FWS), Idaho Department of Fish and Game (IDFG), Oregon Department of Fish and Wildlife (ODFW), Washington Department of Fisheries (WDF), and Washington Department of Wildlife (WDW). 1. DEFINITIONS Discussions of management policies and specific guidelines for hatchery production of salmon and steelhead in the Columbia River Basin require frequent use of two types of terms: (1) gene resources to be conserved or otherwise managed; and (2) categories of fish stocks that are used in hatchery production or may genetically interact with hatchery-released ' For brevity in this report, "policy(ies)" refers to policies, rules, or plans; "document(s)" refers to policies, rules, plans, or guidelines. 128 fish. Explicit definitions and realistic assessment criteria for these terms are of paramount importance. When definitions and assessment criteria are missing from an agency's hatchery-related policy or guidelines, the intent of the document is ambiguous and the potential for having inadvertent errors in biological concepts or management actions is increased. Clearly stated definitions and assessment criteria serve several purposes: 1. They ensure that the intended meaning and implementation of hatchery policies and guidelines are consistent with the agency's desired management goals. 2. They clarify the purpose of and rationale for hatchery policies and guidelines, thus greatly reducing confusion and criticism from agency personnel, user groups, or other parties interested in salmon or steelhead resources. 3. They facilitate evaluation of the biological appropriateness of hatchery- related policies and guidelines. 4. They help to identify the types of data needed for monitoring effectiveness in achieving objectives stated in hatchery-related policies and guidelines. 5. They facilitate efforts to improve consistency in genetic goals among agencies involved in salmon or steelhead hatchery production in the Columbia River Basin. 1.1 Genetic Definitions in Agency Documents Genetic definitions are uncommon in the documents reviewed. ODFW-1 and WDF-1 contain some genetic definitions. They both lack criteria for assessing genetic resources of hatchery or wild and natural stocks, although WDF-1 presents some of the conceptual background. ODFW-1 contains a general definition for "genetic resources". The definition is broad enough that it can be interpreted to encompass all genetic resources recommended for definition (see section 1.2.1 below). More detailed definitions would clarify the intent and interpretation of this document. WDF-1 contains a glossary of some genetic terms. Important gene resources discussed in section 1.2.1 are explained in the body of the document, although the glossary doesn't contain concise definitions for all of them. 129 Documents of other agencies refer to genetic resources of stocks with a variety of undefined terms. IDFG apparently also uses WDF-1, a document which contains genetic definitions (Willa Nelson, NWPPC, personal communication); but there is no written reference to WDF-1 or its definitions. Frequently used terms lacking definition include: genetic characteristics, genetic dilution, genetic diversity, genetic integrity, genetic makeup, gene resources, genetic status, and genetic traits. Criteria for assessing the status of genetic resources in stocks are also missing. Appendix III summarizes the identity and location of these key undefined terms in specific documents. 1.2 Improvement of Genetic Definitions A. Append definitions of genetic resources affected by management actions to all written policies and guidelines regarding salmon and steelhead hatchery production in the Columbia Basin. B. Develop consistent definitions for agencies whose actions impact the same or genetically interacting stocks. Gene resources discussed below provide a starting place for developing practicable and biologically relevant definitions. Consistency of definitions among agencies in the Columbia Basin is encouraged, as this will facilitate coordinated development and achievement of genetic goals for hatchery programs (section 2). 1.2.1 Genetic resources to define Genetic definitions should address at least the following terms because: (a) they describe the genetic resources of fish stocks that may be affected by hatchery programs; and (b) these genetic resources greatly influence the fitness of individual fish, evolutionary potential of an entire stock, and chances of long-term perpetuation of fish stocks and species (section 2.6). A. Classes of genes - include structural genes (coding for a protein product), regulatory genes (control the functioning of structural genes), and genes coding for molecules involved in protein synthesis (e.g., a gene for ribosomal RNA). All three classes of genes are important for the fitness of individual fish. Adaptive evolution of an entire fish stock depends mostly on variability in structural and regulatory genes. 130 B. Types of genetic variation - include variation for qualitative traits (under single gene control) and quantitative traits (controlled by many genes, polygenic). Qualitative traits are described qualitatively rather than by a measurement. Examples of qualitative traits are polymorphic proteins detected by protein electrophoresis; variation in these polymorphic proteins are often used for fish stock identification. Quantitative traits vary in meristic or continuous fashion. Examples of quantitative traits are life history and performance traits. Because the majority of adaptive evolution in a population is based upon changes in quantitative traits rather than in qualitative traits (Lande and Barrowclough 1987), maintenance of genetic variation for quantitative traits is required to ensure long-term perpetuation of fish stocks. C. Hierarchical organization of genetic variation - includes variation in alleles within an individual's genotype, genetic variation between individuals within stocks, and genetic variation between stocks within a species. These three levels of genetic variation constitute the entire genetic diversity of a species. Hatchery-related policies and guidelines must be concerned with all three levels of genetic diversity because adaptive evolution and long-term persistence of the species depends on them all. Some genes within stocks may be organized as coadapted gene complexes. These are combinations of genes occurring in many individuals because they have functioned well together over many generations of natural evolution in the local environment. Occurrence of coadapted gene complexes and their relevance in environments highly altered by human activities (e.g., many parts of the Columbia River Basin) is not yet well documented in salmon and steelhead (Allendorf et al. 1990). 1.3 Stock Definitions in Agency Documents Documents FWS-2, IDFG-1, and ODFW-1 contain some definitions of stock categories. Definitions from these three documents fit under four possible headings based on different breeding histories of ancestors, particularly on the degree to which interbreeding with hatchery-released fish may have occurred: (1) hatchery stocks, (2) wild stocks, (3) natural stocks, and (4) transplanted stocks. Using these four headings. Appendix II compares the definitions found in the three documents. Definitions of hatchery and transplanted stocks may overlap because a hatchery stock may originate from a transplanted stock or from local stock. The category, natural stocks, is meant to be intermediate between wild and hatchery stocks. Appendix IV defines this report's usage of "wild" and "natural" stocks. 131 There is little consistency in stock definitions found in FWS-2, IDFG-1, and ODFW-1. Different conditions for breeding history have been used to distinguish between hatchery stocks, wild stocks, or natural stocks. Note, for example, the differences under the heading, hatchery stocks, in Appendix II. For FWS, a stock fits under this heading only if fish have been held and fed in a hatchery for more than two generations. A contrasting approach is taken by ODFW, which places fish under this heading if they are spawned and/or reared under artificial conditions regardless of the history of the parent stock. The IDFG definition rpost resembles that of ODFW by simply stating that hatchery fish are produced in hatcheries or other artificial facilities; however the issue of parental history is not explicitly addressed. Similar differences exist in definitions fitting under the heading, wild stocks. FWS-2 doesn't recognize an intermediate category of natural stocks while ODFW-1 and IDFG-1 have similar definitions. ODFW-1 is the only document that defines the category, transplanted stocks. Definitions for categories of stocks are not included in any WDF and WDW documents reviewed. Appendix III summarizes the identity and location of undefined stock terms. None of the documents reviewed give criteria for data to use in assigning a particular fish or stock to a category. 1.4 Improvement of Stock Definitions A. Append biologically sound definitions and practicable assignment criteria for stock categories to all written policies and guidelines on salmon and steelhead hatchery production in the Columbia Basin. B. Develop consistent definitions and assignment criteria for agencies whose actions impact the same or genetically interacting stocks. Genetic concerns about hatchery stocks are that they may: (a) lose genetic variation and develop different gene combinations and life history patterns compared to wild or natural stocks; and (b) reduce fitness and long-term perpetuation of wild and natural stocks with which they may genetically interact. Much uncertainty exists about the hatchery conditions, natural environmental conditions, and ancestral breeding histories under which these concerns are legitimate or unwarranted (AUendorf et al. 1990, Kelly et al 1990, Skaala et al. 1990). Properly designed and long-term monitoring studies would help remove some of 132 these uncertainties (section 5). Meanwhile, fisheries agencies are faced with the reality of having to manage these resources in the face of current uncertainties. Many hatchery policies and guidelines therefore contain components designed to minimize negative impacts on wild and natural stocks. Given the long history of hatchery fish releases and stock transfers, discussions of genetic concerns inevitably involve use of terms such as hatchery stock, wild stock, natural stock, etc. Rational formulation and implementation of policies addressing these concerns depend on having: (a) biologically relevant and clearly stated definitions; (b) practicable criteria for assignment of particular fish to each category; and (c) consistent definitions among agencies impacting the same or genetically interacting stocks. 1.5 Improvement of Other Definitions A. Define other frequently used terms in order to clarify the intent of a particular policy or guideline. Appendix III lists the identity and locations of these terms. 2. GENETIC GOALS OF HATCHERY PROGRAMS Fisheries agencies have two basic options for maintaining or increasing abundance of salmon and steelhead stocks in the Columbia River Basin. First, they can manage factors that directly and indirectly affect natural production. Natural production involves adults reproducing in natural environments, followed by survival of their offspring until recruitment to the fishery or escapement to spawning grounds. Second, they can release hatchery-produced fish and manage factors influencing their survival. Genetic interactions of naturally and hatchery produced fish are possible. Under certain conditions, these interactions may detrimentally alter genetic resources of wild or natural stocks, leading to declines in their abundance and long-term persistence in natural environments. Certain conditions in hatchery programs also may detrimentally alter genetic resources of hatchery stocks, leading to declines of their fitness in natural environments. Genetic goals are therefore an expected component of a biologically sound agency document for the use of hatcheries in maintaining or increasing stock abundance. 133 2.1 Genetic Goals in Agency Documents Documents of FWS, IDFG, and ODFW contain identifiable genetic goals for hatchery production. While not directly stated, goals are implied in some policy statements of WDW documents. WDF documents lack genetic goals. 2.2 Genetic Goals in FWS Documents FWS-1 contains the following statements relevant for a genetic goal: a. "Carry out broodstock activities in a manner that will preserve or optimize the genetic integrity of the stocks involved." b. "Strive to provide and/or utilize gametes and fry of the species and strain that best meet the biological requirements of the specific resource management programs." c. "Enter into trades, exchanges, or agreements with State or other Federal agencies, or foreign governments to obtain fish or eggs of the desired strain." While statement (a) is a genetic goal, it's intent is vague for two reasons. First, the expression "preserve or optimize genetic integrity" is undefined (Appendix III). Second, it is unclear if "stocks involved" includes wild and natural stocks that may genetically interact with hatchery fish. Statement (b) may be relevant to genetic goals, depending on the intended meaning of "biological requirements", which is undefined. Statement (c) permits stock transplantations with no recognition that this may lead to introduction of very different genetic material into the recipient stock and no provision for conditions under which this is warranted or unwarranted. Well-performing wild and natural stocks may be negatively impacted by such introduction of new genetic material. Allendorf et al. (1990) outline two situations in which introductions of new genetic material may be warranted. FWS-3, currently only in draft form, addresses some ambiguities of FWS-1. It's foremost goal is protection of "gene resources" of "native populations", including protection of genetic variation in hatchery stocks that may genetically interact with native fish. Also, it outlines steps for evaluation of potentially detrimental genetic impacts of stock transplantations. A genetic goal may be inferred in FWS-4 for Region 1 (covering the Columbia River Basin). It calls for favoring "wild fish strains over hatchery strains" and emphasizing maintenance and restoration of "natural- occurring runs of fish." 134 2.3 Genetic Goals in IDFG Documents This agency's genetic goals closely resemble those of FWS-3. IDFG-1 has two relevant statements. The foremost priority is "preservation of desirable genetic characteristics of wild fish." Consistent with this priority, "hatchery production programs will be managed in a manner that minimizes adverse effects on the quantity and quality of natural production of anadromous fish." In keeping with this policy, the draft Policy Plan for 1990-2005 (IDFG-3) states "the Department will strive to maintain genetic integrity of wild native stocks when using hatchery supplementation." The draft Fisheries Management Plan for 1990-1995 (IDFG-4) makes a similar statement (page 23). 2.4 Genetic Goals in ODFW Documents The Wild Fish Management Policy in ODFW-1 is similar to IDFG policy and the draft FWS-3. It states that "protection of genetic resources shall be the priority in the management of wild fish." Also, because "interbreedinf of hatchery fish with wild fish pose risks to conserving and utilizing the genetic resources of wild populations", alternative strategies are presented to limit these genetic risks. Finally, it mandates development of a gene conservation policy. The Natural Production Policy in ODFW-1 refers to the need to "conserve stock fitness and life history characteristics" in order to "protect and promote natural production of indigenous, and where desirable, introduced fishes." This policy doesn't clearly address the relationship of hatchery programs to the protection of natural production. Conditions for "desirable" use of introduced fishes are not defined. Except for ambiguities associated with these omissions, this policy generally concurs with the Wild Fish Management Policy. 2.5 Genetic Goals in WDW Documents While WDW policies lack a clear statement of genetic goals for hatchery production, a few statements imply their existence. These include: "minimize genetic and competitive impacts of hatchery fish on wild stocks whenever feasible" (WDW-1); "select a suitable wild broodstock for the rehabilitation program. This should be the wild stock indigenous to the river system" (WDW-2 and -3); and 135 10 "ensure that there will be no adverse impacts to existing fish populations" (WDW-6). WDW-1, WDW-2 and WDW-3 represent alternative strategies for hatchery production. Lack of an umbrella goal statement weakens these policies. It is unclear how the choice is made between hatchery releases to increase wild/natural spawning escapements (WDW-2) or to utilize unused or underseeded rearing habitat (WDW-3). A policy for choosing among alternative hatchery strategies may appear in documents in preparation addressing management principles and a steelhead plan (Bob Gibbons, WDW, personal communication). 2.6 Improvement of Genetic Goals A. Initiate all documents addressing hatchery production with a direct commitment to the following genetic conservation goal (Riggs 1990): maintain genetic resources of salmon and steelhead in native, naturalized, and artificially propagated populations with no avoidable and irreversible losses of genetic diversity resulting from management interventions or inactions. B. Consistent with this goal, make conservation of existing wild populations a first priority (Allendorf et al., 1990). C. For agencies whose actions impact the same or genetically interacting stocks, establish a consistent approach to meeting this genetic conservation goal by adoption of the production framework delineated in Riggs (1990) and clarified in Allendorf et al. (1990). Thorough explanation of the foremost need for this genetic conservation goal is presented in Riggs (1990). To reiterate, sustainable maintenance or increases in salmon and steelhead productivity in the Columbia River Basin can only be achieved if the genetic resources required for all forms of production, present and future, are maintained in perpetuity. Taken together, Riggs (1990) and Allendorf et al. (1990) provide a framework for carrying out this genetic conservation goal by delineating six guiding principles, six management opportunities existing in the Columbia River Basin (four involving hatchery production), and three production approaches (two involving hatchery production). 136 11 3. BROODSTOCK AND REARING GUIDELINES Achievement of a genetic conservation goal requires delineation of genetic guidelines for hatchery broodstocks and rearing practices. Broodstock management and rearing activities may alter genetic resources and life history patterns of hatchery stocks. In turn, hatchery-released fish may alter genetic resources and life history patterns of wild or natural stocks via interbreeding. Wild stocks may be genetically altered if excessive numbers of adults are removed to supply gametes for hatchery stocks (section 3.7.5). Indirect genetic impacts are also possible if large numbers of hatchery fish enter into behavioral and ecological interactions with wild or natural stocks (section 4). Hatchery-related practices that may impact gene resources and life history patterns include: a. donor stock source; b. adults mated; c. fertilization protocol; d. rearing practices; and e. size of donor stock remaining for natural reproduction. 3.1 Broodstock and Rearing Guidelines in Agency Documents Agency documents vary greatly in their consideration of hatchery-related practices. Specific guidelines are uncommon and their quality is highly variable. No agency has written guidelines for all five practices listed above that may impact genetic resources and life history patterns of hatchery, wild, and natural stocks. 3.2 Guidelines in FWS Documents Two national-scope documents, FWS-1 and FWS-2, are silent on all hatchery practices important for a genetic conservation goal. The possibility of developing such guidelines is suggested, however, by statements about responsibilities of broodstock hatchery managers to develop and maintain general broodstock management guidelines which "may require a genetics plan, spawning plan, broodstock replacement plan, disposal plan, etc." FWS may address guidelines for some hatchery practices in case-by-case agreements signed with specific state or native American fisheries management agencies (Tom Sheldrake, FWS, personal communication). For example, the Warm Springs National Fish Hatchery is operated under an agreement between FWS and the Confederated Tribes of the Warm Springs Indian Reservation; some relevant hatchery practices are addressed for this hatchery in FWS -6 (discussed below). 137 12 Hatchery practices are partly covered in the draft FWS-3. Donor stock source is only indirectly addressed by discouraging intentional transplantation of fish. Fertilization protocol and size of donor stock remaining for natural reproduction are not discussed. Adults mated and rearing practices are partly addressed by the following statements: "The effective population number of broodstock shall be sufficient for fish reared in, imported to, or exported from hatcheries to preclude undesirable genetic changes." "Genetic engineering and selective breeding, other than that resulting in sterile hatchery fish or designed to mitigate hatchery induced genetic changes, shall be avoided where there is risk of adversely affecting native populations." FWS-5, a memorandum specific to Region 1, contains broodstock spawning, egg incubation, and egg handling guidelines. It partly covers genetic aspects of only two categories of hatchery practices. Adults mated are addressed by recommending a spawning ratio of one female with one male "when possible" and a minimum spawning population size of 200 males and 200 females, while noting that "the more individuals spawned however, the lower will be the incidence of inbreeding." Advice for fertilization protocol is to fertilize eggs from a single female with milt from only one male. This advice is consistent with recent research showing unequal contribution of males if sperm is pooled prior to fertilization (section 3.7.3). Finally, single female egg incubation is strongly encouraged for disease control. Such incubation could also benefit conservation of genetic variation in hatchery stocks if it became the first step in an overall program of identifying separate families in a breeding season (reasons presented in section 3.7.2). FWS-6 was provided as an illustrative example of case-by-case guidelines for a hatchery operated by FWS (Region 1) under agreement with another agency responsible for the fishery resource. While this particular example partly covers donor stock sources, adults mated, and rearing practices, complete coverage of all practices with potential genetic impacts is lacking when the hatchery-specific FWS-6 is evaluated together with the other reviewed FWS documents of regional or national scope. Donor stock source is appropriately restricted to fish occurring in the Warm Springs River, the same water body into which hatchery fish are released. To keep hatchery fish genetically similar to naturally- reproducing fish, at least 10% of the hatchery broodstock in every breeding season must be of "wild origin" (determined via fin-clipping of all hatchery releases). Such a strategy is appropriate for the stated objective, but genetic rationale for the 10% minimum is not given. Adults mated 138 13 are partly considered by requiring their collection from throughout the run and their spawning to be at random. Only one aspect of rearing practices is indirectly addressed by discussion of plans to initiate volitional releases and use of passive fish graders for separating fall (larger) from spring (smaller) release fish. This approach would also reduce sources of unintentional artificial selection at the time of release (section 3.7.4), thus increasing chances of keeping similar genetic resources and life history patterns in hatchery and wild fish. Size of donor stock remaining for natural reproduction is addressed by setting a healthy minimum natural escapement of 1000 "wild fish", based on an estimate that 1250 adults are "needed to maintain maximum wild production." 3.3 Guidelines in IDFG Documents Fertilization protocol is not covered in IDFG documents reviewed, although IDFG hatcheries apparently use WDF-2 (Willa Nelson, NWPPC, personal communication) which contains some fertilization guidelines (section 3.5.3). Discussions of donor stock source, adults mated, and size of remaining donor stock are spread among IDFG-2 and two subsections of IDFG-1. Relevant clauses are summarized below. 3.3.1 Donor Stock Source (•lDFG-2') "Artificial supplementation will utilize indigenous stocks whenever possible." "Upon loss of ability to propagate indigenous stocks, the following inherent and behavioral characteristics of potential donor stocks will be considered (not necessarily in priority order)." Items (a-f) in the list after this last statement follow the approach of matching the gene resources and life history patterns of hatchery broodstocks to the indigenous populations with which they may genetically interact. Items (g) and (h), however, contradict this approach by allowing differences in migration timing or size of mature fish of donor stocks when such differences would enhance a fishery. Potential impacts of these differences on genetic resources and sustainability of naturally reproducing stocks are not addressed. 3.3.2 Adults Mated flDFG-n This factor is not clearly addressed. One statement in the harvest management section of IDFG-1 (page 48) is partly relevant: 139 "whenever possible, we will continually integrate our hatchery and naturally spawning broodstock to maintain a hatchery stock which is capable of successfully surviving through natural production." -^13 Rearing Practices aPFG-l) The following policy is relevant to rearing practices: "Hatchery production goals will be set and manipulated by water temperatures, feeding rates, and general hatchery practices to produce and plant smolts of a size which has produced the highest percentage of returning adults in test programs." Currently, target smolt sizes are similar to natural smolt size for chinook salmon and larger than natural smolt size for steelhead (Steve Yundt, IDFG, personal communication). Maintenance of naturally existing genetic variation for smolt size, a quantitative trait, is important to ensure adaptive evolution and long-term perpetuation of a stock (section 1.2.1.B). Targeting one smolt size may cause inadvertent reduction in genetic variation for this trait and genetically correlated life history traits, thus jeopardizing sustainability of high adult return rates in future generations. . This practice therefore warrants careful review. A statement on page 9 of IDFG-1 acknowledges that "hatchery selection", including "accelerated rearing" could eventually pose a threat to stock persistence, particularly if timing, age composition, or fecundity of runs are altered. 3.3.4 Size of Remaining Donor Stock gPFG-n This issue is addressed by mandating that no more than two-thirds of a natural spawning run will be trapped to build hatchery broodstock in order to leave the remaining third for natural reproduction. The use of one minimum value for all natural spawning runs is a rough estimate, with no clear underlying rationale (Steve Yundt, IDFG, personal communication). Differences in historical patterns of genetic variation and population dynamics of different natural runs may dictate different minimum values in order to conserve their genetic resources and life history patterns. 3.4 Guidelines in ODFW Documents The Wild Fish Management component of ODFW-1 mandates management of hatchery broodstocks so that either: (a) interbreeding with wild populations is impossible; (b) where interbreeding of released hatchery fish and wild fish is possible, hatchery fish "are maintained to be genetically similar to the wild population"; or (c) except for fish genetically similar to the wild population, hatchery fish "that spawn at the same time 140 15 and place as the wild population shall comprise no more than 10% of the total number of naturally spawning fish." Biological rationale for the 10% value and its application to genetic conservation for all naturally spawning stocks is unapparent. Operating principles for keeping hatchery fish genetically similar to wild fish briefly consider donor stock source and adults mated. Rearing practices, size of remaining donor stock and fertilization protocols are not addressed at all, although they could be included in a gene resource conservation policy currently in preparation (Mark Chilcote, ODFW, personal communication). 3.4.1 Donor Stock Source This issue is briefly addressed without referring to specific guidelines: "Use only hatchery fish that originated from the wild population"; and "incorporate naturally produced fish in the broodstock in every generation." 3.4.2 Adults Mated Genetic concerns are briefly addressed without referring to specific guidelines: "Avoid random and nonrandom genetic change due to failure to maintain a representative sampling of the genes within a population." 3.5 Guidelines in WDF Documents WDF documents give guidelines for donor stock sources, adults mated, fertilization protocols, and rearing practices. WDF-1 provides the conceptual background and general guidelines. WDF-2 and WDF-3 give more specific guidelines. Owing partly to the writing style, much of the text in WDF-2 is hard to follow and rationale for some advice is ambiguous. Size of remaining donor stock is not discussed in any WDF document. 3.5.1 Donor Stock Source WDF-3 lists allowable donor stocks for various salmon hatcheries, with a preamble implying an approach of keeping hatchery stocks similar to natural or wild stocks with which they may genetically interact. Chapter 1 of WDF-1 directly calls for the same approach. It also recommends maintaining separate identity of stocks in situations where more than one stock is propagated at a hatchery. 141 16 3.5.2 Adults Mated Artificial selection: WDF-2 and chapter 1 of WDF-1 call for maintaining the genetic diversity of the donor stock in the hatchery stock by avoiding artificial selection unless "specifically directed to do so." WDF-1 explains that gametes should be collected from representative portions of each run, based on return date, size and age. WDF-2 goes on to specify that jacks should be included in the spawning population "at a level of 2% of the total number of both male and female fish spawned that day." While this is explained to offset the distortion in frequency of jacks caused by fishing gear selectivity and hatchery rearing conditions, rationale for a constant value of 2% in all cases is missing. Adherence to one value may be flawed for genetic conservation and long-term stock perpetuation. Neither document gives a policy for specific conditions which warrant intentional selection, although WDF-1 appropriately urges definition of goals and follow-up assessment of effects of any selection program. To be consistent with a genetic conservation goal, any directed selection program should begin with small-scale experimentation and careful monitoring (sections 3.7.4.B and 5). Number of parents: WDF-1 advises a minimum size of 200 parents when "the number of returning adults is not a limiting factor." This recommendation of one minimum value needs to be balanced by advice to maximize the number of parents, taking into consideration the operating constraints of a particular hatchery (section 3.7.2. A) and the demographics of the donor stock (section 3.7.5). Sex ratio: WDF-1 advises a 1:1 sex ratio with no provision for exceptions. Yet WDF-2 recommends a male to female ratio of 1:3 when: the number of available parents is not limiting, more than 0.5 million eggs will be taken on a g.iven day, and the egg surplus will be shipped to another facility. Justification for this advice is not provided. It is fiawed in terms of genetic conservation and long-term sustainability of stocks involved (section 3.7.2.A). 3.5.3 Fertilization Protocol WDF-1 and WDF-2 caution against sequentially adding milt from different males to a lot of eggs from several females because this has been shown to lead to unequal sex ratios. Both documents therefore recommend pooling milt from a number of males in a separate container, and then fertilizing 142 17 egg lots with this mixture. Neither document addresses unequal sex ratio problems associated with such pooling of milt (section 3.7.3). 3.5.4 Rearing Practices WDF-1 cautions against selection during rearing by advising that conditions be "as uniform as possible for all groups of fish." No guidelines are given about non-random culling of individuals from incubators and rearing tanks, a possible source of inadvertent artificial selection (sections 1.2.1.B and 3.7.4). Artificial selection of smolts is permitted, but only after "the majority of each group shows signs of smoltification" to compensate for sex-related differences in growth rate. No WDF document delineates conditions which warrant such selection of smolts (section 3.7.4). 3.6 Guidelines in WDW Documents WDW documents briefly refer to donor stock sources but are silent on guidelines for adults mated, fertilization protocol, rearing practices, and size of remaining donor stock. A document in preparation on genetic conservation and a management program for hatchery broodstock operations (John Kerwin, WDW, personal communication) may include guidelines for these practices. 3.6.1 Donor Stock Source WDW-2 and WDW-3 advise use of "wild stock indigenous to the river system", and, when this is impossible, consideration of "other stocks from nearby streams of similar size and type." Guidelines for donor stock sources are vague in WDW-1 and WDW-6, although the former document suggests strategies to minimize interbreeding of hatchery-released fish with wild stocks. 3.7 Improvement of Hatchery Broodstock and Rearing Guidelines A. Establish written guidelines for maintaining similar genetic resources and life history patterns in hatchery broodstocks and wild or natural stocks with which they may genetically interact. B. Provide written direction on donor stock source, adults mated, fertilization protocol, rearing practices, and size of donor stock remaining for natural reproduction. 143 18 Establish consistency in guidelines of different agencies managing stocks in the Columbia River Basin. 3.7.1 Donor Stock Source Hatchery stocks should be founded from carefully chosen donor populations which have genetic resources and life history patterns similar to the wild or natural stocks with which they may genetically interact (Allendorf et al. 1990). IDFG and possibly WDW pennit an alternative approach of using intentionally different hatchery stocks, along with methods to minimize their interbreeding with wild and natural stocks. To ensure compatibility with a genetic conservation goal, such an approach requires carefully designed monitoring of (a) frequency of interbreeding and (b) incidence of major behavioral or ecological interactions with wild and natural stocks that may lead to indirect genetic impacts (section 4). Releases of large numbers of sterile hatchery fish, for example, would require monitoring to ensure that the majority of individuals are indeed sterile and do not behaviorally or ecologically disrupt the fitness of natural or wild stocks. 3.7.2 Adults Mated A. Prevent founder effects by ensuring that hatchery founders represent a statistically significant sample of the donor stock's gene pool. In every breeding season, maintain the largest effective population size possible under the operating constraints of a particular hatchery. These recommendations will serve to reduce losses of genetic variation in hatchery stocks. Effective population size of a hatchery broodstock is usually smaller than the actual number of parents mated. Degradation of genetic variation due to reduced effective population size continues and accumulates over consecutive generations. 144 19 To maximize effective population size, hatchery operators must: 1. breed as many parents as is feasible; 2. mate at least one male per female in daily matings; 3. whenever possible, split gametes of the least numerous sex into subsets and cross each subset with gametes from a different individual of the more numerous sex; and 4. minimize variation in family size at the time of mating Recommendation 3 obviously places additional demands on labor and other operational constraints of a particular hatchery. Before implementing this mating procedure in a particular case, it may be desirable to evaluate its operational costs and genetic benefit. Genetic benefit, in terms of increased effective population size should be estimated using equations for effective population size as a function of sex ratio (Falconer 1981, Lande and Barrowclough 1987). Although variance in progeny number is a very important variable that should also be incorporated in this effective population size estimates (Lande and Barrowclough 1987), the necessary data are currently unavailable for most hatchery programs. This omission will not be corrected until families in hatchery stocks are identified, as discussed below. Variation in family size can be the most important cause of reduced effective population size and, thus, of erosion of genetic variation (Falconer 1981). Family size is the number of progeny, for one female or one male parent, that survive until they reproduce themselves. Minimizing family size variation in a hatchery stock requires mating similar numbers of males and females from each family occurring in the entire group of returning adults. This necessitates unique identification of each family released from the hatchery so that surviving family members can be recognized and counted when they return as spawning adults. One approach would be to conduct incubation and early rearing in separate compartments until fish are large enough to receive long-lasting tags (e.g., PIT tags), and then to estimate family size by reading the tags of adults returning to the hatchery. Future advances in application of DNA fingerprinting methods to fish may eventually allow non-lethal identification of families in the form of an intrinsic, biological tag. B. Avoid intentional and unintentional artificial selection in collection of parents from donor stock and from adults returning to the hatchery. 145 20 Hatchery broodstock should represent similar proportions of all life history traits existing in wild or natural stocks with which their progeny may genetically interact. Some agencies promote periodic infusion of gametes from wild or natural stocks into hatchery stocks with the expectation that this will keep genetic resources and life history patterns of hatchery stocks similar to those of wild and natural stocks with which they genetically interact. This strategy, however, will be futile if variation in family size is not minimized. To a lesser extent, effectiveness of the strategy also will be reduced if other recommendations for maximizing effective population size, preventing founder effects, and avoiding artificial selection in the hatchery are ignored. Carefully designed monitoring of genetic resources and life history patterns in hatchery and interacting stocks is therefore needed to assess effectiveness of periodic infusions of gametes from wild or natural stocks. 3.7.3 Fertilization Protocol A. MaintaiD high effective population size and low variatioD in family size by using the milt from an individual male to fertilize the eggs of an individual female (Withler 1988). B. In cases where effective population size can be increased by breeding more than one male per female, use the milt of a different individual male to fertilize each separate subset of eggs from an individual female. C. In situations where egg supply is severely limited or male fertility is highly variable, pool the milt from overlapping pairs of males (A and B, B and C, C and D, etc.) and immediately fertilize eggs of individual females (Gharrett and Shirley 1985). These recommendations differ from the common practice of pooling milt from several or more males prior to fertilizing a lot of eggs from an equivalent number of females. Pooled milt, however, leads to unequal contribution of gametes from different males due to differences in potency of their milt (Withler 1988). Consequently, effective population size is reduced due to unequal sex ratios, increased variation in family size, and smaller total number of parents. ' 146 21 3.7.4 Rearing Practices A. Reduce artificial selection and hatchery-induced family size variation during incubation, rearing, and in fish releases. Maintain uniform rearing conditions for all fish of the same stock. Avoid non-random culling of progeny during incubation, rearing, and in fish released. Evaluate the use of volitional releases as a means of reducing inadvertent selection. B. If artificial selection programs are planned or practiced, evaluate if they are consistent with genetic conservation goals. Require small-scale experimentation prior to full adoption of an intentional selection program. Require: well-defined goals; assessment of changes in genetically correlated traits; monitoring for progress towards stated goals; and monitoring for impacts on genetic resources and life history patterns of wild and natural stocks with which the selected stock may genetically interact. C. Consider quantitative assessment of the potential that hatchery environments inadvertently select against life history traits important for fitness of hatchery-reared fish in natural environments. A scientifically sound research and monitoring program would be needed to assess the circumstances under which this concern is valid. Examples of hatchery environmental conditions to examine are incubation and rearing temperatures, rearing densities, and timing and site of releases. 3.7.5 Size of Donor Stock Remaining to Reproduce Naturally A. Ensure that numbers of individuals remaining to reproduce naturally are sufficiently large to prevent avoidable losses of genetic variation in the donor stock. B. Prevent selective removal of adults to ensure existing life history patterns of the donor stock are conserved in individuals remaining to reproduce naturally. 147 22 For most wild and natural stocks, this recommendation is secondary to those regarding handling of hatchery stocks that may interact with them. This recommendation complements advice regarding effective population size and artificial selection of hatchery stocks. As in hatchery stocks, maintenance of genetic resources and life history patterns in the naturally reproducing component of donor stocks is influenced by effective population size. If agencies establish a lower limit on numbers of individuals remaining to spawn naturally, they must recognize that different lower limits may be necessary for different stocks. Attributes of the natural stock to consider include its population dynamics, viability in the face of fishing mortality and degraded natural habitats, and historically natural levels of genetic variation. Also as in hatchery stocks, prevention of intense artificial selection on the naturally reproducing component of the donor stock guards against loss of genetic variation needed for evolution and perpetuation in natural environments. Threatened and endangered stocks, which have experienced severe declines in abundance due to cumulative human impacts, present particularly difficult cases. When stock rehabilitation relies primarily on hatchery production as a means of rapidly increasing abundance, natural reproduction is further reduced by removal of gametes from many or all adults. When rehabilitation relies primarily on improving conditions for successful natural reproduction, use of hatchery production may be precluded. Genetic conservation implications of these alternatives and ways to strike a balance between them must be carefully considered. Agencies must rely on best available scientific information, but recognize that decision making will inevitably involve educated value judgements. 4. INDIRECT GENETIC IMPACTS OF HATCHERY FISH Frequent releases of large numbers of hatchery fish may have indirect genetic effects on wild and natural stocks. They may swamp mixed-stock fisheries, leading to reproductive overfishing of less productive wild and natural stocks. Genetic consequences of reproductive overfishing are reviewed in Kapuscinski and Jacobson (1987) and are beyond the scope of this report. Ecological interactions, such as competition for spawning sites and other limiting resources in natural habitats, also may indirectly change genetic resources and life history patterns of wild and natural stocks (Vincent 1987. Skaala et al. 1990). 148 23 4.1 Agency Policies on Indirect Genetic Impacts Documents of IDFG, ODFW, WDW, and a FWS draft have clauses related to indirect genetic impacts of hatchery fish whereas WDF and approved FWS documents do not. 4.2 Policy in FWS Documents The draft FWS-3 indirectly refers to this issue by prohibiting fish stocking where it "will threaten the persistence or reduce the productivity (recruits per spawners) of viable populations of the same or different species." Criteria for evaluating this threat should be developed. FWS-6, which guides activities only at the Warm Springs National Fish Hatchery, prohibits escapement of fin-clipped hatchery fish above the hatchery location. Also, FWS-7 is a Region 1 "policy on stocking fish at other than designated sites." It addresses emergencies when fish held in a distribution truck cannot be released at their designated site. While the intent of this policy may be interpreted to be protection of genetic resources of naturally-reproducing stocks, explicit statements to that effect are missing for "designated" and "alternate" sites. 4.3 Policy in IDFG Documents Partly in recognition of indirect genetic effects, no new hatchery programs were implemented during 1985-1990 (IDFG-1, p. 21). Major expansions of hatchery production are planned for the near future "as mitigation for losses to Idaho runs attributed to lower Snake River hydroelectric dams (IDFG-4)." The 1990-1995 Anadromous Fisheries Plan, currently in a draft not ready for public review (Steve Yundt, IDFG, personal communication), may have guidelines to prevent indirect genetic impacts of these expansions. 4.4 Policy in ODFW Documents ODFW-1 limits "the number of all naturally spawning hatchery fish to no more than 50% of the total number of naturally spawning hatchery and wild fish." The use of a constant percentage value is inconsistent with the goal of genetic conservation. A different limit on hatchery fish may be advisable in different cases. The appropriate number will depend on the purpose of the hatchery program (e.g., stock rehabilitation versus stock enhancement), the population dynamics of the naturally spawning stocks, and the carrying capacity of the habitat. 149 24 4.5 Policy in WDW Documents The policy in WDW-1 is to minimize "competitive impacts of hatchery fish on wild stocks" either by "selecting a hatchery stock with earlier return and spawning timing than the wild stock" or "keeping smolt numbers at a level that will not result in a large escapement of hatchery fish." WDW-2 and WDW-3 do not address ecological interactions of hatchery fish with wild fish but do refer to problems associated with mixed-stock fisheries. 4.6 Improvement of Policies on Indirect Genetic Impacts A. Institute policies and guidelines on indirect genetic impacts of hatchery stocks on wild and natural stocks. Owing to the magnitude and frequency of fish releases from hatcheries, the pervasive degradation of natural habitats, and the susceptibility of salmonid populations to density-dependent effects (e.g., McCarl and Rettig 1983, Vincent 1987), the potential for indirect genetic impacts on wild and natural stocks may be substantial. Genetic conservation is threatened if policies ignore this potential and focus only on direct genetic impacts of interbreeding between hatchery and wild or natural stocks. Effective hatchery policies and guidelines therefore must address this concern. B. Develop guidelines for case-by-case determination of allowable numbers of hatchery fish released in order to minimize indirect genetic impacts. Appropriate numbers of hatchery fish to release depend primarily on the population dynamics of the wild and natural stocks in the recipient environment and the carrying capacity of the habitat. 5. GENETICS RESEARCH AND MONITORING Research and monitoring needs for salmon and steelhead hatchery programs fall into three major categories. First, better understanding is needed of the status and variability of genetic resources in wild and natural stocks and their importance for ensuring perpetuation of stocks and species. Second, hatchery programs need to be properly designed and evaluated for their effectiveness in sustaining genetic resources of hatchery stocks. Third, monitoring of wild or natural stocks with which 150 25 hatchery stocks may interact is needed to ensure conservation of their genetic resources and life history patterns. 5.1 Research and Monitoring Needs in Agency Documents FWS, ODFW, and WDF documents refer to research or monitoring related to genetic concerns of hatchery programs. Other agency documents are silent on this topic. 5.2 Research and Monitoring in FWS Documents FWS-1 calls for cataloging "characteristics and management information for each available fish strain in the system." I^S-2 refers in several places to research or information on "genetic traits" and mandates assessment of hatchery fish performance and their impacts on "the genetic integrity and viability of wild stocks involved and the implications for meeting management objectives." Neither document specifies the types of genetic characteristics to emphasize. Prior to any stock transplantations, the draft FWS-3 requires collection of information to allow determination of threats to persistence and productivity of "viable native populations." Types of information needed are not specified. FWS-3 also calls for improved knowledge about inbreeding, outbreeding and genetic consequences of harvest and habitat loss or degradation. 5.3 Research and Monitoring in ODFW Documents The Wild Fish Management Policy in ODFW-1 mandates a program to monitor the genetic status of representative populations, but does not provide relevant guiding principles or criteria. 5.4 Research and Monitoring in WDF Documents WDF-1 calls for several types of monitoring regarding hatchery programs. These include monitoring of: 1. achievement of goals and effects of intentional artificial selection, if it is undertaken; 151 26 2. biological characteristics of adults returning to the hatchery; 3. location, size, identity, and performance of naturally spawning stocks in close proximity to hatcheries; 4. efforts to keep different intraspecific stocks reproductively separated in hatcheries; and 5. incidence of accidentally produced interspecific hybrids. 5.5 Improvement of Genetics Research and Monitoring Conservation of salmon and steelhead genetic resources depends heavily on proper understanding of natural evolutionary processes and impacts of hatchery programs on these processes Such understanding will only come from well designed research and monitoring as outlined below. A particular recommendation may contain both research and monitoring components. Details about research and monitoring methods are beyond the scope of this report. The topic of appropriate methods is introduced by Riggs (1990, Appendix VI) and Lande and Barrowclough (1987, pages 114- 119). A. Develop evolutionarily valid criteria for assigning wild or natural stock status to naturally reproducing fish populations. Factors to consider include history of stock transplantations, natural demographic history of the population, generations of interbreeding with hatchery stocks, magnitude of interbreeding with hatchery stocks, and genetic tag data (e.g., from DNA analysis). Uncertainty about these factors must also be considered in a biologically rational manner. B. Monitor levels of genetic variation for life history traits in hatchery stocks. Standard methods of quantitative genetic analysis are especially appropriate because they assess polygenic variation for quantitative traits. Such polygenic variation is most important for adaptive evolution of managed populations in natural environments (section 12.1.B). Determination of single gene variation, as done by analysis of protein polymorphisms or DNA, is of secondary importance for ensuring long-term perpetuation of fish stocks in natural environments but is a useful and complementary tool for addressing certain questions. 152 27 Monitoring programs must be designed to evaluate and prevent two sources of loss of genetic variation in hatchery stocks. First, random losses of genetic variation must be evaluated by monitoring effective population size in every breeding season, particularly as affected by variation in family size. Second, systematic losses of genetic variation must be considered by monitoring sources of inadvertent artificial selection. C. Monitor genetic resources and life history patterns of wild or natural stocks with which hatchery stocks may genetically interact. Similarities and differences between well-performing naturally reproducing stocks and hatchery stocks must be addressed. As explained for recommendation 5.5. B, monitoring needs to focus primarily on polygenic variation, and secondarily on single gene variation. Additionally, some relevant demographic information is obtainable from fisheries and stream surveys. D. Determine susceptibility of naturally reproducing stocks to indirect genetic impacts due to ecological interactions with hatchery stocks. Factors to consider are introduced in section 4.6. B. E. If intentional selection programs are used, undertake carefully monitored small-scale experiments before considering operational implementation. Requirements for any undertaken selection program are outlined in section 3.7.4.B. F. Develop a database of life history patterns, genetic variation, and population dynamics of naturally reproducing and hatchery stocks. Ideally, the database would integrate temporal and spatial information from the entire Columbia River Basin for genetically or ecologically interacting stocks. Such a database will facilitate research and monitoring of genetic concerns influencing sustainability of salmon and steelhead 153 28 stocks. It will also improve decision making about management actions in light of genetic conservation goals. For example, it could provide valuable information for making decisions about: 1. initiation of new hatchery programs; 2. improvement of new hatchery programs; 3. selection of suitable donor stocks; 4. size of donor stock remaining to reproduce naturally; 5. interbreeding between hatchery and naturally reproducing stocks; and 6. intentional selection programs. 154 29 APPENDIX I. AGENCY DOCUMENTS ANALYZED Agency abbreviations used in the text are given in parentheses. U.S. Fish and Wildlife Service fFWS^ FWS-1. Statement of Policy Regarding Fish Broodstock (2/12/88) FWS-2. Implementation Guidelines for the National Broodstock Program (9/14/88) FWS-3. Draft Fish Gene Resource Protection Policy [12/90 from R. Reisenbichler] FWS -4. Anadromous Fish Management - brief policy statement for Region 1, signed 2/9/79 by Regional Director [obtained from T. Sheldrake] FWS-5. Region 1 Broodstock Spawning, Egg Incubation, and Egg Handling Guidelines - memorandum from Assistant Regional Director, signed 9/18/89 [obtained from T. Sheldrake] FWS-6. Warm Springs National Fish Hatchery Operation Plan 1988-1991 [obtained from T. Sheldrake] FWS-7. Policy on Stocking Fish at Other than Designated Sites, signed 2/12/85 by Associate Director of Fishery Resources [obtained from T. Sheldrake] Idaho Department of Fish and Game (IDFG'> IDFG-1. Idaho Anadromous Fisheries Management Plan 1985-1990 (March, 1985) IDFG-2. Transfer Plan (part of Howell et al., 1985) IDFG-3. A Vision for Idaho's Future: Department of Fish and Game Policy Plan 1990-2005, Public Review Draft (May, 1990) IDFG-4. Draft Fisheries Management Plan 1990-1995 (August, 1990) Oregon Department of Fish and Wildlife (ODFWl ODFW-1. Natural Production and Wild Fish Management Rules (January, 1990) Washington Department of Fisheries fWDF) WDF-1. Hershberger, W. K. and R. N. Iwamoto. 1981. Genetics Manual and Guidelines for the Pacific Salmon Hatcheries of Washington WDF-2. Seidel, P. 1983. Spawning Guidelines for Washington Department of Fisheries Hatcheries WDF-3. Salmon Stock Transfers Lists (part of Howell et al., 1985) Washington Department of Wildlife rVVDW> - all documents dated 12/12/88 WDW-1. POL-5101 Hatchery Releases to Produce Harvestable Steelhead WDW-2. POL-5102 Hatchery Releases to Increase Wild Spawning Escapements WDW-3. POL-5103 Hatchery Releases to Utilize Unused or Underseeded Rearing Habitat WDW-4. POL-5104 Steelhead Marking, Tagging and Branding WDW-5. POL-5105 Steelhead Enhancement Coordination WDW-6. POL-5106 Disposition of Excess Steelhead Juveniles and Eggs 155 30 APPENDIX II. AGENCY DEFINITIONS OF STOCK CATEGORIES Italics : highlight key features of a definition, some of which differ among agencies. [ ]: explanatory notes that are not part of the agency definition. HATCHERY STOCKS FWS-2 Domestic Broodstock - population of fish (held and fed in a hatchery for more than two generations) that provides gametes for hatchery rearing programs. IDFG-1 Hatchery Fish - fish produced in hatcheries or other artificial facilities such as hatching and rearing channels or hatching boxes. [Criterion for parental history not stated.] ODFW-1 Hatchery Fish - a fish spawned and/or reared under artificial conditions regardless of the history of the parent stock. WILD STOCKS FWS-2 Wild Broodstock - population of fish in the wild that provide gametes for hatchery rearing programs {includes those populations established by stocking, anadromous stocks, and fish held and fed in the hatchery for less than two generations). IDFG-1 Wild Fish - a stock of fish, maintaining a population through natural production with no hatchery supplementation [in any past generations, Steve Yundt, personal communication], often the indigenous stock. ["Indigenous" is not defined.] 156 31 ODFW-1 Indigenous - descended from a population that was present in the same geographical area prior to the year 1800. Wild Fish - any naturally spawned fish belonging to an indigenous population of the following species... [list includes all Oncorhvnchus sp. found in Oregon.] NATURAL STOCKS IDFG-1 Natural Fish - progeny of hatchery fish which have reproduced in natural environments. Natural Production - fish produced by spawning and rearing in natural habitats with no artificial supplementation, regardless of the parentage of the spawners. ODFW-1 Naturally Spawned - spawned in the natural environment without the aid of humans. [Regardless of parental origin; Mark Chilcote, personal communication.] Native - a fish, species, or stock that naturally propagates in a defined geographic area. [Regardless of parental origin; this term wasn't used in the administrative rules reviewed but appears in other administrative rules; Mark Chilcote, personal communication.] Natural Production - the maintenance of naturally spawned fishes and their capacity to reproduce and rear in habitats which allow those fishes to fulfill all their necessary life history functions. Transplanted Stocks ODFW-1 Foreign (Imported) - a fish or stock which originated in another stream system, geographic area, state, or country. Introduced - originating in a stream system, geographic area, state, or country other than where now occurring. 157 32 APPENDIX III. UNDEFINED KEY TERMS IN AGENCY DOCUMENTS Term Agency Document Location^ Genetic Terms FWS IDFG ODFW WDF WDW gene resources FWS-3 genetic changes FWS-3 genetic characteristics IDFG-1 genetic dilution IDFG-1 genetic diversity FWS-4 WDF-2 genetic impacts WDW-1 genetic (gen.) integrity I^S-1 IDFG- 1,3 WDF-2 genetic makeup IDFG-2 ODFW-l genetic status ODFW-1 genetic traits FWS-2 genetically similar^ ODFW-l optimize , gen. integrity FWS-1 preserve gen. integrity FWS-1 lDFG-1 WDF-2 stock fitness ODFW-1 Stock Terms indigenous stock IDFG- 1.2 WDW-2.3 locally adapted popul. FWS-3 native populations FWS-3 natural spawning/reared WDW-2.3 wild fish FWS-5 WDW- 1-3 Other Terms biological requirements FWS-1 characteristics (of strains) FWS-1 highest quality eggs/fry FWS-2 serious depletion (of sp.) ODFW-l quality of natural product. IDFG-1 1. Abbreviations for agency documents are given in Appendix I. 2. Definition and criteria for assessment of this term are in preparation (Mark Chilcote, ODFW, personal communication). 158 33 APPENDIX IV. GLOSSARY Terms are defined as they are used in this report. They do not necessarily concur with definitions stated or intended in the agency documents reviewed. Thus, they don't necessarily apply to terms quoted or paraphrased from agency documents. Footnotes indicate sources of borrowed definitions. allele - an alternative form of the same gene.^ effective population size - the number of reproducing individuals in an ideal population that would lose genetic variation due to genetic drift and inbreeding at the same rate as the number of reproducing adults in the real population under consideration.^ family size - the number of progeny, for one female or one male parent, that survive to reproduce themselves. fitness - a measure of reproductive success of an individual that is influenced both by survival and fertility;* the frequency distribution of reproductive success for a population of sexually mature adults.^ gene - the basic chemical unit of hereditary information that is passed from parent to offspring.' Three classes of genes include: structural genes, regulatory genes, and genes coding for molecules (transfer RNA or ribosomal RNA) involved in protein synthesis. genetic correlation - correlation between the phenotypic values for two traits (e.g., growth rate and age at maturity) due to genes that affect both traits.^ genetic diversity - all of the genetic variation within a species. Genetic diversity includes both genetic differences between breeding individuals in a population (within stocks) and genetic differences between breeding populations (between stocks).' genetic drift - random changes in allelic frequencies due to natural sampling errors that occur in each generation; the rate of genetic drift increases as effective population size decreases.^ genetic resources - see definition for genetic diversity. 159 34 genetic variation - all the variation due to different alleles and genes in an individual, population, or species; includes variation in alleles and genes influencing qualitative traits (under single gene control) and quantitative traits (under polygenic control).^ genotype - the set of alleles for one or more genes in an organism; the entire set of genes carried by an individual.'^ hatchery stock - a group of interbreeding fish that are artificially propagated in a hatchery setting and for whom the breeding history of ancestors may or may not be known. inbreeding - the mating of related individuals.^ natural stock - a group of interbreeding fish that reproduce without the aid of humans and whose ancestors probably include hatchery propagated fish (degree of hatchery fish contribution is known or unknown). regulatory gene - a gene whose function is to control the transcription of other genes. Regulatory genes themselves do not code for synthesis of a specific protein. (See definition for structural gene.) structural gene - a gene that codes for formation of a specific protein. wild stock - fish that have maintained successful natural reproduction and are known to have had little or no supplementation from hatcheries in past generations.^ ^Same or modified definition from Riggs (1990), citing working glossary, prepared for the Northwest Power Planning Council by Fred Allendorf with reference to glossaries appearing in the Council's Fish and Wildlife Program and in Kapuscinski and Jacobson (1987). ^ Same or modified definition from Kapuscinski and Jacobson (1987). 160 35 APPENDIX V. REFERENCES CITED AUendorf, F. W., J. E. Lannan, and L. A. Riggs. 1990. Clarification of wild/natural production issues in the production principles. Submitted to The Northwest Power Planning Council, September 18, 1990. Falconer, D. S. 1981. Introduction to quantitative genetics. Longman, Inc., New York, N.Y. 340 p. Ghanett, A. J., and S. M. Shirley. 1985. A genetic examination of spawning methodology in a salmon hatchery. Aquaculture 47: 245-256. Howell, P., K. Jones, D. Scamecchia, L. LaVoy, W. Kendra, and D. Ortmann. 1985. Stock assessment of Columbia Eliver Anadromous Salmonids. Bonneville Power Administration, July, 1985. Kapuscinski, A. R. and L. D. Jacobson. 1987. Genetic guidelines for fisheries management. Minnesota Sea Grant College Program, St. Paul. 66 p. Kelly, M. D., P. O. McMillan, and W. J. Wilson. 1990. North Pacific salmonid enhancement programs and genetic resources: issues and concerns. Technical Report NPS/NRARO/NRTR-90/03. National Park Service, U. S. Department of the Interior, Washington, D. C. Lande, R. and G. F. Barrowclough. 1987. Effective population size, genetic variation, and their use in population management. Pages 87-123. In M. E. Soule (ed). Viable populations for conservation. Cambridge University Press, Cambridge. McCarl, B. A. and R. B. Retting. 1983. Influence of hatchery smolt releases on adult salmon production and its variability. Canadian Journal of Fisheries and Aquatic Sciences 40: 1880-1886. Riggs, L. A. 1990. Principles for genetic conservation and production quality. Results of a scientific and technical clarification and revision. Prepared for "Ilie Northwest Power Planning Council, [Contract No. C90-005]. Skaala, 0., G. Dahle, K. E. J^rstad, and G. Nzevdal. 1990. Interactions between natural and farmed fish populations: information from genetic markers. Journal of Fish Biology 36: 449-460. Vincent, R. E. 1987. Effects of stocking catchable-size hatchery rainbow trout on two wild trout species in the Madison River and O'Dell Creek, Montana. North American Journal of Fisheries Management 7:91-105. Withler, R. E. 1988. Genetic consequences of fertilizing chinook salmon (Oncorhynchus tshawytscha) eggs with pooled milt. Aquaculture 68:15-25. 161 ■~ftJU Stat«Bent of Trout UnllBited before the U.S. House of Representatives Coaaittee on Merchant Marine and Fisheries Subcoaaittee on Environment and Natural Resources on the Role of Hatcheries In Recovery of Naturally-Spawning Salaon Populations Prepared by Steven N. Moyer, Director of Govemaent Affairs March 9, 1993 Trout Onliaited (TO) is pleased to provide the following testimony for the Subcoaalttee's March 9, 1993 hearing on habitat/watershed aanageaent and the role of hatcheries in the recovery of natural ly-spa%ming salaon populations of the Pacific northwest region. TU is a national coldwater fisheries conservation organization of over 70,000 aeabers in 435 chapters around the nation. Dedicated to the preservation, protection, enhancement, and restoration of trout and salmon resources, TU is vitally concerned about the fate of declining Pacific salmon stocks. Recovery of these magnificent resources is one of TU's highest priorities. This hearing, others like it, and the Administration's upcoming "Forest Summit" are essential responses to the worsening ecological crisis in the Pacific northwest region. The plight of the northern spotted owl finally got attention focused on years of mismanagement of forests in the region. Unfortunately, forests were not the only resource mismanaged for decades in the region, and 1991 and 1992 saw three Pacific salmon stocks listed as either threatened or endangered (two Snake River Chinook America's Leading CoUtcaUr FiMheriet Coiuervation Orgaimation Wulmigum, D.C. Hcadqnulcn: 800 FoUm Luw, SE, Suite 250, Vieniia, VA 22180-4959 705-281-1100 FAX 703-281-1825 162 stocks as threatened in 1992; Snake River sockeye listed as endangered in 1991), due in large part to construction and operation of the Columbia River hydroelectric system. Willa Nehlsen's (et al 1991)' landmark study, "Pacific Salmon at the Crossroads: Stocks at risk from California, Oregon, Idaho, and Washington," raised the stakes even higher in this crisis by identifying 214 "at risk" (in immediate need of protection because of low or declining population size) stocks of trout and salmon in those states. The authors of this study also identified 106 Pacific salmon stocks that had already been driven to extinction. The new, stark reality for the region is that major changes must be made very soon to the land and water development activities that brought our salmon stocks to their knees. If such changes do not occur soon, the Endangered Species Act and court orders will dictate terms to the region for years to come. Pacific salmon are at a crossroads. The time for talk and study of the situation is rapidly dwindling. The time for bold actions, be they administrative or legislative, is now. Two topics critical to protecting and recovering Pacific salmon are those discussed today, habitat/watershed management and hatcheries. Our comments on these issues are set out below. The other critical components of the crisis are operation of the Columbia River hydroelectric system and harvest of Pacific salmon, by U.S. and Canadian harvesters. TU urges this Committee to look carefully at these other issues also, because resolving them will be crucial to ensuring recovery of these stocks. The Role of Hatcheries For too long, hatchery production of Pacific salmon has been the option of choice and the path of least resistance for reconciling the hard choices between extraction of some of the region's 163 natural resources and conservation of salmon. The outcome of this choice is now overwhelmingly clear: salmon, and the many people dependent on thea, have lost. Nowhere is this clearer than the Columbia River system where pre-European settlement r\ins, estimated at 16 million fish, have been reduced to severaly hundred thousand wild fish. This dismal record follows after construction and operation of 89 state, federal, and tribal hatcheries, and over one billion dollars spent under the provisions of the Northwest Power Planning and Conservation Act for salmon restoration, much of it on hatcheries intended to mitigate the effects of the Columbia's hydroelectric system. Hatcheries in exchange for habitat destruction has been a terrible deal for Pacific salmon. The region must immediately and dramatically make substantial changes to improve habitat protection and watershed management (such as those highlighted in Dr. White's statement), provide flows in the Columbia River hydrosystem which nurture and restore wild salmon, and substantially reduce salmon harvest. Importantly, the region must also reform hatchery production of salmon to ensure: 1) cost-effective results; and 2) most critically, that wild stocks are not damaged by hatchery-produced fish. TU believes that protecting and restoring wild salmon stocks are the keys to all salmon conservation efforts and the acid tests against which all hatchery efforts must be measured. Hatchery production of salmon must, in the words of a now widely used axiom, "first, do no harm," to wild fish stocks. The rich salmon genetic diversity of the region is one of its biological crown jewels. Those jewels have been diminished and tarnished greatly. Salmon conservation efforts should emphasize restoring this diversity and resiliency, not reproducing it in hatcheries where overwhelming evidence suggests we are doomed to fail. This is not to say that all hatcheries in the region are bad. 3 164 Some of the region's hatcheries have contributed siibstantially to sport and commercial harvest of Pacific salmon. Also, restoration of critically-low stocks of salmon will be dependent on hatchery fish for long term restoration efforts. However, data derived from hatchery operations in the region show that some are not cost-effective and risk damaging wild stock genetic diversity by comingling of wild and hatchery-reared fish of the ssune stock, and in some cases actually have damaged wild stocks. Just as development activities in the region must be reassessed and modified to better protect wild salmon, so too must the region's hatcheries. Fisheries managers must place greater emphasis on nurturing wild stocks and must eliminate hatchery and stocking practices which undercut that emphasis. In recent years, some fisheries scientists have raised serious questions about the effects of hatchery-produced fish on wild stocks. In particular, the widely practiced method called "supplementation," stocking hatchery-reared individuals of a particular stock on top of wild stocks has been questioned because of data showing genetic damage to wild stocks. A study by Nickelson et. al. (1986)" demonstrated that stocking of hatchery salmon caused a decline in total fish production by 50% and that this effect lasted into the following two generations. A modeling study by Byrne et. al. (1992)' predicted that long- term stocking of fry or smolts led to extinction of native fish in some scenarios. Finally, Waples's review of this issue (1990)* led him to conclude that hatchery fish can have substantial direct and indirect genetic impacts on wild fish. Although it is impossible to quantify, clearly at least some genetic damage is being inflicted on wild Pacific salmon stocks, and others are at risk of being damaged. To alleviate damage and minimize risk, federal, state, and tribal fisheries managers must 165 conduct thorough genetic monitoring of all stocking operations- To our knowledge, this is not being done on a systematic basis by many of the agencies involved in stocking programs. Fisheries aanagers Bust evaluate zmd Bonitor batcbery success to determine cost-effectiveness based on contribution to actual stock abundance. A second key question for the region's hatcheries is the question of cost-effectiveness. At a time when the fisheries budgets of all agencies are wanting, each dollar spent on salmon recovery must be well justified in terms of contributing to stock recovery. According to Oregon Trout", the Oregon Department of Fish and Wildlife recently calculated the cost per adult product from each hatchery in the state. Two examples of cost per adult that are exorbitant are spring Chinook from Lookingglass Hatchery at $872 per adult and spring chinook from Irrigon Hatchery at about $10,000 per adult. Clearly, this money would have been better spent on other management procedures, such as habitat restoration. Further, to look again at the Columbia River on a large scale, a 1992 General Accounting Office study found the cost of producing hatchery-reared salmon in the Columbia River basin to be $537,000,000. In light of the Columbia's declining runs and newly listed threatened and endangered stocks, this is a very poor investment. Even though the Oregon study may have been bad news for some, at least the study was conducted. Again, to our knowledge, few hatchery-operating agencies are conducting cost-benefit analyses that are based on cost per adult, i.e. contribution to the adult stock abundance. To upgrade efficiency of these operations. periodic cost-benefit analyses must be done for each State. federal, and tribal hatchery in the region. To reduce genetic risk and to ensure cost-effectiveness, an 5 166 Environmen'tal Impact Statement: (EIS) should be completed for the region's hatcheries. TU believes that the best way to evaluate the true environmental costs and cost-effectiveness of the region's state, federal, and tribal hatcheries is to follow EIS procedures of the National Environmental Policy Act (NEPA) , or something analagous to an EIS, to assess these operations. Such a process would ensure a common understanding of the best available data on these critical questions, consider a range of alternatives to the status quo based on the best available data, and then lead to modifications to hatchery operations to minimize risk and improve cost- effectiveness. TU recently has taken the initial steps of legal action in California to compel the state fisheries agency to do just this (comply with the state NEPA law) for its state hatchery operation. Another major benefit of the EIS process would be substantial public involvement in overseeing management decisions involving hatcheries. TU strongly believes that sport and commercial fishermen and the public need to be made aware of the costs and risks associated with hatchery operation, and should have full opportunity to "just say no" if they don't believe the costs and risks are worth the high expense of operating and maintaining hatcheries . To ensure that standardized procedures are followed, we recommend that the Secretary of the Interior, through the Director of the U.S. Fish and Wildlife Service, be charged with conducting such an NEPA/EIS evaluation. This process should be conducted and completed as quickly as possible so as to help guide recovery efforts of federally listed stocks as well as other regional stocks in decline. 167 Thanks again for the opportunity to provide these recommendations. We look forward to working with this Subconunittee on resolving the Pacific salmon crisis. Notes 1. Nehlsen, W., J.E. Williams, and J. A. Lichatowich. 1991. Pacific salmon at the crossroads: Stocks at risk from California, Oregon, Idaho, and Washington. Fisheries 16:4-21. 2. Nickelson, T.E., M.F. Solazzi, and S.L. Johnson. 1986. Use of hatchery coho salmon presmolts to rebuild wild populations in Oregon coastal streams. Canadian Journal of Fisheries and Aguatic Sciences 43:2443-2449. 3. Byrne, A., T.C. Bjornn, and J.D. Mclntyre. 1992. Modeling the response of native steelhead to hatchery supplementation programs in an Idaho river. North American Journal of Fisheries Management. 12:62-78. 4. Waples, R.S. 1991. Genetic interactions between hatchery and wild salmonids: lessons from the Pacific Northwest. Canadian Journal of Fisheries and Aquatic Sciences. 48 (Suppl.l) 124-133. 5. Bakke, W. 1993. Testimony of Oregon Trout, Inc. before the U.S. House of Representatives, Merchant Marine and Fisheries Committee, March 5, 1993. 5pp, 168 statement of Trout Dnlislted before the U.S. House of Representatives Merchant Marine and Fisheries Coamittee Subcoaoaittee on Bnvironaent and Natural Resources at a Hearing on Watershed Hanageaent in the Pacific Northwest Prepared by Dr. Ray J. White, Science Advisor March 9, 1993 My name is Ray J. White. I an an independent stream habitat consultant in Edmonds, Washington, near Seattle. I eun retired from Montana State University but remain on its adjunct faculty. My experience in assessing and restoring salmonld habitat covers 35 years, as a biologist in charge of evaluating Wisconsin's stream habitat management, as a visiting scientist In Europe, as a professor at two universities, and In consulting on many streams. I serve on Trout Unlimlted's volunteer Board of Scientific Advisors and I provide this statement on behalf of that orgemization and its 70,000 members nationwide. I also work with other fishery and conservation groups in the Pacific Northwest, and sit on the executive committee of a coalition of 35 organizations working to salvage the dwindling salmon resource. From close professional association with USFS and BLM scientists and managers, I have some understanding of their missions and of problems and opportunities confronting then — and AmerKa's Leading Coidwater FUherief Conservation Organization Washington, D.C. Headquarters: 800 FoUin Lone, SE, Suite 250, Vienna, VA 22180^959 703-281-1100 FAX 703-281-1825 169 a great interest in today's subject. I strongly support the initiatives in the U.S. Forest Service and Bureau of Land Management for better salaonid habitat, and for greater eaphasis on watershed integrity. The potential is great for positive chemge so that owe public forests and grasslands can do aore to help prevent the demise of the wild Pacific salaon resource — and help it on the road to recovery. In particular, I support the watershed approaches liKe those embodied in the Pacific Rivers Council's proposal and in earlier efforts to forge ecosystem-wide management systems like the so- called "Gang of Four" report on late successional forest ecosystems . As a scientist, I can speak to certain attributes of the watershed approach under consideration here today. It is based on science, it is geographically comprehensive, and it distinguishes between protecting present good habitat and restoring abused habitat. It emphasizes that, first and foremost, we should hang onto the good habitat that's left: our healthy watersheds. And it provides the basis for, as a second priority, restoring the various kinds of damaged habitat. I urge you to put it into effect on federal lands in the Northwest. Why? Because our Pacific salmon are in bad trouble, because past efforts to solve habitat problems have been inadequate, and 170 because the salmon need major, coordinated help now. Things people do have driven the resource to its knees. Washington's, Oregon's, Idaho's, and California's wild salmon populations are pitiful, fast-declining remnants of what they once were. In the last two years, fishing has had to be virtually stopped on many stocks. If we keep doing what we've been doing to our lands, forests and waters, there will soon be no economically viable wild salmon fishery. Please realize that a national treasure is collapsing. It is collapsing because of us — because of what vs. are doing. We can still turn the situation around if we change some of our actions, but it will have to be soon. Again and again in our history, we have destroyed the habitat basis of fisheries and thought that hatchery programs (a sort of fish farming) could make up for it. That hasn't worked. It has never worked. For fundjunental biological and economic reasons, it cannot work. Only healthy watershed ecosystems can economically produce salmon on a sustained basis. In the Pacific Northwest are we going to echo past folly? Will we continue to damage our forest and grassland watersheds and lose the fisheries that depend on them? 171 In our squandering of one aajor Aaerican fishery resource after another, destruction of virgin forests has played a major role. Beginning over 250 years ago, people cleared the East Coast forests. Together with overfishing, river dasming, and pollution, this eradicated our Atlantic salmon by about the year 1900. Massive artificial breeding and stocking in the late 1800s failed to save that magnificent fishery, and recent high-tech hatchery programs on somewhat rehabilitated streeuns have failed to recreate a significant Atlantic salmon fishery. We took the Midwest's timber, otherwise abused streams and lakes there, and devastated that region's fisheries. The once- thriving Michigan grayling dwindled as logging pushed across that state, and, by 1932, it vanished. The native Great Lakes fish community, much of which spawned in pre-logging streams, largely disappeared by 1945 or 1950. In it's place is a grotesque assortment of exotics — fishes that don't belong and don't function properly there. They don't behave themselves, so to speak. Now we have to put up with them and make the best of it. The virtual extirpation of beaver, followed by overgrazing, environmentally abusive hard-rock mining practices, excessive logging, and irrigation diversion, radically changed watersheds and streams in the interior West, annihilating many stocks of cutthroat trout, that region's primary native salmonid. Hatchery programs made the situation worse by genetic disruption and by 172 introducing competitor species. If we don't act fast and intelligently in the Pacific Northwest, we will soon complete a colossal repetition of those mistakes. Over 100 locally adapted Pacific anadromous salmon and trout stocks are already extinct: over 200 are at risk' of extinction. Only a fast-dwindling vestige of the world's once most spectacular salmon resource remains. And, as you know, several Pacific salmon stocks were recently listed as threatened and endangered, and petitions for listing many more stocks are imminent unless massive change is accomplished soon. Annually stocking millions of hatchery salmon has failed to stem the decline; it also has damaged wild salmon populations amd deluded people into ducking the hard decisions' ' * * '. Among the hard decisions society has all too often avoided are to protect intact habitat and to restore abused habitat. If we make better choices now, the remnant wild stocks can begin to rebuild themselves . An essential choice is to manage our federal lands differently. We have long tended to emphasize timber cutting and livestock grazing. After the Multiple-Use-Sustained-Yield Act of 1959, more effort toward non-commodity and indirect commodity uses of National Forests began. Still, these were too often token sidelines. It's easy to set policy, then work around it. 173 Where stream habitat work was done in the Pacific Northwest, it was at first often without scientific understanding; agencies sometisies did not realize how little they knew and proceeded on a so called "comiBon sense" basis, doing more ham than good. But much has been learned through trial, error, and research. USPS and BLM now have excellent knowledge and methods. What's needed is to eliminate traditional administrative obstacles and provide funding, so the agency stream scientists and managers can, in comprehensive, coordinated ways, do the job they know has to be done. Let's look at some general areas of stream management capability that have improved over the years. In the past, some stream restoration methods that work wonders in Midwestern creeks were applied to steep West Coast streams and did not withstand high flows' ', but now methods that are more durable and more in keeping with the Northwest's natural stream characteristics are used* " ", and there is profound understanding of the needs and possibilities for ecological approaches in such work". Also, until about 15 years ago common sense said wood debris jams in Pacific Northwest streams obstruct salmon runs, and major programs were undertztken to remove such material . But as Forest Service research revealed, salmon, having lived for millennia in streams choked with fallen wood, were well adapted to it; they 174 usually could get over or around the supposed obstacles, and wood debris accumulations (and beaver dams) proved to help produce salmon in many ways''. Old-growth forest sheds large logs and other woody debris into streams, tying their beds together, stabilizing them. The downed wood also traps gravel, forming spawning grounds, and provides complex cover and diverse pools, where fish hide, rest and feed" ". These effects are especially important on steep Northwest streeuns. An unfavorable administrative tendency in the USPS and BLM has been toward quick economic yields and technologic fixes rather than toward ecologic health emd long term productivity of lands and waters. It has been a ruin-and-rebuild approach, probably self -deceiving from the start, and often less than whole-hearted on the rebuilding end. Rather than managing conservatively for sustained natural functioning of forests and grasslands, on which such resources as salmon runs depend, there has been radical exploitation, giving high short-term profits to a narrow range of users and damaging fundamental land-water- vegetation functions, followed sometimes by so-called "mitigation." Whenever you hear "mitigation" in connection with stream habitat work, an alarm bell should go off in your mind, and you should examine for trouble. 175 In trying to mitigatively "fix" stream habitat after destructive logging, roading and grazing, public land agencies have gotten into trouble — applying aspirin while continuing to do what causes the underlying cancer. Stream habitat certainly can be restored. In small, gently-flowing creeks of the East, of the Midwest, and of western mountain valleys, it is relatively easy and inexpensive. But on steep, high-force streams of the Pacific Northwest, doing it right requires substantial investment of resources, something which agencies have too seldom seen fit to spend. This is not to say that stream habitat restoration should not be done in on the Pacific Northwest's streams. There has been huge damage, and our land management agencies and others should spend the funds needed for healing. And the basic approach should be more one of healing than fixing. The self- healing powers of Nature are tremendous. The main thing is to put Nature in position to exert that power. To enable healing, the first step is to remove the disease. This means halting or reducing the human activities that are causing the damage. Once that is done, the actions of water, soil and vegetation in shaping stream channels often will do much to bring back productivity for salmon. It is a principle of salmonid stream habitat management that the greatest gains are achieved by alleviating human influences on the worst-abused 176 streams. But keep in mind, this is second in priority to protecting remaining undamaged habitat. In other situations, putting Natxure in position to self-heal salmon habitat means putting jams of huge logs in streams where such "obstructions" were once removed when the channels were used to float logs to market — and where second-growth forest has not had time to grow and topple enough big trees to restore proper channel structure. Hundreds of years may pass before a second- growth forest does this, even if left uncut. I sulsmit that it will be most rewarding in the long run HOT to road and cut the scarce remaining old-growth forest, but to manage more conservatively our present timber-harvest forests and grazing lands. Thus, needs for costly "mitigation" will be reduced while reaping sustained benefits, such as salmon r\ins AMD timber AND Iseef AND wildlife AND recreation. Itany of the methods for such management have been developed by aquatic ecologists and hydrologists within USFS and BLM. The agencies should be reformed to enable these people to put into practice what they have developed. Organizing such reforms according to watersheds will be far more effective than according to the present administrative or political boundaries. A watershed is a logical xinit in terms of water catchment and flow and of the plant and animal life 177 deriving therefroa. A watershed is an ecosystem encompassing a nested system of forest (or grassland) and aquatic ecosystems. There is much call of late for "ecosystem" management. This makes eminent sense — managing for the function of the system, rather than managing parts of it piecemeal, without regard for other parts or the whole system. We do not yet know the forms that ecosystem management will take, but managing for ecological integrity (in a word, health) of watersheds will surely be a good start. The Pacific Rivers Council strategy for hanging onto the last best watersheds in the Pacific Northwest and for securing them by putting people to work stormproof ing the human-affected edges of such watersheds would seem to be one helpful first step. It is in keeping with the new management thrusts that are developing within USFS and BLM, based on scientific understanding of interrelationships among land, water and organisms. I urge that in guiding DSFS and BLM, Congress consider the proposal and the ideas presented here. Correcting the abuse of federal lands will go a long way toward ensuring the survival of many of the salmon stocks that are today in great peril. Ultimately, however, we also must address the threats that derive from the abuse of the non-federal lands that lie within our Pacific Northwest watersheds. To do so. Congress will need to take a hard look at the Clean Water Act. One of the Clean Water Act's primary objectives is to 10 178 restore and maintain the biological integrity of all waters of the United States. As Congress reauthorizes the Clean Water Act, I ask you to consider strengthening the Act's "non-point source" provisions and creating a strong anti-degradation policy to protect all of our nation's outstanding national resource waters. Doing so will mean that we can achieve on a comprehensive basis the same objectives that are under consideration here today. Thank you. I would be happy to answer any questions you night have. Notes 1. Nehlsen, W. , J. E. Williams, and J. A. Lichatowitch. 1991. Pacific salmon at the crossroads: stocks at risk from California, Oregon, Idaho, and Washington. Fisheries 16:4-21. 2. Goodman, M. L. Preserving the genetic diversity of salmonid stocks: a call for federal regulation of hatchery programs. Environmental Law: 20:111-166. 3. Hilborn, R. 1991. Hatcheries and the future of salmon in the Northwest. Fisheries 17:5-8. 4. Meffe, G. K. Techno-arrogance and halfway technologies: salmon hatcheries on the Pacific coast of North America. Conservation Biology 6:350-354. 5. White, R. J. 1992a. Why wild fish matter: a biologist's view. Trout (Trout Unlimited), Summer 1992:25-33,44-50. 6. White, R. J. 1992. Why wild fish matter: balancing ecological and aquacultural fishery management. Trout (Trout Unlimited), Autumn 1992:16-33,44-48. 7. Hamilton, J. B. 1989. Response of juvenile steelhead to instream deflectors in a high gradient stream. Pages 149-158 in R. E. Gresswell, B. A. Barton, and J. L. Kershner. Practical approaches to riparian resource management: an educational workshop. U.S. Bureau of Land Management, Billings, Montana. 11 179 8. Frissell, C. A., and R. K. Nawa. 1992. Incidence and causes of physical failure of artificial fish habitat structures in streams of western Oregon and Washington. North American Journal of Fisheries Management 12:182-197. 9. House, R., V. Crispin, and R. Monthey. 1989. Evaluation of stream rehabilitation projects — Salem District (1981-1988). Technical Note (T/N OR-6), U.S. D.I. Bureau of Land Management, Portland, Oregon. 10. House, R. , and V. Crispin. 1990. Economic analysis of the value of large woody debris as salmonid habitat in coastal Oregon streams. Technical Note (T/N OR-7), U.S. D.I. Bureau of Land Management, Portland, Oregon. 11. House, R., V. Crispin, and J. M. Suther. 1991. Habitat and channel changes after rehabilitation of two coastal streams in Oregon. Pages 150-159 in J. Colt and R. J. White, editors. Fisheries bioengineering symposium. American Fisheries Society Symposium 10, Bethesda, Maryland. 12. Sedell, J. R., and R. L. Beschta. 1991. Bringing back the "bio" in bioengineering. Pages 160-175 in J. Colt and R. J. White, editors. Fisheries bioengineering symposium. American Fisheries Society Symposium 10, Bethesda, Maryland. 13. Dolloff, C. A. 1986. Effects of stream cleaning on juvenile coho salmon and Dolly Varden in southeast Alaska. Transactions Of the American Fisheries Society 115:743-755. 14. Bisson, P. A. and eight others. 1987. Large woody debris in forested streams in the Pacific Northwest: past, present, and future. Pages 143-190 in E. Sale and T. Cundy, editors. Proceedings of a symposium on streamside management: forestry and fisheries interactions. University of Washington, February 12-14, 1986. 15. Sedell, J. R., P. A. Bisson, F. J. Swanson, and S. V. Gregory. 1988. What we know stbout large trees that fall into streams and rivers. Pages 47-81 in C. Maser, R. F. Tarrant, J. M. Trappe, and J. F. Franklin, editors. From the forest to the sea: as story of fallen trees. General Technical Report PNW-GTR-229. U.S. Department of Agriculture Forest Service, Portland, Oregon. 12 180 a OREGON TROU TESTIMONY OF OREGON TROUT, INC. before UNTIED STATES HOUSE OF REPRESENTATIVES COMMTTtEE ON MERCHANT MARINE AND FISHERIES SUBCOMMTTTEE ON ENVIRONMENT AND NATURAL RESOURCES MARCH 5, 1<><>3 The Honorable Gerry E. Studds, Chairman Dear Mr. Chairman: Oregon Trout, Inc. welcomes your invitation to provide written testimony to the committee regarding the role of hatcheries in recovery of Padfic safanon. We would appredate this statement being inchided in the committee record. Oregon Trout, Inc. is the lead petitioner on four q>ecies of Columbia River safanon that were listed under the Enoangered Species Act in 1991. Oregon Trout incorporated in 1983 with the mission of conservmg and restoring long-term abundance of wOd safanon, trout, and steelhead. The organization in headquartered in Portland, Oregon and has several thousand members throughout the Pacfic Northwest TTie Committee's Inanlrv should be expanded. The Committee's letter of February 19, 1993 asks three questions each of which presumes that some form of artificial production, a very expensive process, is necessary for the survival and restoration of "naturally-spawning" salmon populations. That presumption is not necessarily true and could lead the Committee to erroneous conchiaons. We suggest that the Committee ask the threshold questions: "Is any form of artificial production necessary to protect and restore naturally-q}awning salmon populations? If so, what are the criteria for use of artificial production and what steps can be taken without artificial production to protect and restore those populations? With an expanded focus the Conmiittee will learn that in many cases artifidal production is neither necessary nor beneficial to naturally-spawning salmon populations.. To Protect and Restore Native Fish and their Ecosystems ^w Water Tower BuUding • 5331 S.W. Macadam • Suite 228 • Portland, Oregon 97201 • (503) 222 9091 • FAX (503) 222-9187 181 The Honorable Geny Studds March 5, 1993 Page 2 ArtMktol productjon has no role until the reaaons for dccUne of naturallv-spawnlng salmon populations are known and anaivud. Salmon populations can decline for a number of reasons inchiding, 1. Overfishing. 2. Degraded water quality, 3. Lack of sufficient water quantity, 4. Disease, 5. Natural catastrophe -- forest fire, land slide, natural water pollution, etc., 6. Poor ocean conditions, lack of ocean based feed, 7. Freshwater habitat destruction. Qearly, artificial production is no substitute for abundant clean water, conservative harvest management, and conservation of freshwater habitat Survival of all naturally pawning populations requires those components. The use of artificial production is not inokingglass Hatchery spring chinook cost $872.00 per adult (this is a hatchery above eight federal dams in the Columbia River system). Irrigon Hatcheiy spring Chinook cost $10,000 per adult (this is another Columbia River hatchery above only three dams). In 1992 the General Accounting Office calculated the costs of hatcheiy salmon production in the Cohmibia River from 1981 to 1991 to be $537,000,000. However, during this time natural sahnon stocks continued to go extinct and five stocks were listed under the Endangered Species Act The investment in hatcheries foiled to arrest the salmon decline. On the other hand, naturalproduction is cheap. Fish that reproduce in healthy productive habitat cost nothing. The costs of restoring habitat and purchasing water are one time capital costs. They are by for the better long term investment 4. Hatcheries are not reliable. There is growing abundant evidence that hatchery enhanced fisheries begin to foil after a pericxl of years. Hatcheries necessarily eliminate a number of natural selection processes that humans cannot duplicate. Impaired operation of natural 183 The Honorable Geny Studds March 5, 1993 Page 4 selection in any population of animal weakens that population's adaptation to its environment. Year after year of hatchery output eventually weakens stocks subject to "enhancement" or "supplemcnUtion". In time those stocks cannot withstand environmental stress and change. Eventually they fail and the stock collapses leaving few alternatives other than importation and permanent artificial proectful]y submitted. Bin M. Bakke Oregon lYout, Inc. A*^T^lllf^^U literature citations list Bakke, Managing for Productivity: A New Strategy for Salmon Recovery (1993). 185 RBFSRBBCZ8 HATCHBRY AND WILD SALMON INTERACTIOM STUDIES: 1. Chilcote, M.W., S.A. Leider, and J.J. Loch. 1986. Differential reproductive success of hatchery and wild summer-run steelhead under natural conditions. Trans. Am. Fish. Soc. 115: 726-735. (Study shows that hatchery steelhead are at least nine times less productive in the natural stream environment than are wild steelhead. And wild steelhead have a higher survival rate than hatchery steelhead at every life cycle stage.) 2. Reisenbichler, R.R., and J.D. Mclntyre. 1977. Genetic differences in growth and survival of juvenile hatchery and wild steelhead trout. J. Fish. Res. Board Can. 34: 123-128. (Study shows that crosses of hatchery and wild steelhead produced less viable progeny than wild crosses and that hatchery crosses had the lowest survival. This study concluded that hatchery and wild crosses produced fewer smolts and adults in the next generation.) 3. Reisenbichler, R.R. 1984. Outplanting: potential for harmful genetic change in naturally spawning salmonids. p. 33-39. In J.M. Walton, and D.B. Houston [ed.] Proceedings of the Olympic wild fish conference. Peninsula College. Fisheries Technology Program. Port Angeles, WA. 4. Byrne, Alan, T.C. Bjornn, and J.D. Mclntyre. 1992. Modeling the response of native steelhead to hatchery supplementation programs in an Idaho river. N. Am. J. Fish. Mgt. 12: 62-78. (Study shows that long-term stocking of fry or smolts led to the extinction of native fish in some scenarios.) 5. Nickelson, T.E., M.F. Solazzi, and S.L. Johnson. 1986. Use of hatchery cobo salmon presmolts to rebuild wild populations in Oregon coastal streams. Can. J. Fish. Aquat. Sc. 43: 2443-2449. (This study showed that stocking of hatchery salmon caused a decline in total fish production by 50% and this effect lasted into the next adult and juvenile generation.) 6. Waples, R.S. 1990. Genetic interactions between hatchery and wild salmonids: lessons from the Pacific Northwest. Can. J. Fish. Aquat. Sci. Vol. 48 (Suppl. 1) 1991. (This paper investigates the effects of hatchery fish on wild fish, concluding that hatchery fish can have substantial direct and indirect genetic impacts on wild fish.) 186 TESTIMONY BY PETER BERGMAN BEFORE THE SUBCOMMITTEE ON ENVIRONMENT AND NATURAL RESOURCES OF THE COMMITTEE ON MERCHANT MARINE AND HSHERIES. I am aware of the experts who will provide testimony to you and I will not dwell on topics I'm sure they will discuss in detail. Briefly, hatcheries used properly are useful or essential for the recovery of many natural salmon stocks. An extreme example is the use of hatcheries for the several remaining Redfish Lake sockeye in Idaho; retaining these fish in hatcheries initially for their full life cycle appears to be their only hope for survival. There are enough examples of hatcheries like Spring Creek in the Columbia River or Minter Creek or Green River in Puget Sound to show that hatcheries used for production of cultivated salmon stocks can be very successful. Using hatcheries for rearing salmon to increase natural runs - i.e. fish that spend their entire lives in nature - is less well understood, but in various modes I have little doubt they can play a beneficial role. An important discussion of hatcheries and the protection of natural populations is the recently completed NMFS paper "Pacific Salmon and Artificial Propagation Under the Endangered Species Act". I would like to focus my testimony on the decision-making process which involves anadromous fish hatcheries in the Pacific Northwest. Making hatcheries successful for any purpose requires a logical management system, and the process used in the past will require major revisions to allow hatcheries to achieve their potential. The following remarks are specifically about the Columbia Basin, because I have recently examined it and because of its regional importance, but the issues are widespread. A key point to put my comments in perspective is that hatchery production in the Columbia has increased enormously over recent decades but adult production has not increased and has probably decreased. I believe the primary reason for this is an irrational decision-making process. The first management problem I would like to describe is jurisdictional. The Columbia contains about 100 anadromous fish hatcheries. They are operated or affected by a multitude of jurisdictions— at least three federal agencies, three states, several Indian tribes, several coordinating bodies, and a number of electric utilities. Certainly most of the important management decisions are systemic, involving groups of hatcheries, sub-basins, or the entire basin. But there is no directed authority or accountability for successful management. No one is in charge. There have been some recent, major efforts to coordinate these hatcheries. However, the system-wide decision making process is fundamentally based on consensus. Opinions on any given issue are ordinarily diverse, due to varying jurisdictional goals and a paucity of scientific information. Thus obtaining consensus is extremely difficult, and if obtained rarely rq>resents significant progress. 187 The second hatchery management problem is the process by which past experience is transformed into current management decisions. Obviously, in order to improve, proper goals must be established and the results of actions must be measured in terms of effects on the goals. But ordinary practice has been to judge success by numbers or pounds planted from hatcheries rather than the adults or catch produced, which are the proper goals. Whatever past goals should have been, they will clearly change in some fashion with natural stock emphasis. In any case, there is no modem, organized process to collect and analyze relevant information about measures of success to transform the results into new policies. Further, there is no adequate feedback loop to consider what research is most likely to be productive to improve success. There is, of course, much valuable experience currently in the system which, properly organized, could yield much progress. Most of this remains in the minds of individuals and disappears from the agencies when these persons leave, when it should be stored in modem computers which could provide institutional memories to avoid such losses. In conclusion, the anadromous hatchery system of the Columbia, and probably the Northwest, requires a central management authority. It should have ultimate responsibility for establishing goals, comprehensive planning, and monitoring and evaluating success in meaningful terms. It must be hdd accountable, be able to enforce its dictates, and will require a complete set of modem information management tools. This is not a proposal for changing existing agency control of particular hatcheries; rather, a higher level of control is required to remove jurisdictional gridlock and promote progress. 188 Review of the Oregon "A Review of Management and Environmental Factors Forest Industries Council Responsible for the Decline and Lack of Recovery of Oregon 's Wild Anadromous Salmonids" Report: (V.W. Kaczynski and J.F. Palmisano, June 1 Prepared by the Oregon Department of Fish and Wildlife "^.-^ '^^"^'^^^^^ ^^^— J_ -Z^^i^-^" Coordinated by Habitat Conservation Division Oregon Department of Fish and Wildlife Portland, Oregon December 1992 OREGON P^ 189 OREGON DEPARTMENT OF FISH AND WILDLIFE REVIEW COMMITTEE MEMBERS The following personnel of the Oregon Department of Fish and Wildlife contributed to the review of the OFIC sponsored document: Ray Beamesderfer Columbia River Research Program Project Leader Rich Berry Fish Propagation Section Program Director Jeff Boechler Forest Practices Program Coordinator Ron Boyce Columbia River Fish Passage Program Leader Robin Brown Nongame Wildlife Program Marine Region Coordinator Stephanie Burchfield Water Resources Program Program Manager Chip Dale Natural Production Program Program Leader Bob Garrison Fish Propagation Section Program Leader Steve King Columbia River Management Program Leader Marc Liverman Range and Grassland Projgram Grassland Habitat Biologist Dave McAllister Forest and Grasslands Program Program Manager Gail McEwen Land Use Planning Program Program Manager Don Mclsaac Harvest Management Program Manager Dave Nichols Fish Passage Program Program Manager Tom Nickelson Freshwater Production Research Program Program Leader Tony Nigro Columbia River Research Program Program Leader Martin Nugent Threatened & Endangered Species Program Coordinator 190 DRAFT EXECUTIVE SUMMARY In June 1992, the Oregon Forest Industries Council released a report titled "A Review of Management and Environmental Factors Responsible for the Decline and Lack of Recovery of Oregon's Wild Anadromous Salmonids". The purpose of the document was to evaluate and determine the relative contribution of management and environmental factors to the decline and lack of recovery of Oregon's salmonid stocks. The Oregon Department of Fish and Wildlife conducted a review of this report to determine if it provided constructive insight into defining and evaluating the problems affecting Oregon's anadromous salmonid resources. The Department's review of the report involved two major tasks: (1) a review of the scientific information presented in the report, and (2) an evaluation of the analytical methods used to rank the relative importance of factors implicated in the decline of Oregon's anadromous fisheries resources. The review of the scientific information included verification of the accuracy of the data and conclusions extracted from a portion of the cited scientific studies and information sources, and a review of the completeness of the scientific literature presented in the report. The review of the analytical methods used to rank the factors included an assessment of the technical validity of the methodology, and an evaluation of the scientific basis for the analyses according to the scientific information presented in the report. The Department's review indicated that the report contained major technical and analytical weaknesses caused by a failure to stratify analyses by location, by species and by life history stages within species. The relative importance of factors affecting the productivity of salmonids in Oregon varies by region and watershed according to the distribution and intensity of various human activities and environmental conditions. The report's analyses of the relative importance of environmental and management factors were based upon a statewide pooling of information that failed to reflect regional variability. In addition, certain changes in habitat or management practices will affect salmonid species differently, and will have varying effects on different life history stages of a given species. The analyses presented in the report fail to account for variability between species and life history stages, and limit the evaluation of the relative importance of the factors to the effects on "salmonids" as one homogenous group. A review of the scientific information presented in the report identified several problems including: (1) a failure to base analyses or conclusions on information presented in the report, (2) inaccuracies in the statistical information presented in the report, (3) inaccurate interpretation or reporting of scientific studies, (4) failure to analyze data using rigorous and scientifically valid methods, and (S) incomplete summary of scientific information available for a topic. These problems directly affect the validity of the information and conclusions contained within the report. The Department reviewed the methods used to rank the relative importance of the environmental and management factors, and assessed the validity of the conclusions derived from the analyses. The review indicated that these analyses were not based on empirical data and were largely subjective. The authors presented a matrix as a method to evaluate the relative importance of the factors, but the approach used in the matrix was inadequate. The fundamental problems with the report's matrix analysis methodology were: (1) the analysis was not stratified by location and species, (2) the impact of the factors were arbitrarily ranked, (3) some population impacts were multiple measures of the same effect on salmonid populations, (4) the measure of a 191 DRAFT factor's impact was arbitrary and was not based on a change in salmonid population abundance, and (5) the method used could not measure the impact of multiple factors acting simultaneously on a population. These matrix problems resulted in conclusions that were oversimplified, incorrect and not scientifically valid. To demonstrate the complexity of quantifying and evaluating the effects of various factors on salmonid production in a scientifically valid manner, the Department provides an example of an alternative matrix approach. The example approach is based upon a prediction of the relative change in adult salmonid production due to a variety of factors, and is consistent with concepts currently being used in life cycle modeling to weight the effects of various mortality sources on salmonid production :n the Columbia River Basin. A major difference between this approach and the report's matrix is that the relative importance of a factor, or combination of factors, is based upon the predicted change in total adult production of a species. The Oregon Department of Fish and Wildlife has concluded that this report does not provide an adequate scientific analysis or justification to support the conclusions concerning the relative contribution of environmental and management factors to the decline of Oregon's anadromous salmonids. BACKGROUND In June 1992, a report sponsored by the Oregon Forest Industries Council (OFIC) titled 'A Review of Management and Environmental Factors Responsible for the Decline and Lack of Recovery of Oregon's Wild Anadromous Salmonids' was released to the public. The purpose of this document was to evaluate management and environmental factors to determine the relative contribution of these factors to the decline and lack of recovery of Oregon's native salmonid stocks. This report has been heralded by the OFIC as "...the most comprehensive evaluation done to date on the relative reasons for the crisis in our fisheries. " The Oregon Department of Fish and Wildlife (Department) is very concerned with the decline of anadromous salmonid stocks in the Pacific Northwest. The scope of these declines was discussed in an American Fisheries Society report (Nehlsen et al. 1991). Given the importance of this issue to the activities and responsibilities of this agency, and to the citizens of Oregon, the Department conducted a review of the OFIC report to determine if it provided constructive insight into defining these current problems. This report presents the findings of our review. INTRODUCTION The Department's review of the OFIC report involved two major tasks: (1) a review of the scientific information presented in the report, and (2) an evaluation of the analytical methods used to rank the relative importance of factors implicated in the decline of Oregon's anadromous fisheries resources. The review of the scientific information included verification of the accuracy of the data and conclusions extracted from cited scientific studies and information sources, and a review of the completeness of the scientific literature presented in the report. The review of the analytical methods used 192 DRAFT to rank the factors included an assessment of the technical validity of the methodology, and an evaluation of the scientific basis for the analyses according to the scientific information presented in the report. SCOPE OF THE INFORMATION AND ANALYSIS The Department's review indicates the OFIC report contains major technical and analytical weaknesses. These weaknesses are based upon failures to stratify analyses by location and by species. Failure to Stratify by Species and Location The relative importance of factors affecting the productivity of salmonids in Oregon varies by region, and watershed according to the distribution and intensity of various human activities and environmental conditions. The OFIC report's analyses of the relative importance of various environmental and management factors (Tables R- 1 , R- 2, Table 2.3-1) are based upon a statewide pooling of information that fails to include regional variability in assessing the importance of these factors. The report's primary source of information comes from the Columbia River basin. Conclusions from this information are generalized to the entire state. Specifically, the majority of information presented on fishery harvest and management, hydroelectric development impacts, and predation is based upon Columbia River data. Reliance upon the history and dynamics of anadromous stock declines in this area to make conclusions for all populations within the State is unwarranted because of the following: (1) hydroelectric development, land and water use in this basin is unequalled in any other basin of the State; (2) the Columbia River basin has historically been the most active area for commercial fisheries, experiencing harvest rates well in excess of most other Oregon watersheids; (3) predation results are uniquely applicable to large hydroelectric reservoirs of the Columbia River Basin; (4) the majority of wild anadromous salmonid production occurs in coastal tributaries totally unrelated to Columbia River conditions. An example of how the use of Columbia River information fails to depict statewide conditions is the authors use of Columbia River tule and coho harvest data to represent the impacts of harvest on all wild populations of anadromous salmonids (V. W. Kaczynski and J.F. Palmisano, June 30, 1992). These stocks are of hatchery origin and are managed for high catch rates. Harvest rates predicated on these hatchery stocks is not a valid measure of the relative statewide harvest impacts on coastal stocks of coho and chinook, or on stocks of steelhead or seanin cutthroat trout. 193 DRAFT Failure to Stratify bv Species and Environmental Affects Certain changes in habitat or management practices will affect salmonid species differenUy. In addition, these changes will have varying effects on different life history stages of a given species. Yet, the analysis presented in the OFIC document regarding the relative importance of environmental and management factors is limited to the effects on "salmonids" as one homogenous group. This lack of differentiation between species or life stages among salmonids is apparent in the assessment of environmental and management impacts. The report provides no analysis that recognizes differential responses by different species that use similar or different environments in unique ways. For example, an alteration of freshwater habitat that reduces the abundance and quality of pools may not significantly affect the survival of steelhead fry, but will significantly reduce the survival of juvenile coho and age-1 + and older steelhead and cutthroat trout. The problem is further enhanced when the relative importance of these factors are represented as a statewide assessment of such different species as coastal stocks of coho and chinook, or on stocks of steelhead or searun cutthroat trout that may use the same habitat at different times. The report should provide an analysis for each species and each location or watershed, weighted according to the percentage of that species to the entire anadromous population, for the analysis to adequately depict the relative importance of factors on a statewide basis. The failure of the report to recognize location and species-specific differences in the evaluation of the relative importance of the factors fails to identify actual problems affecting anadromous salmonids in Oregon. TECHNICAL INFORMATION REVIEW A review of the scientific information and literature citations was completed to assess the accuracy and completeness of the document. This review involved comparing the information presented in the report directly to the conclusions and data presented in a sample of the original cited studies. The accuracy of selected data tables and figures, and a portion of 5ie personal communication citations were also verified. The Department did not verify all of the cited scientific studies, but selected a portion of these citations to assess the overall accuracy of the document. The following discussion summarizes the findings of our information review (see Appendix A for a detailed review). These findings are presented as an overall summary preceding specific comments on each chapter of the report. General Conclusions A review of the scientific information presented in the report identified several problems with the document. These problems include: (1) a failure to base analyses or conclusions on information presented in the report, (2) inaccuracies in the statistical information presented in the report, (3) inaccurate interpretation or reporting of scientific studies, (4) failure to analyze data using rigorous and scientifically valid methods, and (5) incomplete summary of scientific information available for a topic. A brief discussion of these specific problems is as follows: 194 DRAFT Failure to Base Analyses on the Information Presented The report is largely a compilation of statistics and information that lacks any direct correlation to the analyses and conclusions of the report. The use of statistics or information to evaluate the relative importance of the environmental and management factors is not documented nor apparent in the report. The conclusions appear to be derived from an independent, subjective ranking of the factors that is not based upon scientific information. An example of this problem exists in the discussion of fish harvest. This section presents a variety of harvest statistics but does not provide analyses that evaluate the relative contribution of this factor to the decline of salmonids. The report eventually concludes, however, that overharvest is the greatest factor responsible for the decline and lack of recovery of Oregon's anadromous salmonids (Table R-1). Information Inaccuracies The report contains a significant amount of incorrectly reported information, and examples where the biology of fish populations in Oregon were poorly understood by the authors. Inaccurate reporting of fisheries related statistics were prevalent in both the tables and in the text of the report (see Appendix A). One example of the authors misunderstanding of Oregon's fisheries resources is the numerous references to pink salmon "declines". The report begins by noting that "Oregon pink salmon are virtually nonexistent today... ' and attributes the "decline" of pink salmon to such factors as overharvest and mining. These conclusions are based on the absence of this species in ocean and inriver harvest statistics and does not recognize that pink salmon are not indigenous to Oregon. Pink salmon are intercepted in ocean fisheries off Oregon in odd-numbered years, and are occasionally observed straying into Oregon streams, but the normal distributional range of this species is from approximately Skagit Bay, Washington northward (Emmett et al. 1991). Inaccurate Interpretation or Reporting of Scientific Studies The report contains a number of examples where conclusions or data from the original studies were inaccurately reported (see Appendix A). The inaccuracies included: (1) citing conclusions that were not present in the original research, (2) citing only a portion of the original authors conclusions, (3) citing statements that were in direct conflict with the original study, and (4) citing information in a manner that was overtly discouraged by the original authors. A significant number of these inaccuracies were identified even though only a subset of the total literature citations were verified. Failure to use Rigorous and Scientifically Valid Methods to Analvze Data The report contained examples where information extracted from scientific studies were analyzed in a manner that was not scientifically valid. Incorrect conclusions were then derived from these calculations. For example, the questionable use of data was common in the discussion concerning the loss of salmonids to marine mammal predation. Calculations derived to estimate the annual consumption of salmonids by 195 DRAFT marine mammals for the entire state of Oregon (Table 2.2.7-2. and 2.2.7-3.) were based on questionable assumptions, incorrect estimates of marine mammal abundance and highly variable information that did not accurately portray the complex dynamics of predator-prey relationships. Incomplete Summary of Scientific Information The information included in the report is incomplete and selectively presented for several topics. In general, a signiflcant amount of information is presented concerning harvest and Columbia River issues, but considering the amount of information on the topic, little is presented for fish habitat degradation. For example, research studies on the effects of forestry practices are numerous, but only a minor portion of these studies were referenced. Several major topics, such as water temperature and the effects of long-term riparian harvest on large woody debris abundance were inadequately discussed. Several important forest management studies were also ignored including the Oregon Alsea Watershed Study (Moring 1975a, 1975b; Moring and Lantz 1975) and the Carnation Creek Study (Hartman and Scrivener 1990, Holtby 1988). These studies are unique in their assessment of the long-term effects of forest practices on the production of salmonids. An example where only a portion of the results of a study were presented was the discussion of the Tillamook Bay Erosion Study (USDA-SCS, 1978). In the discussion of this study, the authors misuse information to conclude that "stream sediments /rom agriculture were twice that from forests... on a unit area basis... " In making this conclusion, the report directly conflicts with conclusions of the original study which states: "Erosion and sediment delivery rates on forest lands still make significant contributions to the problems of the basin. The mean annual gross erosion amounts to 286,245 tons. The mean annual fluvial sediment load is 51,602.6 tons from forest lands. These are 95.6 and 85.1 percent, respectively, of the basin totals. " (USDA-SCS 1978) "The total sediment in the system is the crucial problem. " (ibid) Chapter Summaries MANAGEMENTT FACTORS Section 1.1 Harvest The overall conclusion of this section is that overharvest is largely responsible for the decline of anadromous salmonids in Oregon. The major problems with this conclusion can be summarized into three general issues: (1) an over-reliance upon Columbia River harvest and population status data to conclude that anadromous populations are depressed statewide due to harvest. (2) failure to acknowledge the synergistic relationships of habitat alteration, harvest, and other factors to explain population declines. 196 DRAFT (3) limiting the comparison of "recent trends" to the period of the 1970's to 1990 is too short a timeframe to derive conclusions concerning the health of anadromous populations. The effects of increased regulatory restrictions on harvest, and natural variability in run sizes prohibit making definitive conclusions based upon this range of information. In addition, the supporting tables and figures that report fishery harvest statistics contain a significant number of inaccuracies (see Appendix A). Section 1.2 Fish Resource Agency Policies and Goals This section describes management goals and trends in the escapement of Oregon Chinook and coho salmon stocks, and fishery agency policies related to the management of these populations. The major problems within this section are as follows: (1) declines in Oregon's salmonids are attributed to harvest and harvest management policies without recognizing that changes in the productivity of individual stocks (as reflected by stock-recruitment relationships) due to freshwater habitat degradation can influence spawning escapement. Changes in freshwater habitat productivity can synergistically contribute to the decline of salmonids when harvest management does not compensate for these changes. (2) escapement information for chum salmon, steelhead and searun cutthroat were not presented due to lack of data on these species. However, the report uses escapement trends for coho and chinook to conclude that harvest is a primary factor in the decline of all Oregon's anadromous salmonids (Tables R- l,R-2 and 2.3-1). (3) ODFW methods to estimate the escapement of coastal wild coho stocks are inaccurately portrayed. (4) the report describes an ODFW Harvest Policy which does not exist. (5) in describing the ODFW Wild Fish Management Policy, no acknowledgment is given to Habitat Policies which are an integral component. Section 1.3 Hatcherv Practices This discussion is a general presentation of past hatchery management practices (largely based on Columbia River information) that is an inaccurate portrayal of the majority of current ODFW Fish Propagation programs. The report fails to note that many of the practices described have been discontinued. In addition, no information is presented that could provide the basis to rank the importance of this management factor to the decline of Oregon's anadromous salmonids. 197 DRAFT ENVIRONMENTAL FACTORS .Wtion2.1 Water Use This section discusses habitat loss and reduced salmonid production due to dam construction, fish passage problems, inadequate water diversion screening, water flow reductions and fish habitat modifications. The focus of these habitat issues is primarily limited to the Columbia River Basin, and very littie information is presented for coastal tributaries. The following problems were identified: (1) the loss of habitat due to blockages from dam construction is reported as one-third of the anadromous salmonid habitat in Oregon. This loss is largely restricted to the Columbia Basin. The report does not acknowledge that this problem is minor on coastal streams where significant anadromous production occurs. (2) the discussion of upsti-eam passage issues is restricted to information from the Columbia Basin. (3) the scope of the current need to screen water diversions to prevent fish loss over-exaggerates the existing situation. The report implies that 55,000 water diversions are unscreened, so the loss of anadromous salmonids "...must be in the billions. ' The report does not recognize that of the 56,000 diversions reported, only approximately 4,000 occur where gamefish, or threatened or endangered nongame fish species are present. In addition, of these 4,000 diversions approximately one-fourth are presentiy screened. Of the 3,000 remaining diversions where screens are needed, a significant percentage impact only non-anadromous salmonids and/or nongame threatened or endangered fish species. The discussion should also be regionalized to reflect the relative importance of screening needs on fish bearing streams in different portions of the state. (4) the discussion of water withdrawals and instream flow reductions is limited to the Columbia Basin. The relative importance of this issue to coastal watersheds is not assessed. Section 2.2 Land Use 2.2.1. General The report presents a historical perspective of human development, and a description of the land management and ownership patterns in Oregon. A substantial portion of this section is devoted to describing the negative affects of roads on sti-eam habitats and the survival of salmonids. This discussion is accurate, but the report fails to acknowledge that a majority of road miles and road-related impacts occur in relation to forest management activities. The scientific studies cited as the basis for the discussion were primarily forestry studies. The effects of riparian vegetation removal on water temperature, sources of large woody debris and nutrients, and streambank stability are presented as "general" land management concerns. The report does not attribute the relative importance of these activities to different land management activities. 198 DRAFT 2.2.2. Agriculture The potential impacts of agricultural practices on salmonid production are attributed to irrigation, nonpoint pollution, erosion and grazing practices. In general, the report presents an accurate description of the potential impacts that these land management activities can have on salmonids. However, many of the "general" problems that are attributed to agricultural practices are equally pertinent to other land management activities. The following problems with the report were noted: (1) the use of Oregon Department of Environmental Quality (ODEQ) nonpoint source (NPS) pollution data (ODEQ 1988) to imply that agriculture is the primary contributor to these problems is not scientifically based. The report appears to conclude that agriculture is the most important land management factor to NPS pollution because "agricultural land use predominates monitored problem areas. " Assigning the relative importance of land management practices based upon the location of monitoring areas is invalid. The report does not acknowledge that upstream activities affect water quality in downstream (monitored) reaches. This discussion should have been placed in the "general" land management discussion as it is applicable to all land management practices. (2) the agricultural discussion is largely focused on conditions in the Columbia Basin. The information should have been regionalized to assess the relative importance of the various practices to anadromous salmonid declines in different locations of the state. (3) the report concludes that "agricultural practices are currently the dominant land use practices. . .of concern for wild anadromous salmonid fish in Oregon. " While agricultural practices are a concern in certain regions of the state, no empirical information is provided to support this statement for the entire state. 2.2.3. Forestry This section provides an incomplete review of the available scientific literature concerning the relationship between forest management and salmonid habitat productivity. The report fails to adequately present existing information for several important topics (large woody debris and temperature), attributes forestry-related studies and impacts to "other" land management discussions (roads and riparian vegetation removal), and ignores several important long-term studies of the affects of forest management on salmonid habitat and production. The report concludes that forestry is of limited importance to the decline of salmonids because current activities are being regulated by the Oregon Forest Practices Act. This conclusion does not recognize that past as well as current practices should affect the relative importance of these activities to the historical decline and lack of recovery of Oregon's anadromous salmonids. The following specific problems were identifial during the review: (1) the report does not incorporate several very important long-term studies of salmonids and forest management. Specifically, results from studies such as the Alsea Watershed Study and the Carnation Creek Study should be presented. 199 DRAFT The discussion does not recognize the long-term changes in habitat productivity that have resulted from forest management activities. (2) the importance of forest management activities to the long-term supply of instream large woody debris is inadequately discussed. Current shortages of this material are primarily attributed to past debris removal activities, but pertinent research concerning the influence of timber harvest in riparian areas to these shortages is not presented. (3) the affects of forest road construction on salmonid survival should be presented in this section. Forest roads are a significant proportion of the total road miles in Oregon. (4) the comparison of pesticide use in forestry and agriculture is not scientifically valid because the data used to make these comparisons does not include all forest lands. The original study reported pesticide use on US Forest Service lands only, and did not include other federal, state or private forest lands in the estimate. 2.2.4. Municipal-Industrial This section is primarily a discussion of point source pollution discharges by municipal and industrial entities without any empirical evaluation of the importance of these factors to the decline of salmonids. In addition, the tabular information that is presented to summarize these pollution problems is inaccurate. A table listing the number of stream miles "adversely affected" by such parameters as low dissolved oxygen, bacteria, turbidity, elevated temperatures, etc. is presented in a manner that implies that municipal and industrial sources are the cause. However, the data in this table actually reflects an assessment of statewide nonpoint pollution problems from a multitude of land use activities. The report cited for this information (ODEQ 1990) indicates that municipal and industrial sources are a minor component of the pollution problems, and that the majority of stream miles affected are attributed to forestry and agricultural practices. 2.2.5. Mining This section is a historical discussion of mininjg in Oregon with very little information presented concerning the effects of these activities on stream habitat or salmonid productivity. The information presented is inadequate to derive any conclusions of the relative importance of these activities to the decline of salmonids. This section is generally an accurate description of the variability that natural events can exert on the survival and productivity of anadromous salmonids, and appropriately notes that the magnitude of the effects of these events can be increased by land 10 200 DRAFT management activities. However, no information is presented to provide a basis to evaluate the importance of these events. There are several clarifications that should be included in the report: (1) the report implies that El Niiio events are relatively common in Oregon. In actuality, El Nino's of the magnitude to bring warm oceanic currents to the coast of Oregon are relatively rare: in the past fifty years this has only occurred four times (1941, 1957-58, 1982-83 and 1992). (2) the report does not acknowledge that oceanic events, such as El Nino, can affect salmonid species at differential rates due to differences in offshore migration patterns. For example, north-migrating chinook and steelhead are affected differentiy than Oregon coho or south-migrating chinook stocks. 2.3.2. Predation and Competition This section discusses the potential impact on anadromous salmonids from predation and competition with other wildlife such as marine mammals, birds and other fish species. Estimates of marine mammal predation and competition were based on questionable analytical methods. The information presented in this section was not adequate to evaluate the relative contribution of these inter-specific relationships to the decline of salmonids. The following problems were identified during the review: (1) the report fails to recognize that most of the inter-specific relationships discussed are natural occurrences (with the exception of American shad establishment), and that the relative importance of predation and competition is likely influenced by human activities. For example, decreases in salmonid abundance due to other factors such as harvest and habitat degradation result in ■^ natural losses (predation and competition) becoming increasingly more significant. In addition, no evidence was presented to indicate that such interactions have increased above natural historic levels. (2) the discussion of fish predation on juvenile salmonids is restricted to studies of the Columbia River where dam presence has a direct influence on predator- prey relationships. Similar predation rates are questionable for other watersheds in Oregon. However, the evaluation of the importance of this factor to the decline of salmonids does not recognize this regional variation. (3) squawfish predation estimates are extracted from one study that may have over-estimated predation rates due to sampling design problems, and another study that estimated squawfish predation in the immediate vicinity of hydroelectric dams where the predation rates observed are much higher than the rest of the squawfish population. (4) the discussion of competitive interactions with shad in the Columbia River is largely a hypothesis that is not substantiated by scientific research. The analysis fails to document the extent of spatial and temporal over-lap in estuary rearing habitat between juvenile shad and salmonids, and does not document whether food availability is limiting juvenile salmonid production within Oregon's estuaries. Interestingly, the report also does not note that juvenile shad are a prey source of juvenile salmonids in rivers and estuaries (Emmett et al. 1991). 11 201 DRAFT (5) estimates of marine mammal predation on salmonids are based upon "simple" mathematical calculations that do not adequately reflect the complexity of predator-prey relationships. In addition, these calculations are based on questionable assumptions, incorrect estimates of marine mammal abundance and population structure, and highly variable information. The variability of these estimates makes direct comparisons to fish harvest questionable. (6) the estimates of marine mammal predation are largely extracted from studies of the Columbia River estuary and the Strait of Georgia (British Columbia) where salmonids were concentrated or available during a large portion of the year. These studies cannot be applied to estimate salmonid consumption by Oregon marine mammal populations over a broad geographic area. In addition, calculations of marine mammal predation often assumed that salmonids were available for 365 days of the year: this assumption is not accurate for Oregon. CRITIQUE OF METHODS USED TO FORMULATE RECOMMENDATIONS The most important part of the OFIC report is the ranking of the relative importance of a variety of management and environmental factors to the decline and lack of recovery of Oregon's anadromous salmonids. This information could provide the basis for prioritizing management efforts to facilitate the recovery of these populations. The importance of the document is, therefore, largely dependent upon the validity of this analysis. The Department reviewed the methods used to rank the relative importance of the environmental and maiuigement factors, and assessed the validity of the conclusions derived from this analysis. The methodology employed to rank the factors may be best chara(;terized by the following text from the report: 'Two separate subjective methods were used to rank relative mortality: rough increased mortality associated with factors studied and a matrix approach. Tables R-1 and R-2 reflect those ratings. " Our review of Tables R-1 and R-2 indicated that these analyses were not based on empirical data. Table R-1 was created by an independent subjective ranking of the factors by the authors. Table R-2 was compiled using a matrix analysis approach (Table 2.3-1) but was also largely subjective. The fundamental problems with the authors matrix analysis methodology were: (1) the analysis was not stratified by location and species, (2) the impact of the factors were arbitrarily ranked, (3) some population impacts were redundant and were multiple measures of the same effect on salmonid populations, (4) the measure of a factors impact was arbitrary and was not based on a change in salmonid population abundance, and (S) the method used could not measure the impact of multiple factors acting simultaneously on a population. A discussion of these specific problems follows: 12 202 DRAFT (1) Analysis was not stratified by location and species The analysis did not stratify the evaluation of the impacts of the factors on salmonid populations by region, or by species. The relative importance of a factor to the productivity of anadromous salmonids will vary by region and watershed according to the distribution and intensity of the respective factor. In addition, the impacts of a factor will vary for different species due to the life history requirements and biological characteristics of each species. Failure to incorporate these stratifications into the analysis lead to incorrect conclusions concerning the relative importance of the factors. (2) The impact of factors were arbitrarily ranked The criteria for assigning a relative score (1, 2, or 3; Table 2.3-1) as a measure of the population impact of each factor in the matrix was not documented, and appeared to be arbitrary. The basis for assigning these values was not related to the discussions of the various factors, or information presented in the report. Since the relative impact rating for a factor was the sum of scores for all impacts assigned to the factor, the rating was very dependent upon the scores that were assigned. (3) Some population impacts were redundant Some of the population impacts in the matrix were redundant and were multiple measures of the same effect on salmonid populations. In the analysis, a factor was often given several scores for the "biological papulation impacts" even though the impact actually only represented a single effect on the population. This redundancy over-weighted the impacts of certain environmental or management factors on salmonid production. For example, salmonids harvested in ocean fisheries were given scores for biological impacts titled: "direct mortality-young", "direct mortality-adults", "indirect mortality", "contributes to mixed fishery", and "contributes to reduced spawning escapement". These scores were then added to obtain a relative impact score. The analysis failed to recognize that the five impacts are synonymous and represent a single effect on salmonid prwiuction (reduced adult spawning escapement). Assigning a "harvested fish" to each of these categories resulted in that fish being counted five times, thus overestimating the actual impact of harvest. Because the matrix analysis method relied upon a direct summation of impact scores (1, 2, or 3) to evaluate the relative importance of the factors, the ranking of the factors was directly dependent upon the number of matrix categories. The selection of these "biological population impact" categories was not supported by any information presented in the report. In addition, these categories did not accurately reflect the complex biology of anadromous salmonids. Using redundant impact categories and a summation method that is dependent upon the number of categories selected results in conclusions that are not scientifically valid. (4) The measure of a factors impact was not based on changes in population abundance The analysis method appears to be based on an assessment of the "increased mortality" that a factor can exert on a single life history stage of salmonids, and fails to base the 13 203 DRAFT estimate of the relative impact on the total production of salmonids. This method ignores compensatory survival mechanisms, widely recognized as being important to the population dynamics of most species. To estimate the biological impact of each factor on salmonid production, the matrix method would require a mechanism to sum impact levels while recognizing that increased mortality at one phase of the life cycle can be compensated by reduced mortality at a subsequent stage. The total impact of a given factor on the productivity of the population should be represented by the relative change in the production of adult salmonids. For example, reduced spawning escapement will result in a lower production of juveniles, but if freshwater habitat is not limited the survival of these juveniles to the smolt stage will be increased because of reduced density-dependent mortality (a compensatory mechanism). The net effect on the total production of adults will be less than the direct reduction in juvenile numbers due to this compensation in survival rates. (5) The method could not measure the effects of multiple factors The matrix methodology could not measure the cumulative impact of multiple factors affecting a population simultaneously. The analysis was limited to an evaluation of the effect of a single factor on one aspect of salmonid life history, and failed to include a method to recognize synergistic interactions of multiple factors on total stock productivity. For example, the effects of a 60 percent harvest rate on coho salmon populations will vary markedly if ocean survival rates (smolt to adult) the previous year change from 8 percent to 4 percent. In addition, a particular harvest rate that is acceptable for a population living in a pristine basin will be unacceptably high if egg to smolt survival rates are reduced because of freshwater habitat degradation. Ignoring these complex relationships results in over-simplified conclusions that are not likely to accurately predict the relative importance of the factors. ALTERNATIVE ANALYSIS APPROACH To demonstrate the complexity of quantifying and evaluating the effects of various factors on salmonid production in a scientifically valid manner, the Department has developed an example of an alternative matrix approach. This approach is based upon a prediction of the relative change in adult salmonid production due to a variety of factors, and is consistent with concepts currently being used in life cycle modeling to weight the effects of various mortality sources on salmonid production in the Columbia River Basin. A major difference between this approach and the OFIC report matrix is that the relative importance of a factor, or combination of factors, is based upon the predicted change in total adult production of a species. In this example, an array of biological impacts is evaluated by estimating changes in five population parameters: (1) adult spawners, (2) fecundity per adult, (3) egg survival, (4) juvenile survival, and (5) survival to adult. Each of these parameters could be ftirther partitioned: for example, juvenile survival could be subdivided into fry survival, summer survival, over-winter survival, etc. The potential causes of biological impact affecting these population parameters are numerous and include such sources as sedimentation, increased stream temperature, predation and harvest. In our example, these causes are generically referred to by a numerical designation (Table 1). Associated with each cause of biological impact is a list of factors or activities that contribute to the identified impact. These factors would include the environmental and 14 204 DRAFT management activities identified in the OFIC report, but this matrix recognizes that a specific cause of biological impact can be associated with more than one activity. The effect of each biological impact in the matrix is presented as the relative survival change (percent) in each life history parameter. For example, if siltation reduces egg survival by 45 % , the matrix entry would be -45 % . If a factor has a direct negative impact on one parameter that results in a related change in another parameter, it would be reflected in the matrix. For example, if a 45% reduction in egg survival results in a 10% increase in juvenile survival because of reduced juvenile rearing densities, matrix entries would be -45% for egg survival and -1-10% in juvenile survival. This approach allows the incorporation of compensatory survival relationships in the evaluation of the environmental and management factors. The final measure of the biological impact of each factor on salmonid production is the percent change in recruits to adult. With this approach, the evaluation is based on the change in total salmonid production that occurs because of the activity being evaluated. For a given factor, the recruits to adult (RTA) relationship is estimated under baseline and impacted conditions as: RTA = (adult spawners) x (eggs/adult) x (egg survival) x (juvenile survival) x (survival to adult). The percent change in RTA (PRTA) is then calculated as: PRTA = -100 X [1 - (RTA impacted / RTA baseline)]. The empirical data used to calculate the percent change in salmonid production (PRTA) is not presented in the matrix. The purpose of the matrix is to present the direction and magnitude of changes in population parameters and production. A supportive table for each matrix would present ^e associated empirical data. The column and row headings of this table would be the same as the corresponding matrix, however the entries would be the empirical measures, under baseline and impacted conditions, of adult spawners, fecundity per adult, egg survival, juvenile survival, survival to adult, and recruits to adult. The following table provides an illustration of the possible format of an alternative matrix using this methodology (Table 1). In the first column are the identified causes of biological impact and all of their various combinations (to examine cumulative effects). In the second column are the potential activities or sources that contribute to the identified impact. In columns 3-7 are the relative survival changes (percent) of the five population parameters. The final column reports the total relative change (percent) in salmonid production (recruits to adult) associated with the identified biological impact. To complete an accurate evaluation of the relative impacts of the various environmental and management factors, a separate matrix would have to be generated for each species and basin combination. 15 205 DRAFT Table 1. An example of an alternative matrix to evaluate the affects of various environmental and management activities on the survival of anadromous salmonids. This matrix follows the methodology discussed in the previous text. Species: Basin: X Y Biological Impacts (Percent Change) In: Population Parameters Production Cause of Impact Factor or Source Adult Spawners Fecundity per Adult Egg Survival Juvenile Survival Survival to Adult Recruits to Adult I 2 3 1+2 1+3 2+3 1+2+3 The previous matrix example only considers three sources of biological impact. The analysis will become increasingly complex as the number of impacts being evaluated increases. In addition, the ne^ to generate a separate matrix for each species and basin (or aggregation of similar basins) combination requires that a considerable amount of survival data be available for an accurate evaluation of the factors. Unfortunately, much of the necessary data is currently lacking for most species and basin combinations. CONCLUSIONS The Oregon Department of Fish and Wildlife has concluded that this report does not provide an adequate scientific analysis or justification to support the conclusions concerning the relative contribution of environmental and management factors to the decline of Oregon's anadromous salmonids. 16 206 DRAFT LITERATURE CITED Emmett, R.L., S.L. Stone, S.A. Hinton, and M.E. Monaco. 1991. Distribution and abundance of fishes and invertebrates in west coast estuaries, Volume II: species life history summaries. ELMR Rep. No. 8. NOAA/NOS Strategic Environmental Assessments Division, Rockville, MD, 329 p. Hartman, G.F., and J.C. Scrivener. 1990. Impacts of forestry practices on a coastal stream ecosystem. Carnation Creek, British Columbia. Can. Bull, of Fish, and Aquat. Sciences 223, Ottawa. Holtby, L.B. 1988. Effects of logging on stream temperaUires in Carnation Creek, British Columbia, and associated impacts on the coho salmon (Oncorhynchus kisutch). Can. J. Fish. Aquat. Sci., Vol 45: 502-514. Moring, J.R. 1975a. The Alsea watershed study: effects of logging on the aquatic resources of Uiree headwater streams of the Alsea River, Oregon, Part II - Changes in environmental conditions. Oregon Department of Fish and Wildlife, Fishery Research Report No. 9, Portland, OR. Moring, J.R. 1975b. The Alsea watershed study: effects of logging on the aquatic resources of Uiree headwater streams of the Alsea River, Oregon, Part III - Discussion and recommendations. Oregon Department of Fish and Wildlife, Fishery Research Report No. 9, Portland, OR. Moring, J.R., and R.L. Lantz. 1975. The Alsea watershed study: effects of logging on the aquatic resources of three headwater streams of the Alsea River, Oregon, Part I - Biological studies. Oregon Department of Fish and Wildlife, Fishery Research Report No. 9, Portland, OR. Nehlsen, W.,J.E. Williams, and J.A. Lichatowich. 1991. Pacific salmon at the crossroads: stocks at risk from California, Oregon, Idaho, and Washington. Fisheries, Vol. 16, No. 2. Morris L.A., H.W. Lorz, and S.V. Gregory. 1991. Forest chemicals. In: Influences of Forest and Rangeland Management on Salmonid Fishes and their Habitats, W.R. Meehan, editor. American Fisheries Society Publication 19: 207-296, Bethesda, MD. Oregon Department of Environmental Quality (ODEQ). 1988. 1988 Oregon Statewide Assessment of Nonpoint Sources of Water Pollution. Oregon Department of Environmental Quality, Water Quality Division, Portiand, OR. Oregon Department of Environmental Quality (ODEQ). 1990. Oregon 1990 Water Quality Status Assessment Report, 305b Report. Oregon Department of Environmental Quality, Portiand, OR. Sedell, J.R., andR.L. Beschta. 1991. Bringing back the "bio" in bioengineering. In: Fisheries Bioengineering Symposium, J. Colt and R.J. White, editors. American Fisheries Society Symposium 10: 160-175, Bethesda, MD. U.S. Department of Agriculture-Soil Conservation Service (USDA-SCS). 1978. Tillamook Bay drainage basin erosion and sediment study, Oregon. Main Report. Portland, OR. 17 207 DRAFT APPENDIX A Technical Review Comments Concerning Information Presented in the OFIC Sponsored Report. This appendix provides specific comments on the report compiled by Oregon Department of Fish and Wildlife (Department) staff. These comments provided the basis for the discussion presented in the ODFW review of this report. The appendix is organized in a manner consistent with the format of the OFIC report and, where possible, direct references to pages and tables of the report are specified. MANAGEMENT FACTORS Section 1.1 Harvest Page 5, 1.1.1. Fisheries Resources This section provides a general discussion of anadromous salmonid populations in Oregon. The following statements were inaccurate or misleading: "...all salmonid populations in Oregon are depressed (see Table 1.1-1),...' Table 1.1-1 only provides a list of Columbia River populations and does not reflect the status of '...all salmonid populations in Oregon... ' In reality, many Oregon salmonid populations are currently healthy, such as north coast fall chinook (primarily wild), upriver bright (Columbia River) fall chinook (primarily wild), Columbia River sockeye (all wild with very large runs in the 1980s), and upriver summer steelhead (Columbia River). '. . . Chum, pink, and sockeye salmon populations are so low that they occur in the fishery only as inciderual catches... " Pink salmon are not present in Oregon streams but are harvested in ocean fisheries: these fish are believed to be Puget Sound stocks. Occasional pink salmon are also harvested in the Columbia River, but these are believed to be strays from Washington or British Columbia streams. The average sockeye escapement is presently near the 75,000 fish goal, but recent runs were of such strength 1983-88 fisheries were allowed. Several recreational chum salmon fisheries exist on north coastal streams. A- 1 208 DRAFT 'I^nk salmon river migration runs occur only in odd-numbered years in Oregon. " Pink salmon are not native to Oregon, and are only rarely observed in Oregon streams. This species is found in oceanic and coastal areas north of about 40° N latitude, and its normal distributional range is from approximately Skagit Bay, Washington, northward (Emmett et al. 1991). Ocean harvests do occur in odd-numbered years off Oregon, but these catches are comprisal of fish from streams outside Oregon. Page 6, 1.1.3. Historical Catch Columbia River Commercial Fisheries (pages 6-7) In this section, the authors attempt to describe historic Columbia River commercial catches. This discussion contains a significant number of data errors concerning the volume of fishery landings in the early years, especially for sockeye salmon (Craig and Hacker 1940, Cleaver 1951, WDF and ODFW 1992). Decline of Run Size (pages 7-8) In this paragraph the authors attribute a reduced Columbia River run size of salmonids solely to fishery harvest. This is substantiated by the following quote: '...the commercial fishery described above has taken its toll on the run size of the Columbia River salmonid fishery. ' The basis of this conclusion is a comparison of salmonid run sizes prior to development activities on the Columbia River to current levels (13 million fish versus 1 million fish). This analysis does not recognize, nor does it mention, the effects of the development of the Columbia River Basin on these populations. This paragraph also contains mis-represented information: ". . .fi-om a low of about one million fish in 1983 (ODFW 1991) to a high of about 4.5 million in 1976 (Gunsolus, 1977). " The authors compare the estimated run size entering Columbia River in 1983 (1.0 million) to the total production of Columbia River fish (ocean catch plus run returning) in 1977. The apparent source of this information is a report by ODFW and WDF (1991), but this cannot be verified. Decline of Harvest (page 8) This paragraph attempts to show that the decline in harvest occurred prior to the development of the Columbia River Basin. In fact, harvest declined little from the 1870s to the 1930s. Major declines occurred since the 1950s when development A-2 i 209 DRAFT affected runs and fisheries were increasingly regulated (Cleaver 1951, WDF and ODFW 1992). Indian Fishery (page 9) In this paragraph, the authors attempt to compare NPPC estimates of tribal harvest in the early 1800s (5-6 million adult salmonids, annually) to harvests of the Celilo dip-net fishery in the 1940s and 1950s. The estimated landings for the 1940s and 1950s used as a comparison are under-estimated by 90-99%. The following examples highlight discrepancies in the data: 1956 Celilo Falls chinook harvest: Report estimate - 4,000 lbs. Actual landings - 635,000 lbs. (FCO and WDF 1971) 1941 Celilo Falls salmon and steelhead harvest: Report estimate - 295,000 lbs. Actual landings - 3,500,000 lbs. (FCO and WDF 1971) Columbia River Sport Fisheries (pages 8-9) These paragraphs accurately describe the fisheries, and appear to be paraphrases from ODFW's "Lower Columbia River and Buoy 10 Recreational Fisheries" annual report (Melcher and King 1991). It should be noted, however, that WDF and WDW are co- managers in Columbia River sport fisheries. ODFW does not complete all fishery monitoring as is implied in the third paragraph. Coastal River Basins Sport Fishery (pages 9-10) "In recent years, coho salmon escapement in most Oregon coastal rivers has offered only sparse opportunity for sport fishing. ' Coastal rivers offer excellent opportunities for sport angling, especially for fall chinook salmon. Coho angling opportunities are also good in several coastal systems, though anglers primarily target returning hatchery stocks due to higher success rates in these fisheries. The authors erroneously cite Nicholas and Hankin (1989) (actually Nicholas and Hankin 1988) in reporting that the harvest of adult chinook in many tidewater fisheries was several hundred fish annually from 1947 to 1960. Harvests in these fisheries were actually of the magnitude of several thousand fish. Coastal River Basins Commercial Fishery (page 10) These three paragraphs described commercial fisheries in Oregon's coastal rivers and estuaries that have been closed for 30 years or more. The chinook fisheries are described using Nicholas and Hankin (1988), erroneously cited in References. The description of the coho fishery is from ODFW's Coho Plan (ODFW, 1982). A-3 210 DRAFT The description of the steelhead fishery is from ODFW's Steelhead Plan (ODFW, 1986). The authors erred by stating that the Steelhead Plan estimated annual commercial landings in the 1920s to be 100,000-120,000 fish. The plan simply stated that using an average weight of 8-10 lbs divided into landings produces commercial catch estimates similar to those of the present sport catch. Ocean Troll Fishery (page 1 1) A short, inaccurate, and incomplete description of the Oregon troll fishery is given in two short paragraphs. The third (and last) paragraph paraphrases (incorrectly) only several of 19 summary paragraphs in Van Hyning (1973). Van Hyning (1973) provides a review of Columbia River fall chinook returns 30-60 years ago, and discusses reasons for their decline in the 1950s. The 1950s decline was attributable to increased ocean troll fisheries primarily in Canada. Van Hyning warned that "...the effect of the recent era of intensive river development was hardly covered in this analysis..." (ibid, p.77). Furthermore, Van Hyning emphasized that "...these conclusions cannot be extrapolated to the future and may not apply to other species, runs, or races of salmonids. " (ibid, p. 82). Analysis of Latter-Day Historical Catch (page 1 1) These four paragraphs paraphrase some of the conclusions in McKeman et. al. (1950) relative to Oregon coastal coho 1923-48. McKeman lists three causes of coho declines in those years: 1) logging, 2) water flows, and 3) intensity of fishing. The authors paraphrase many of McKeman's comments relative to fishing, but only briefly mention the other causes with the following statement: "...two other factors considered in the study, floods and logging, were found to be related to coho salmon abundance in Oregon. " The authors conclude this section by stating: "Thus, as in all the earlier fisheries, overfishing was found to be a major cause for the decline of all the commercial salmonid fisheries of Oregon between the 1920s and late 1940s. " The authors reviewed no other historic reports to base this conclusion. Page, 12, 1.1.4. Recent Catch These two introductory paragraphs offer no useful information in comparisons of recent catch data for both sport and commercial fisheries. For example, 1990 harvests are compared to 1989 and to the 1978-90 average. The conclusion of the authors is that sport catch has declined slightly and the commercial catch has declined sharply. In fact, both fisheries show a stable or increasing trend with only 1990 being down (ODFW Salmon and Steelhead Catch Data, 1977-90; ODFW and WDF, 1991; PFMC 1991). A-4 211 DRAFT Columbia River Fisheries rpage 13) The authors summarize Columbia River fisheries with a single paragraph comparing 1990 harvests to 1989 harvests. In this discussion, the authors have transposed two numbers for the 1989 catch (864,000 versus 846,000 actual). The next comparison is of 1990 harvests to the peak landings (several years between 1883 and 1928). Finally, they refer to their Table 1. 1-10 which states that all Columbia salmonids except fall Chinook are declining (please refer to the review of tables and figures later in this document). The discussion mentions closed seasons for summer chinook and sockeye but fails to acknowledge long-standing closed seasons for upriver spring chinook and lower river commercially-caught steelhead. Commercial Net Fishery (pages 13-14) These paragraphs review data contained in Tables 1.1-11, 1.1-12, and 1.1-13 (please refer to the review of tables and figures later in this document). The comparisons are mostly accurate but provide little useful information. The authors erred in the 1990 Chinook catch as "only 640,000 chinook salmon were landed..." If this were true it would be the largest landing since 1948. Only 64,000 chinook salmon were landed in 1990. The authors have also confused the number of gill-net licenses with the number of fishermen. They describe the number of gill-net licenses as increasing slightly and then use the exact same data to mean number of fishermen, stating a range and then deciding there is a decline. The authors compared the poor 1990 catch and effort (open fishing days and licenses) to the excellent 1986 catch and effort, noting there were only six more licenses in 1986, yet 4 less open days, and surmised: "Reduced run size appears to be the cause of the reduced commercial catch of 1990. " The 1986 Columbia River salmonid return was estimated at 3.2 million fish, the largest return since Bonneville Dam was completed in 1938. The 1990 return was the lowest since the early 1980's (ODFW and WDF 1991). Indian Net Fisherv (pages 14-15) These four paragraphs describe treaty Indian commercial landing trends from 1960 to present p^ catch years. This section accurately describes the demise of the tribal fishing grounds at Celilo Falls in 1957 ending tribal fishing that occurred for millennia but then goes on to compare their near zero catch in 1960 to the high catch level now Tribal fishers did not perfect the technique of set-netting in slack water pools until mid- 1960s. A-5 212 DRAFT River Sport Fishery fpage 15) This one paragraph introduces four tables of sport catch information. Please refer to the reviews of Tables 1.1-16 to 1.1-19 later in this document. Lower Columbia (pages 15-16) The first three paragraphs describe the sport catch in the main-stem lower Columbia for each race or species of s^monids. In most cases the catch has declined over time. However, the authors have ignored increased angling season closures in the last 20 years as a contributor to this trend. Seasons in the early 1970s were open year round while recent angling seasons have been restricted to only January to March and August to December for salmon, and year round closures for wild summer steelhead. The last paragraph describes a declining catch rate for lower Columbia sport anglers based on Table 1.1-17. A review of this table (discussion to follow) shows that the angler trip totals the authors used included sturgeon and shad anglers (fisheries that have grown immensely in recent years). Including non-salmonid anglers in this comparison providwl a greater than 50% under-estimate of salmonid catch rate. Thus the author's concluding statement is misleading: "These (declining catch rates) imply a reduction in run size'. Buov 10 (pages 16-17) These three paragraphs compare highs and lows in harvest during the 9 years of this fishery (Table 1. 1-19). This discussion does not acknowledge the effects of closed seasons, catch quotas, in-season closures, or concurrent adjacent ocean fisheries on these harvest statistics. Coastal River Sport Fishery (pages 17-18) This section provides comparisons of annual variation in sport catch figures, all from Table 1.1-21. These comparisons are especially meaningless since the data being compared is from only a 13-year period (1978-90). Ocean Troll Fishery (page 18) This section provides comparisons of troll catch statistics contained in Table 1.1-22. The discussion does not acknowledge the effect of harvest quotas or seasonal regulation on the fishery catch or effort trends. A-6 213 DRAFT Ocean Sport Fishery (page 19) This section provides a comparison of ocean sport catch statistics from Table 1.1-23. Again, no discussion is provided concerning the effects of harvest quotas or seasonal regulations on the fishery catch or effort trends. Summary (pages 19-20) A summary of the annual catch variations described for the eight fisheries is presented on pages 13-19. The theme of the summary is that Oregon's salmonid fisheries have declined in recent years. This assessment combined with the escapement record, '...which will be presented latter (sic) in the report... ', indicates to the authors: *. ..that Oregon 's salmonid stocks are not presently in good biological condition. ' The discussion within this section of the report never mentions that annual management actions directiy affect catch magnitudes. If management had allowed unrestricted fishing and catches were high relative to prior years, would these increasing catches indicate Oregon's salmonid stocks were in good biological condition? Page 20, 1.1.5. Regional Catch This section describes declines in Pacific Coast fisheries based on Figures 1 . 1-1 1 to 1.1-13, data that were not verified as the source is not listed in the References. Based on these data, the authors attribute the supposed recent declines to environmental factors in the ocean. The remainder of this section is a discussion of Poon and Garcia (1982), a report for a utilities consortium about the effect of fishing pressure, hydropower development, and irrigation withdrawal on Chinook salmon. It is unclear how this report is relevant to a section on regional catch. Page 22, 1.1.6. Indirect Effects of Harvest Shaker Mortality (pages 22-23) The authors present two different types of fishing mortality and they erroneously attribute both types to "shaker mortality." The authors also incorrectiy apply shaker mortality estimates to total salmonid landings. A review of these issues follows: 'Shaker loss in ocean fisheries was extensively reviewed by Ricker (1976) who concluded that one additional fish is killed for every two legal fish landed and reported... ' (emphasis added) 'Boydston (1972) estimated the shaker mortality... to be 43 percent of the reported chinook catch. ' (emphasis added) A-7 214 DRAFT "TTie U.S. Fish and Wildlife Service (1983) uses a shaker mortality rate for Klamath River fall chinook...of 40 percent of the reported catch. ' (emphasis added) The estimates from these studies actually refer to the proportion of sublegal fish that are killed for every legal fish landed and reported. These estimates are nol mortality rates for fish that are encountered, caught and released (i.e. shakers). 'Recent studies of the ocean troll fishery in Alaska (Wertheimer, 1988) estimated a hooking mortality rate of about 25 percent for chinook salmon. ' "PFMC assumes a shaker mortality of 30 percent from the use of barbed hooks and 26 percent for barbless hooks. " These estimates refer to hooking mortality rates for fish that are encountered and released, and are appropriate measures of shaker mortality. However, the authors failed to specify to which species the PFMC estimates referred. It is important to note that these estimates will vary by species, fishery location, gear type (as is apparent in the PFMC estimates), etc.. "The values presented above suggest that shaker mortality is between 25 to 50 percent of the ocean catch. " "From the PFMC and USFWS data collected from Oregon and northern California, an annual shaker morality (sic) value of between 30 and 40 percent seems appropriate for Oregon. " The authors erroneously combine estimates of the proportion of sublegal fish that die for every reported fish landed with estimates of fish that die after being encountered and released (shaker mortality) to derive a range of "shaker loss" estimates. These different types of fishery mortalities are not synonymous, and cannot be combined into a single range estimate. The authors also combine mortality estimates for different species into one generic estimate. The mortality rates can vary substantially for different species and sizes of fish. It would have been more appropriate to present species-specific shaker mortality estimates over a number of years to more accurately portray the range of possible estimates. The Pacific Salmon Commission reviewed all available literature on hooking mortality for commercial troll chinook fisheries and concluded that a reasonable estimate of this mortality was from 20 to 30 percent (PSC, 1987). These estimates correspond with tiie study by Wertheimer (1988) and are substantially less than the range estimate presented by the autiiors. The 30 to 40 percent estimate by the authors does not seem "appropriate". A-8 215 DRAFT "Applying a shaker mortality of this value [30 to 40 percent] to the 582,000 salmon landed in Oregon during the 1990 ocean commercial troll and recreational fisheries adds an additional mortality of 174,400 to 232,500 fish to the 1990 ocean population (Table 1. 1-24). " This analysis is erroneous. Shaker mortality estimates apply to the loss of fish that are encountered and released in a fishery, and cannot be applied to estimate the fish lost as a proportion of the total landings. Shaker mortality estimates are only applied to the number of fish encountered and released. They cannot be estimated without first estimating the number of sublegal fish or non-target species encountered by a fishery. For the author's estimates to be accurate {174,400 to 232,500), the fisheries would have needed to encounter and release 582,000 salmon (assuming that 30 to 40 percent shaker mortalities are accurate). Applying estimates of shaker mortality to total fish landings greatly over-estimates the loss of salmonids. For example, if a troll fishery harvestwl 100,000 legal fish in a season and encountered and released an additional 50,000 fish, applying a 30 percent shaker mortality rate to the total landings would estimate a loss of 30,000 additional fish. In actuality, the loss would be 15,000 fish (30 percent of 50,000). In the previous example of PFMC shaker mortality estimates (30 to 26 percent, by gear type), the hooking loss estimates are applied to estimates of the number of fish encountered and released by the fishery, not to the total landings. The authors erroneously apply a generic range of mortality estimates derived from commercial troll fisheries to the estimate of total 1990 landings that includes harvest by recreational anglers. Commercial and recreational ocean salmon fisheries differ greatly in fishing methods and gear. It is inaccurate to apply mortality estimates from commercial fisheries to recreational salmon landings. To correctly estimate the incidental loss of salmonids during ocean fisheries, the authors should ensure that: (1) the appropriate type of fishing mortality estimate is being used, (2) fishery data is stratified by angler-type (commercial versus recreational), (3) estimates are stratified by gear-types (barbed versus barbless hooks, etc.)^4) mortality estimates are stratified by species, and (5) other factors such as fishery location, time of the year, encounter rates for non-target species and sublegal fish, etc. are considered. Dropout Mortality (page 23) '. . . it seems reasonable to assume an annual dropout mortality rate of between 4 and 8 percent for the Columbia River commercial net fishery. " The authors estimate these dropout mortality losses based upon information from the Klamath River tribal fishery, and the Puget Sound gill-net fishery. There have been no studies of gillnet dropout in the Columbia River to substantiate these estimates. Gillnet dropout is believed by ODFW to be low in the Columbia River fishery, and the mortality rate varies considerably by fish species, gillnet type, and by time of the year. The authors do not account for this variability, and do not state whether the fisheries evaluated for the dropout mortality estimates were conducted with similar gear, under similar environmental conditions, or targeted similar sizes and species of salmonids. A-9 216 DRAFT In-River Sport Fish Mortality fpaee 23) "The data presented suggest that it would be reasonable to assume a minimum loss rate of between three and nine percent for the inriver fisheries of Oregon. ' The authors base these loss estimates on steelhead studies in British Columbia, and note that ODFW applies these estimates to Oregon's catch and release program for wild winter steelhead. The ODFW believes that hooking mortality is approximately 3 percent when barbless hooks are used (a requirement for all Oregon catch and release streams). Approximately half of Oregon's steelhead streams are now regulated as catch and release fisheries. The authors fail to note that this mortality (3 percent) would only apply to fish that are released, which is currently estimated as about 25 percent of the steelhead catch. The major problem with this discussion is the authors application of these hooking mortality losses to the total 1990 Oregon inriver harvest of salmonids. This analysis fails to recognize that the majority of these fisheries are not regulated as catch and release, and that a majority of the fish landed are retained. It is erroneous to apply catch and release hooking mortality estimates to fisheries that are not regulated in this manner, and where fish are not regularly released. The estimates provided in this report are likely to be significantly greater than the actual hooking mortality loss. Page 24, 1.1.7. Out-of-state Harvest This section attempts to describe oceanic migration patterns of Oregon salmonids, and the interception of these fish by out-of-state marine fisheries. The section is technically weak and most of the conclusions are erroneous. ^"Few, if any, Oregon-produced summer chinook and spring chinook salmon from the Columbia are caught in out-of-state fisheries. " This statement is false. Oregon has no Columbia River summer chinook. Spring chinook are caught in Canadian and Southeast Alaska fisheries (35 % of Willamette spring Chinook from 1980-90 were caught in these northern fisheries). In discussing Vreeland (1989) the authors mix relative fishery contribution of "four brood years" with total harvest over a "four-year period." Tliis analysis is not scientifically valid as presented. Furthermore, they err when they claim that the entire Columbia River catch of hatchery fall chinook (21.9% of total) is made by citizens of Oregon. About half of the Columbia catch is by Washington citizens. "Thus, 73.4 percent or 749,000 of these Oregon produced fish were lost to harvests outside the state. ' Columbia hatchery fall chinook (tules) are produced in seven Washington, three federal, and only three Oregon hatcheries. Most of these hatcheries are federally funded. The Canadian catch of these fish is supported by the U.S. Section to the Pacific Salmon Commission. A- 10 217 DRAFT 'No data are available on the contribution and distribution of wild fall Chinook salmon from the Columbia River. But it probably is similar to that observed for these hatchery fish. ' This statement is erroneous. Columbia River wild fall chinook (lower river wild and upriver brights) are far more northern in their oceanic range and there is considerable data available from coded-wire tagged fish. For example, ODFW's salmon manager, Dr. Donald O. Mclsaac, has studied Lewis River fall chinook and published the results (Mclsaac 1990). The authors claim '...no specific catch data were found" regarding the contribution of coastal chinook and coho to out-of-state fisheries. Considerable information is available especially in Pacific Salmon Commission documents. Page 24, 1.1.8. Mixed Fisheries Issues This section is a discussion of mixed stock fishery issues. The entire theme is that mixed stock fishing will cause less abundant stocks to decline and ". . .possibly become extinct. ' The authors use several examples: 'It is easy to understand how declining stocks like summer chinook salmon or Snake River sockeye salmon can be depleted in an ocean mixed fishery. ..." Summer chinook inriver fisheries have been closed for nearly 30 years, the ocean harvest on these fish is light, yet these fish continue to decline in the absence of harvest. Also, Snake River sockeye have been nearly completely protected since the Snake River dams were completed in the 1970s yet these stocks declined to near zero returns. The Department objects to the suggestion that harvest caused the decline of these Snake River fish. The authors provide another conclusion based upon only a partial analysis of the reason for stock declines. The authors portray harvest rates on Columbia River hatchery coho (average of 88%) as being excessive (as compared to the OCN MSY rate of 69%) and conclude with the statement that this "...harvest rate should be closer to zero if the population [lower Columbia wild coho] is to survive. " This simple conclusion provides no mention of the potential affects of reduced stock productivity on these declines due to human-caused habitat changes. The weakness of this analysis is evident in the discussions of lower Columbia coho, Snake River summer chinook and Snake River sockeye. A-11 218 DRAFT 'Thus, this mixed fishery has significantly contributed to the decline of wild coho salmon in Oregon. ' The authors conclude the discussion of Columbia River coho salmon harvest with this statement applied to all coho populations in Oregon. An analysis of the effects of mixed-stock fishery harvest on Columbia River hatchery populations is not an applicable information base to make conclusions on the decline of all coho populations. These hatchery stocks are managed for a much higher harvest rate than are coastal wild populations. Ocean fisheries are managed with the intent of targeting on Columbia River hatchery coho stocks while attempting to minimize the interception of wild coastal stocks. In addition, Columbia River coho are intercepted in the ocean fisheries, in the intensive Buoy 10 recreational fishery, and in an inriver gill-net fishery. Coastal stocks are generally only exposed to the ocean fishery, with minor harvest during inriver sport fisheries. A conclusion which fails to recognize that these coho salmon stocks are managed with different objectives is false. Page 26, 1.1.9. Terminal Fisheries Similar to the previous section, the authors provide a discussion of terminal fisheries that portrays these fisheries as being "...the opposite of mixed fisheries. ' Several examples are offered as proof that terminal fishing is better than ocean fishing including statements that ocean fisheries catch immature chinook, and that "...the incidental morality (sic) rate of gill net fishing was four to eight percent compared with the 30 to 40 percent of trolling. " The immature chinook discussion is attributed to Nicholas and Hankin (1988), wrongly listed in the references section. The incidental mortality rates are not substantiated by the authors (please refer to our previous discussion and the review of Table 1.1-24 concerning errors in these estimates). In proposing that terminal fisheries be instituted as a better management tool for anadromous salmonid harvest, the authors should include a discussion of existing Oregon statutes (e.g. ORS 509.216) that prohibit certain terminal commercial fisheries from most Oregon waters. Section 1.2 Fish Resource Agency Policies and Goals Page 28, 1.2.2. Spawning Escapement Columbia River Stocks (pages 28-29) The reference for the status of the 754 populations was missing from the references section and, therefore, could not be verified. The Department believes that the information nu.y be false. A-12 219 DRAFT The following statements were found to be inaccurate or misleading: Coastal River Stocks (pages 29-30) 'A similar evaluation of escapement data for the coastal river basins collected between 1968 and 1984 (NPPC. unpublished) showed that of 1 73 populations, ..." It is not clear to which populations this paragraph and subsequent paragraphs refer. The data are not presented in the report and are referenced as unpublished. Summary (pages 30-31) "Similar decreases in escapement observed between coastal hatchery populations and wild populations could be explained by Nickelson's (1986) findings that coastal hatchery coho salmon had low ocean survival when hatchery smolt numbers were high. . . . The success of hatchery fish in the Columbia River Basin appears to contradict Nickelson's (1986) findings for coastal hatchery stocks that showed poor ocean survival when released in large numbers. ' The paper by Nickelson (1986) is misrepresented. This paper did not find a relationship between decreased survival of coastal hatchery coho salmon and numbers released. In fact, just the opposite, the paper concluded that survival of hatchery coho was unrelated to numbers of smolts released. The paper also didn't separate out coastal hatchery stocks (except those released from private hatcheries). ". ..annual number of coastal hatchery smolt releases has recently been relatively low, 15 million to 20 million. . .smolt releases had been much higher in the late 1970s and early 1980s when they exceeded 60 million fish annually for coho salmon alone (Nickelson 1986). " The smolt release values are inaccurate. They are too high to be coastal hatchery releases. The hatchery coho salmon smolt release numbers presented in Nickelson (1986) were for all public hatcheries contributing to the Oregon Production Index area (Columbia River and Oregon coastal combined) and for private hatcheries. The total of these two groups never exceeded 60 million in any one year, as claimed. Page 32, 1.2.3. Escapement Goals Coastal River Goals (page 33) 'Annual estimates of coastal coho salmon spawning escapement are derived in aggregate for the stock through spawning ground index surveys of three coastal lake basins (Cooney and Jacobs, 1990). " A-13 220 DRAFT This statement is incorrect. Estimates of coho salmon spawning abundance are derived from index surveys in 14 basins plus 3 lake basins, not just the 3 lake basins as indicated in this paragraph. Page 34, 1.2.4. Spawning Escapement and Return to Rivers Columbia River Goals (page 34^ This section includes erroneous information. The McNary Dam fall Chinook escapement goal for 1991 was 45,000. The escapement range of 30-45,000 is an oversimplified description of the Willamette spring Chinook escapement goal over Willamette Falls, not into the Willamette River. Coastal Rivers rpapes 35-36) The following statements were found to be inaccurate or misleading: 'Spawning escapemeru of Oregon coastal coho salmon in 1990 was only 69,000 fish, just 43% of the goal... " The actual coho salmon escapement estimate for 1990 is 104,200 (not 69,000 which was listed as preliminary by PFMC (1991) and should have been foot-noted as such). The 1990 escapement was 65% of the goal, not 43%. (Source: ODFW OCN database, Rod Kaiser, Ocean Salmon Management, Newport, OR). "...in each year that the escapemeru goal for coastal coho salmon was not met. catch rmmbers exceeded the escapemeru goal number by a factor of from two to five. . . " This statement is misleading because the catch referred to was comprised primarily of hatchery fish from the Columbia River. The comparison of this catch estimate with escapement of wild fish to coastal streams is irrelevant. A relevant comparison would be the ocean and coastal tributary catch of OCN compared to OCN escapement. Ratios of catch to escapement for OCN coho salmon since 1980 range from 0.4: 1 to 3.5: 1 and have averaged 1.4:1, or an average harvest rate of 58%. A- 14 221 DRAFT 'In the past, the number of spawners from the three coastal lake basins was expanded to determine escapement for the entire Oregon coast. It now appears probable that there was an overexpansion of spawning densities from the index surveys. This over expansion of spawning densities led to treated estimates of spawners, stock recruitment, and escapemeru goals, and is believed responsible for underescapement and overharvesting of coastal coho salmon. PFMC is preseruly revising the method to estimate future spawning escapement for coho salmon... " This paragraph is a total misrepresentation of the methods of estimating coho spawning escapement, the conclusions of PFMC (1992), and the work ODFW (not PFMC) is doing to investigate the current methods to estimate spawners. Specifically: 1. Estimates of coho salmon spawning abundance are derived from index surveys in 14 basins plus 3 lake basins, not just the 3 lake basins as stated in this paragraph. 2. Preliminary data indicate that in years of very low escapement, estimates of spawner abundance derived from the standard index streams are higher than estimates derived from random surveys. Research into better methods to estimate spawning escapement were initiated and are being conducted by ODFW, not PFMC, as part of a continuing process to improve coho salmon escapement estimates that began in 1980 [see Beidler and Nickelson (1980) and Solazzi (1984)] 3. If estimates of spawner abundance were inflated, they would result in inflated stock recruitment and escapement goals, but would not result in underescapement and overharvest because the relationship between catch and escapement would remain the same (since catch is estimated directly from escapement) and the MSY harvest rate would remain the same. The net result would simply be that we would have fewer fish (both catch and escapement) than we originally thought. Columbia River (pages 36-37) The goals listed for spring chinook are not wild fish goals, but rather an aggregation of wild and hatchery fish. The lower river fall Chinook goal is not 17,000 adults. The only Lower Columbia wild goal recognized is 5,700 for the North Lewis River. This goal has been exceeded in every year of record. Data in Table 1.2-11 does describe wild fish, even though the text does not make this distinction. 'In 1990, spawning escapemeru goals were met for only three of eight populations of wild anadromous salmonids in Oregon. " This statement is incorrect for the following reasons: A-15 222 DRAFT 1. Three of the eight salmon populations analyzed are not wild populations based on the data used (Columbia River spring, summer, and Upper River fall Chinook). 2. Two of the populations are not Oregon populations: Columbia River sockeye spawn in Washington; Snake River sockeye are from Idaho. 3. Only one of the eight populations analyzed, OCN coho, correctly fits the claim of a wild population not attaining the escapement goal. Page 38, 1.2.5. Production Harvest Policies Management Agencies (pages 38-39) "Harvest of Columbia River salmonids is managed by ODFW under the Columbia River Management Plan. " The Columbia River Compact manages commercial fisheries in the Columbia River. Oregon has one vote in this Compact. "State regulation within territorial waters (0-3 miles offshore) are not required :o follow PFMC regulations. " This statement is incorrect. The State of Oregon has twice been preempted by the Department of Commerce for opening fisheries within state marine waters that were inconsistent with PFMC regulations for waters 3-200 miles offshore. 'The Columbia River Management Plan is a litigation settlement... " The citations for this statement (ODFW, 1987, 1988) are incorrect. The proper citation is the U.S. District Court legal description. Harvest Policy (page 39) It is unknown how the authors determined that the harvest policy cited is the ODFW 'harvest management policy". ODFW has no documented harvest policy with this degree of specificity. Chinook Salmon (pages 39-40) The harvest rate data on which the authors conclusions are based are false. Also, ocean harvest rates for Columbia River chinook are wrong, therefore, the total harvest rates are wrong. The largest error is for 1987-89 Upriver fall Chinook. The 1961-69 ocean A-16 223 DRAFT harvest rates for coho seem substantially high as well. Therefore, concluding statements about the effect of harvest rates on populations are also false. Coho Salmon (pages 40-41) 'The Columbia River coho salmon run. which has about five percent wild fish, is managed for the maximum production of the hatchery component (Crammer (sic) et al. , 1991). " The Columbia River Compact considered Clackamas River wild coho in management decisions to regulate the commercial gill-net fishery in 1991. Page 42, 1.2.6. Present Wild Fish Management Policy A paragraph is presented on each of the major sections of the policy that were approved in 1990, with the exception of the section on habitat. Statements to the effect that ODFW "shall oppose habitat degradation that causes a population to experience a decline in abundance. . . " [OAR 635-07-527 (2)] have been left out of the discussion. In addition, the 1990 version of the policy was updated and expanded in 1992. Section 1.3 Hatcher Page 47, 1.3.2. Hatchery Culture Practices Since 1977, ODFW researchers have developed an extensive data base of survival and hatchery practices that guide hatchery programs. The authors make no mention of studies published by ODFW scientists on these subjects [for example: Johnson et al. 1990 and Solazzi et al. (1991)]. 'Current hatchery practices commonly maintain fish in an unnatural, stressful environment. " This statement implies that most hatchery fish are raised in a stressful environment. This is not true. In some isolated instances fish may be stressed for short periods of time due to crowding or low water flows and consequently low dissolved oxygen levels, but this is not the common rearing practice at our present hatcheries. The Department generally restricts the loading levels in rearing ponds and routinely monitors dissolved oxygen levels in the outfall of hatchery rearing ponds. A-17 224 DRAFT 'Hatchery conditions may result in predisposing factors that enhance the susceptibility of juvenile hatchery salmonids to stress and subsequently increased rates of infectious diseases " (emphasis added) In isolated instances this statement is true, they may, but the statement gives the impression it is standard hatchery practice: this is not true. "The ODFW's ability to recommend time, size, and location of hatchery fish releases has been hindered by an inadequate data base and inconsistent results from past studies, attributed to poor experimental design or disease problems. ' The Department is presently building a data base that assists in determining the best times and sizes for release. True, disease is a problem in some cases. The major factor contributing to the variability of the data is variation in environmental factors occurring in both fresh water and marine areas over which man has no control. Hatchery factors over which the Department has control contribute to a very small part of the variability in the results from year to year in fish survival. Page 48, 1.3.3. Genetic Risk The word "may" is used four times in this section in quotes and only serves to provide a possibility of some action occurring, but provides little conclusive evidence to the discussion. Page 48, 1.3.4. Transfers This paragraph discusses primarily past practices with little emphasis on the present. Page 48, 1.3.5. Outplanting "...this practice is extensive and has persisted for decades. " This statement may be true for trout stocking programs, but it is certainly not true for most anadromous salmonids. Outplanting has been greatly reduced in recent years except for fish transported to acclimation sites such as coho to net pens in Youngs Bay or steelhead to acclimation sites in N.E. Oregon. A- 18 225 DRAFT 'Coho salmon outplanted into the lower Columbia River are the progeny of numerous previous stock transfers over multiple generations and may carry the genetic material of a broad spectrum of ancestral stocks, often from different watersheds: some were not even of Columbia River origin. ' Present ODFW lower Columbia River hatchery coho stocks were all derived from the Early Toutle coho stock. This group of fish is regarded as a single unit. No attempts are made to utilize native coho brood stocks from these hatchery streams as very few, if any, native coho presently exist in these areas. In the late 1970' s, there were some small experimental groups of tagged Late Cowlitz coho released in Scoggins Creek, a tributary of the Willamette system. These releases were not successful and the practice was discontinued. Small experimental crosses of 1979 brood coho at Big Creek included stocks from the Smith and Soleduck Rivers. These experimental groups were less than 10,000 fish per tagged group. The adults returning from these experimental releases were destroyed and the experiments discontinued. Present hatchery practice is to utilize native broodstocks for development of hatchery releases for ODFW hatchery production. Stocks may be collected from a separate watershed, reared in a hatchery and then returned to the parent stream for release. Outplanting of coho presmolts was extensively conducted due to legislative directive in the 1980's. The practice was evaluated as unsuccessful and potentially harmful to the native wild spawning populations so the practice was discontinued. The following passages are inaccurate: 'Cramer et al. (1991), report that outplanting and subsequent spawner abundance on 15 test and 15 control streams on the Oregon coast were monitored for three years. " The study referred to was conducted over a period of 6 years (not 3 years) and was published by Nickelson et al. (1986), not Cramer et al. (1991). "A major component of the ODFW coho restoration program, however, is the supplementation of wild coho in coastal streams with hatchery presmolts. . . " The "Coho Restoration Program" did use hatchery presmolts to supplement wild coho. However, this program took place in 1980-82 and was terminated as a result of the evaluation conducted by the Research Section of ODFW and reported by Nickelson et al. (1986). Page 50, 1.3.7. Diseases 'Hatchery fish act, during this low level of infection, as reservoirs of pathogens that are released into the streams. ' A-19 226 DRAFT Wild fish that are allowed to move above hatcheries also act as reservoirs of infection to fish reared in hatcheries. "...hatchery reliance on antibiotics may result in mutant strains of pathogens. ..antibiotics may not eliminate infections in hatchery fish, but merely maintain mortalities in the hatchery at an acceptable level. " Again, the authors report possible problems as events which "may" occur without any substantiating evidence. Page 51, 1.3.8. Hatchery Production for Harvest There appears to be two different opinions in the fishery community as to the purpose for hatchery fish production. One opinion considers that hatchery fish should only be used to maintain native wild populations of anadromous salmonids and that fish production should be dependent entirely on wild fish. The other opinion considers hatchery production for supplementation of fish to supply both sport and commercial fisheries that could not exist if they had to depend solely upon natural fish production. Both goals are correct for some streams but neither is appropriate in all situations. Each is a management tool to be used in a specific instance to accomplish a specific management goal. ENVIRONMENTAL FACTORS Section 2.1 Water Use Page 56, 2.1.3. Upstream Passage - Gross Habitat Area Losses "Estimates of Columbia Basin salmon and steelhead spawners based on habitat availability before 1850 are 6.2 million salmon and 8.3 million steelhead (NPPC, 1986).... At a 2:1 catch to escapement ratio, this is an annual loss of 6.8 million salmon and 9.2 million steelhead to fisheries on a sustained basis. " The total Columbia Basin losses cited from NPPC 1986 appears to be incorrect: the authors cite a loss of 7.9 million salmon and steelhead. The loss of salmon and steelhead estimated by NPPC above Bonneville is between 8 and 16 million fish annually (NPPC 1987). The authors also incorrectly apply a catch/escapement ratio to the NPPC data in order to estimate losses to fisheries. However, the NPPC data is a total production estimate that includes harvest. A-20 227 DRAFT 'Total stream miles are another way to evaluate gross area losses. . . . These figures include tributaries and yield a more conservative one-third stream mile loss estimate for the Columbia Basin. " Estimates of miles of stream lost in the Columbia Basin are more realistic, not conservative, estimates of habitat loss than estimates based on square miles. This should be obvious: there are many square miles of desert in Southeast Oregon with very few miles of stream. Also, White Salmon River is in Washington, not Oregon. 'Gailsville [sic] Reservoir (upper Cow Creek. Umpqua River) blocks approximately 15 miles ofanadromous salmonid habitat (Lumas [sic], 1992). " Both "Loomis" (an ODFW district biologist) and "Galesville" are misspelled. Furthermore, a retired PacifiCorp employee, J. Haenel, is also cited in this paragraph twice. This citation is then spelled differently in the list of references, as "Hanel". Which is the correct spelling? This section also makes reference to reports by "PNRBC" and "USAED", which are listed in the References section but not spelled out. These references should be spelled out in the Reference section because they are not universally understood in the fisheries community. "Gross anadromous salmonid habitat losses in Oregon due to water developmem projects are about one-third of the historical native anadromous habitat. ..' The authors conclude this section with a statement that fails to acknowledge that these habitat losses are not distributed evenly across all regions of the state. This statement does not specify that the importance of habitat blockages to the decline of salmonid populations is relatively minor in coastal tributaries, and that an evaluation of the relative importance of this factor should be regionalized to recognize this fact. I^ge 57, 2.1.2 Upstream Passage Effectiveness "Fish passage problems at Oregon City Falls, . . . were recognized in the 1970s (PNRC, 1976). The source of this information is not listed in the reference section, unless possibly both the organization's abbreviation and the year of publication are listed incorrectly. A-21 228 DRAFT "Mainstem Columbia and Snake River dams had significant upstream passage problems as well. Gibson et al., (1979), estimated a 20 percent adult mortality rate associated with passage at John Day Dam, and Weiss (1970) estimated 13 percent associated mortality at Bonneville Dam and 12-25 percent at The Dalles Dam. Similar adult mortality (loss) rates may apply at older fish passage facilities elsewhere in Oregon.... "The design and engineering of passage facilities have evolved as successes and failures brought more understanding about sensitive interactions between biological and engineered systems ' (Rainey, 1991). " The report implies that the adult losses at Bonneville, the Dalles, and John Day dams can be attributed to outdated fish ladder designs - this is not true. The high mortalities at these dams during the 1960s and 1970s were due to high flow and forced spill prior to Columbia River Treaty storage. The cited studies (Gibson et al. 1979 and Weiss 1970) showed that adult losses were highest during high spill years due to fallback and delay. In this paragraph, both Gibson and Weiss are cited but are not included in the References section. At the end of this paragraph, "Rainey, 1991" is quoted but is also missing from the References section. The second paragraph of page 58 incorrectly describes the 1991 Fish Passage Center (FPC) Annual Report (FPC 1991). The following statements were inaccurately reported: "Loss of adult fish was higher than normal in 1990 based on individual dam counts..." The Fish Passage Center report does not state that "higher than normal losses of adults" occurred. Rather, FPC (1991) reported that "fallback of adults probably occurred at some projects during periods of high spill", and that warmer than normal water temperatures July through September "likely caused additional mortalities". The FPC report states these results as probable occurrences, nQl mortalities that occurred or were measured in 1990. "High spill levels (to benefit downstream passage of smolts) from May through mid-June. . . * The high spill levels occurred because of overgeneration (exceedance of powerhouse capacity) from high natural runoff, not because of flow augmentation to benefit fish. "Passage efficiency was very low in the Sruike complex of dams in 1990 compared to 1989 (FPC, 1991). " This statement is not supported by the reference to FPC (1991). The FPC report does not state that passage efficiency was low in the Snake complex in 1990 compared, to 1989. A-22 229 DRAFT The Fish Passage Center report mentions that the loss of fish between the [Snake complex] projects this season "was higher than normal, based on counts at individual dams." However, it is misleading to rely upon dam counts to assess fish losses due to errors associated with dam counts^ fallback, tributary entrance ("tum-ofP), harvest, and mainstem spawning. Page 59, 2.1.5. Downstream Juvenile Passage - General 'In 1990, ODFW identified some 56,000 surface water diversions that potentially impact fish populations in Oregon. ..Less than 1000 (two percent) are presently screened. . . ODFW ranked the remaining 55,000 thousand (sic) unscreened diversions (98 percent) and determined that 3,240 water diversions were significantly impacting fish populations (primarily anadromous salmonids) ... Frankly, we were surprised by the magnitude of unscreened diversions in Oregon (5 5, (XX)) ... The priority need for some 3, 240 fish screens out of a total 55,000 unscreened diversions is a disturbing statistic". The authors statements and conclusions regarding the magnitude of screening needs are misleading. Information cited out of context from Nichols (1990) implies that 55,0(X) water diversions exist in Oregon that need to be screened. In fact, the cited report clearly states that only 3,240 water diversions, representing less than six per cent of all diversions in the state, require fish screening. The remaining diversions are not located where gamefish or nongame threatened or endangered fish species exist. The authors also state that the majority of the 3,240 water diversions needing screens impact anadromous salmonids. However, the cited report (Nichols 1990) provided no information on species composition from which this conclusion could be substantiated. In fact, a significant percentage of the 3,240 total water diversions identified in the report as n^ing screens impact non-anadromous salmonids and/or non-game T&E species. 'Total anadromous fish losses fi-om unscreened diversions are very large but presently are not estimated. A rough preliminary calculation indicates that losses over the years must be in the billions '. (emphasis added) The authors state that anadromous fish losses from unscreened diversions are very large but are not estimated. They then reference a calculation that is not identified, explained, or qualified in any way which indicates the loss over the years to be in the billions. This estimate is speculation that is not substantiated. A-23 230 DRAFT "Since 1964. . . and through 1990 a total of 525, 000 steelhead smolts were saved [referencing live box catches on 29 fish screen bypasses in the John Day system]. If the 300 total screens divert fish at a similar rate to the 29 sampled screens, this would equate to over 5.5 million steelhead smolts saved by the fish screens operated on the John Day River". The logic used to estimate 5.5 million steelhead smolts saved by screening ([300/29] • 535,000 = 5,534,482) has a significant problem. The authors assume that any given fish is caught only once in any of the 29 traps, when in fact, any given fish could be trapped many times as it moves downstream past more and more diversions. If each fish was caught twice, their 5.5 million fish estimate would be cut in half. If each fish was caught five times, the estimate would be reduced by 80% to approximately one million fish. "Oregon has relatively strict and straightforward regulations on fish screen protection (ORS 498. 248 and ORS 509. 615). These statutes require that water diverters provide and maintain screens. . . at owner expense... the solution does not appear to require additional regulation, but rather enforcement. Funding for enforcement. . . appears to be the major problem' . The authors are unaware of substantial statutory changes that occurred in the fish screening laws nearly two years ago. The statutory provisions they cite were debated during the 1991 Oregon Legislative Session and were significantly amended effective July I, 1991. House Bill 3457 created a new cost-sharing program for fish screening which includes an implementation schedule for 3100 of the 3240 water diversions identified for screening. The new law specifically prohibits the Department from requiring water diverters to screen their diversions unless it is under the provisions of the new program. Page 60, 2.1.6. Effectiveness of Fish Screens "ODFW approach velocity criteria are 0.5 _^s for fry and l.OJpsfor fingerlings (Pearce and Lee, 1991). " The velocity criteria cited by the authors (from a document that is not listed in the references) is outdated and is not currently being applied by ODFW. For the past several years, ODFW has been using approach velocity criteria of 0.4 fps for fry and 0.8 fps for fingerlings. Page 61, 2.1.7. Downstream Juvenile Passage - Mainstem Columbia-Snake Projects "Maximum hydraulic generating efficiency for vertical axis Kaplan turbines at most Columbia-Snake projects is 90-92 percent. " A-24 231 DRAFT The report should make the distinction that the cited turbine efficiencies (90-92%) are those modeled by manufacturers and that none of the turbines at mainstem dams have been indexed in-situ. Furthermore, it is unknown to what extent turbines are operated at peak efficiency. Monitoring of turbine operations at Corps projects in 1992 indicates that turbines are frequently operated outside of 1 % of peak efficiency (operating criteria established by the agencies and tribes) especially during low flow periods. 'Today, most researchers use the Schoeneman et at. , (1961) 11 perceru mortality rate as the best available mortality estimate for typical vertical Kaplan turbines. " This statement is false. In the Columbia and Snake basins, most researchers use a 15% turbine mortality rate, not the 11% estimated by Schoeneman et al. for McNary Dam. The NPPC used a 15% turbine mortality in System Planning (Integrated System Plan, CBFWA 1990) which is the mid-point of turbine mortality estimates of Columbia River dams (11-20%). 'Preliminary screen assessment studies indicate that screening mortalities may be similar to turbine mortality. " This statement is incorrect and obviously based on a single study, the Bonneville II survival study that showed that mortality of fish passing through the bypass system was higher than fish passing through turbines. The Bonneville II survival study is incomplete (adult returns will not be complete until 1995), and results from this study are not applicable to other dams due to design problems of the bypass system, location xjf the bypass outfall in an area of high predator abundance, and high efficiency of turbines (92% compared to 90% or less at other Corps projects). Page 63, 2.1.8. Modified Habitat Issues 'In arty event, transportation survival is relatively high (80-90%) in contrast to river migration past and through several water use project. " This statement should be qualified. It is true that transportation survival of smolts is relatively high compared to in-river migrants. However, transportation survival to adult compared to in-river migration has been shown to be higher for steelhead at Corps projects but marginally higher for chinook. At mid-Columbia projects, transportation survival of chinook and sockeye to adult has been shown to be lower than in-river migration (Carlson et. al. 1989). 'Gas supersaturanon levels have subsequently decreased, but at higher spill levels they can still cause significant smolt mortalities (NPPC, 1986, FPC, 1991). ' Although a Fish Passage Center 1991 report is cited as supporting this statement, close review of the FPC report reveals that it is being misinterpreted here. The FPC report A-25 232 DRAFT states, "Because of the high levels of spill that occurred at some projects in 1991, monitoring crews were alerted to note any evidence of 'gas bubble' disease in the fish sampled. There were no reports of injury to fish as a result of gas supersaturation" (page 22, FPC 1991 Annual Report). Page 65, 2.1.9. Water Flow Rates "Major rivers (native salmonid runs) identified as being seriously impacted by irrigation were the Deschutes, Hood, John Day, McKenzie arid Santiam Rivers. ' Anadromous salmonid populations are not seriously impacted by irrigation withdrawals l in the McKenzie River basin. A portion of this basin, The Mohawk River, is adversely affected by irrigation withdrawals but this activity only affects resident fish populations (per. comm. ™ igaiion wiuiurawais uui uus acuviiy uiujf aiit^is kp^iuuh. nan iwi^uianv/.u , Mark Wade, ODFW Biologist, Nov. 17, 1992). | "Table 2.1.9-1 summarizes basin water flows, withdrawal rights and ins t ream flow rights datafi}r selected salmonid streams in Oregon. " This table is not included with the other tables in the back of the report unless it is mis- labeled. "Subsequently, McConnaha allocated system survival estimates into individual dam combined turbine and spillway (structural-operational survival, and reservoir survival (non-structural). Individual dam structural survival ranged from 52 to 70 percent for spring chinook and sceelhead juveniles (30 to 48 percent mortality per dam). " In this paragraph, the authors attempt to summarize McConnaha' s table, "Data Base for Reservoir Smolt Survival at Snake-Columbia River Projects" which is presented as Table 2.1.9.-2 in this report. The authors incorrectly identify column b, "Estimated System Dam Survival," in the text as "Individual dam structural survival". Hence, the authors report that individual dam survival ranged from 52 to 70 percent, when in fact, McConnaha' s analysis used these estimates to represent combined dam survival for the actual number of dams (5 or 6) present at the time when systems survival data were collected. In his model, McConnaha used estimates of individual dam survival (from 0.89 to 0.93, recognizing considerable spill during the test years) to separate out reservoir and dam survival from the observed system survival data. System dam survival is the product of each assumed individual dam survival. A-26 233 DRAFT Page 66, 2.1.10. Flood Control and Navigation The following statement is unsubstantiated and misleading: "There are 22 major estuaries in Oregon, plus 1 7 minor estuaries:. . . All estuaries were especially critical for native pink and chum salmon, which mostly have disappeared,... " There is no evidence that pink salmon were ever native to Oregon estuaries. Chum salmon populations were found primarily in north coastal estuaries with smaller populations occurring in some central and southern estuaries. Only sixteen estuaries in Oregon (including the Columbia River) are believed to have historically contained populations of chum salmon (Chilcote et al. 1992). Section 2.2. Land Use Page 70, 2.2.1. General The authors do not report that the majority of road mileage in Oregon is for the purpose of forest management. Therefore, the negative effects of roads cannot be separated from the other negative effects of logging. The following passage is contradictory and the second sentence is unsubstantiated because the citation is not listed in the References. 'Fine sediments are detrimental to spawning gravel habitats and many millions of salmon and steelhead eggs and alevins have been smothered and subsequently died. However, salmon and steelhead are resilient, and the sediment spawning area impact is not always dramatic (Iwamoto etal.,1978) Other citations in this section not listed in the References include: Sidle et al. (1988), Bjomn (1969, 1970), Bjomn et al. (1974), Stober et al. (1982), Duyck (1987), Froehlich (1970), Saltzman (1977), and Burwell (1970). Roads rpaees 73-75 and 177-179): The report generally appears to be an accurate assessment of the impacts of roads on salmonid habitat, and the relationship of this activity as a factor contributing to the decline of these fish. This section does not identify land management activities responsible for a majority of the road construction affecting salmonid habitat, however. The relative responsibility for road construction may be obtained from a table in this section (page 73) which identifies that 70 percent of Oregon road miles are attributed to an "other" category comprised primarily of forest management roads. In addition, a majority of the literature citations substantiating the impacts of roads were extracted from studies concerning the affects of forest roads. The Department believes that this A-27 234 DRAFT discussion should be moved to the "forestry" portion of the report where the results of the studies cited are most applicable. Solar Radiation-Riparian Vegetation Loss (page 751: The report states that loss of riparian vegetation can be detrimental to salmonid production due to increased water temperatures in "...central and eastern Oregon streams... ", and cites reports indicating that "fsjunlight and temperature effects are not easily predictable or explainable in western Oregon (NCASI 1987, Hicks et al. 1991). " While we agree with the statement that loss of riparian vegetation can be detrimental to salmonids, we do not agree with the inference that this problem is limited to central and eastern Oregon. Past scientific studies have noted detrimental increases in stream temperature due to riparian vegetation removal in western Oregon (Brown et al. 1971; Moring 1975a; Moring 1975b; Moring and Lantz 1975; etc.). In addition, the Department was not able to locate information in Hicks et al. (1991) to support the statement that temperature effects are "ru)t easily predictable or explainable in western Oregon ". The Department was unable to verify the statement attributed to NCASI (1987) as the referenced study is not documented in the bibliography. These statements appear to be unsubstantiated by the references cited, and are not supported by the majority of research available on this subject. Page 76, 2.2.2. Agriculture General Comments Introductory material consists of questionable assertions concerning historical and contemporary agricultural practices. For example, the statement that "agriculture was the first major step in the evolution of culture and the first alteration of ecosystems" disregards the prior emergence of language, clothing, and religion, and the ecological consequences of cooperative hunting and the use of fire. Historical (pages 77-78> "In 1970. private acreage for crops in Oregon had risen to 5.3 million acres... fsjome 1.7 million acres were irrigated. " According to the most recent data available from the U.S. Department of Commerce (1987 Census of Agriculture 1:37 Oregon State and County Data), there were 2.8 million acres of cropland in Oregon, 1.6 million of which were irrigated, not 5.3 million acres of cropland with 1.7 million acres irrigated as suggested (citing 1970 data). The total for the first column of the untitled table at the bottom (million acres dryland) is 4.6, not 3.6. A-28 235 DRAFT Irrieation (pages 78-81) The totals for the columns in the Table titled Oregon River Basin runoff characteristics (cfs) are 105,000 (mean annual runofO, 22,500 (mean summer runofO, and 5730 (low summer runofO respectively, not 107,000, 21,000, and 6,000 as indicated. Nonpoint Source Pollution (pages 80-81 and 159-160): The authors provide an adequate assessment of the distribution and impacts of nonpoint source pollution (NFS), but they imply that agriculture is the only land management activity responsible for these problems. Nonpoint source pollution is common to many land use activities, but agriculture appears to be solely implicated because: (1) this discussion is presented only in the agriculture section, and (2) by the statement that 'agricultural land use predominates the monitored problem areas. " It should be clarified that the referenced ODEQ report was prepared to guide the development of an NPS database and NPS control plans, and was not designed as a "...fault-finding or finger-pointing exercise" (ODEQ 1988). Further, the statement that agriculture 'predominates the monitored problem areas" is not a conclusion of, nor appears to be substantiated by the ODEQ report. Assigning the relative importance of land management activities basal upon the location of "monitoring areas" is an invalid approach that does not recognize that upstream activities can affect water quality in downstream reaches. The ODEQ report (ODEQ 1988) included a description of land use activities potentially contributing to NPS problems by citing the "land uses most commonly cited in connection with" the NPS problems for each basin. This qualitative information is summarized in Table 1. For consistency with the OFIC report subject, six basins were excluded because they do not contain anadromous salmonids. Forestry was referenced by the respondents as often as agriculture and grazing in identifying land use activities potentially contributing to the NPS problems. Forest management was also identified as a potential contributor in all basins where anadromous salmonid populations exist except the Umatilla. The ODEQ also presented a version of this information in a subsequent document that reported the number of miles of stream affected by NPS pollution in each basin of the state, and the suspected sources of this pollution (ODEQ 1990). This information is reproduced in Table 2 (basins without anadromous salmonids were again excluded from the comparison for consistency with the OFIC report subject). This information suggests that forest management activities represent a considerable source of NPS pollution, and that the number of stream miles potentially affected by forestry exceed the estimates for all other individual activities. The authors incomplete presentation of the ODEQ reports resulted in potentially erroneous conclusions. In describing the relative distribution of NPS problems the authors cited ODEQ (1988) in reporting that: 'Hood River Basin appeared most affected (84 perceru of assessed miles had moderate or severe water quality impacts), and the Rogue River Basin appeared least affected (44 perceru of assessed miles had water quality problems). " A-29 236 DRAFT Forestry was the "most commonly cited land use activity" (Table 1), and was suspected of affecting the majority of stream miles (Table 2) in the Hood River Basin ("most affected") while agriculture was considered less important. In addition, the Rogue River Basin ("least affected") was only one of two coastal basins where forestry was not one of the "most commonly cited" land use activities potentially contributing to NPS problems, and was the only coastal system where forestry was not the dominant source of stream miles affected by NPS pollution (Table 2). Table 1. The *OK>st commonly cited' land use activities attributed to NPS problems identified in the ODEQ NPS Report (ODEQ 1988). This analysis is qualiutive and is only compiled to highlight problems with statements within the OFIC report. Basins without anadromous salmonids were excluded for consistency with the subject discussed in the OFIC report. Basin Land Use Activities Most Commonly Cited Others Cited Coastal North Coast FOR. REC IR-AG. NI-AG. GR Mid-Coast FOR. GR, NI-AG Umpqua FOR GR. RNG South Coast IR-AG. NI-AG FOR, GR Rogue River IR-AG FOR Interior Willamette R. FOR IR-AG, NI-AG, URB Sandy River FOR, REC Hood River FOR AG, REC Deschutes River GR FOR, IR-AG, REC John Day GR, IR-AG, NI-AG, FOR. REC Umatilla IR-AG, NI-AG, GR Walla Walla Grande Ronde GR, FOR IR-AG= irrigated agriculture, NI-AG =nomrrigated agriculture FOR = forestry. GR- grazing REC = recreation URB= = urban I RNG=rangeland management A-30 237 DRAFT Table 2. Summary of river miles, by basin, affected by nonpoint source pollution, and the suspected causes. This Uble was reproduced from Table 3.2-4 of ODEQ (1990). The table was modified to only include basins supporting anadromous salmonid populations. Table 3.2-4: Suspected Nonpoint Sources of Water Quality Problems In Rivers where Beneficial Uses Are Not Fully Supported — Summary by Basin of River Miles Affected by Each Source (1988 Assessment) T KIVEX MILES IMPACTED BT MOSS THAN OSE SOURCE ASE COUNTED SEPAJtATELT FOlt BACH SOURCE ■■■'■:'■""■:". '::^ Noapoint Source Natural Other Agricuhure Range Forestry Storm Water CotDbtned Sewen Constnictioa Traiuport Mining Recreatioa 475 315 615 135 185 325 295 425 480 0 350 195 545 10 85 20 90 295 115 0 365 415 820 110 30 375 185 135 270 0 9. 430 180 625 40 IS 75 135 15 215 0 615 250 545 225 270 165 300 215 637 0 720 495 585 680 485 400 420 1.255 480 5 5 5 115 5 10 0 0 120 55 0 120 too 155 10 0 40 0 100 40 0 705 970 520 210 190 65 110 675 205 0 1,120 1.315 1.035 5 0 0 125 685 985 0 It 620 670 140 70 50 40 45 85 75 0 nde 390 805 680 55 60 340 135 540 70 5 5,915 5,715 6.380 1,555 1.380 1,845 1.840 1 4,545 3,627 1 10 1: infoniuiioa in (hit uble wii biied on DEQ'i oonpoini Kwice •ucumeol which wti complcKd m 1988. The •ueumed it • dau hue which coouios {liu (biied 00 tctual sampling including the niulu of DEO'i unbient iDooilonnx) and eviliuled dau (baied oo a combinauoa of dau. obiervalion. aol |l judfmcni). The evaluated dau were larjely provided bjr other afCDciea and have not yet be«a verified by DEQ. The iniJea{e ouoben riiouJd Iherefofv be 1 •timalet. Updalea of (he aueumeni are planned. In this aueianKnl, moat of the infotnutioa received wai for major lira-order atreami where problema »no problem) wet« repotted for a particular itream •egment, that Kgmentwai grouped with the "JuOy supporud" tpntOU. Sireanu with "modtnur" water |>lemi were claiaified at "panlalfy lupporud". Streami with "jrverr " water quality problema were cltitified ai "not lupponed". IH4997.5 A-31 238 DRAFT Erosion (pages 82 and 160): The authors state that: "A storm of equal intensity will cause at least two times the erosion on agricultural lands as on managed forest lands (Sedell and Beschta, 1991). • Review of the cited document failed to substantiate this statement. Sedell and Beschta (1991) cited one study by Hickin (1984) which reported that: "...riverbanks that are well bound by roots offer far greater resistance to lateral erosion than relatively unvegetated banks of rivers of western Canada. For similar hydraulic conditions and bank characteristics, a river migrating through a cleared or cultivated floodplain would erode at nearly twice the rate of one reworking a naturally forested floodplain." (Sedell and Beschta 1991) [emphasis added]. The statement appears to be a misinterpretation of this study. The study by Hickin (1984), as summarized by Sedell and Beschta, compares relative erosion rates between floodplains with vegetation removed and naturally forested floodplains. The statement from Sedell and Beschta (1991) makes no distinction between agricultural or forest management vegetation removal: the study refers to "cleared or cultivated" floodplains where "cleared" implies that vegetation was removed. In addition, erosion rates on cleared land were compared to naturally forested floodplains: the assumption that naturally forested floodplains are synonymous to "managed forest lands" is not substantiated by Sedell and Beschta (1991). The discussion of floodplain functions presented in Sedell and Beschta (1991), including studies by Hickin (1984) and Li and Shen (1973), substantiated the value of floodplain habitats. These studies highlighted the need for the protection of natural vegetation along floodplains to reduce erosion and sediment transport, protect the natural ecological functions of these areas, and to provide necessary fish and wildlife habitat. Sedell and Beschta (1991) referenced a study by Li and Shen (1973) in reporting: "an exponential increase in relative sediment transport rate as cylinders were removed (i.e. as trees were harvested) from floodplain forests. This relationship highlighteid the need to retain trees on forested floodplains to reduce sediment transport of flood waters." Grazing, (pages 84-85) The authors present no discussion of the regional nature of the problem, distinctions between public and private range conditions, problems with bank stability, groundwater, water quality, water temperature, etc. Literature citations are inadequate considering Uie great amount of agency and academic interest in this topic. A-32 239 DRAFT General rnages 84-85) This section is an odd mixture of beaver lore and anecdotes concerning settlement and channelization. The fact that mining has contributed to current fish habitat problems is acknowledged in a single sentence, lumping it with agriculture and mining. The authors cite research by Mcintosh, Sedell and Clarke (1992) documenting historical stream degradation and the loss of pool habitat on the Grande Ronde River. These changes were appropriately attributed to the cumulative effects of land use practices over a fifty year time interval. However, the authors appear to imply that agriculture and mining are the primary causes, and that forestry impacts were restricted to activities prior to 1941: 'The biggest stream habitat problem today is in the agricultural lands below the forest... ' "Land use practices responsible for the degradation... are historical and include agriculture and historical mining and forestry (pre-1941). " These statements, and the fact that the discussion is only present in the "agriculture" section, seem to imply that other land uses in the basin are a minor component of the habitat problems. The observation that the loss of the most productive habitat occurred where farms and ranches are located today (in the mid-section reaches) implies that agriculture may be responsible, and neglects that sediment impacts are transported downstream from upper portions of watersheds. Also, the statement limiting forestry impacts to "pre-1941" is inconsistent with the study results which measured habitat changes occurring after 1941 (1941-1990). The authors also repeat these statements in the summary section (page 163). Similar research assessing the cumulative changes to stream habitat over time has been conducted by Jim Sedell (US Forest Service, PNW Research Station). Hicks et al. (1991) cite the results of a study (Sedell, unpublished) which showed a 70 percent loss of pool habitat over 50 years following large-scale timber harvest and salvage of downed timber in the Breitenbush River, Oregon. This information was not presented even though Hicks et al. (1991) was cited several times in this report. Summary (pages 85-86) The authors conclude that agricultural practices are the "...dominant land use practices... of concern for wild salmonidfsj. ' There is no mention in any section of problems associated with diked pastures or transportation systems that support farms and ranches. A-33 240 DRAFT Page 86, 2.2.3. Forestry General Comments This section provides an incomplete review of the available scientific information concerning the relationship between forest management and salmonid habitat productivity. The report does not adequately present existing information on several subjects (large woody debris and water temperature), attributes forestry-related studies and impacts to other land management activities (roads and riparian vegetation removal) and does not present the results of several important long-term studies of the affects of forest management on salmonid habitat and salmonid productivity. The importance of large woody debris for salmonid habitat, and the relationship that riparian conifer harvest contributes to the shortage of this material is not adequately presented. For a comprehensive literature review, the report should include information contained within: Naiman et al. 1992; Bisson et al. 1992; Bisson et al. 1987; Bilby and Ward 1989; Bilby 1981; Robison and Beschta 1990; Bustard and Narver 1975; McMahon and Hartman 1989; Heifetz et al. 1986; Nickelson et al. 1992; Andrus et al. 1988; Ursitti 1990; and many others. The relationship between riparian vegetation removal, water temperature and the productivity of salmonids is not presented in adequate detail. For a comprehensive literature review, the report should include the results of such studies as: Holtby 1988; Beschta et al. 1987; Brown et al. 1971; Duston et al. 1991; Li et al. (in process); Ringler and Hall 1975; and many others. The results from long-term studies of forest management and salmonid habitat are not presented in the report. For example, the results from studies such as the Alsea Watershed Study (Moring 1975a, 1975b; Moring and Lantz 1975) and the Carnation Creek Study (Hartman and Scrivener 1990; Holtby 1988) should be included in the report for the document to be comprehensive. Woody Debris Removal (page 88): The report presents a significant discussion of past debris removal activities by fisheries agencies, but does not investigate the role of riparian conifer harvest on the long-term supply of large woody debris. The current shortage of this material is primarily attributed by the authors to debris removal activities, but research exists that also discusses the relevance of these shortages to timber harvest. In addition, the report does not acknowledge that typical debris removal projects involved log jams consisting of hundreds of logs that totally obliterated sections of streams. A-34 241 DRAFT Fine Sediments (pages 90 and 172): The authors make several statements concerning the effects of fine sediments on salmonid production which are inaccurate, and are not supported by the literature cited. The specific statements were attributed to Hicks et al. (1991) and are as follows: 'Fine sediments reduced spawning success but may have locally increased primary and secondary productivity . Locally, increases in food production for juvenile and salmonids (sic) may have increased nursery carrying capacity. ' 'Sediments [from logging related surface erosion, mass wasting, roads, scarification and slash burning] generally reduced spawning success and rearing capacity but may have increased rearing capacity locally. " "Invertebrate production may have been locally stimulated. . . " [referring to logging related increases in fine sediments] (page 172). Information reported by Hicks et al. (1991) is directly contrary to the statements contained within this report. Hicks et al. (1991) state that: "in addition to directly affecting salmonid survival, fine sediment in deposits or in suspension can reduce primary production and invertebrate abundance and can thus affect the availability of food within a stream (Cordone and Kelley 1961; Lloyd et al. 1987)." In addition. Table 14.1 from Hicks et al. (1991), which is accurately reproduced in the OFIC report (pp 170-172), specifically attributes increased fine sediments to "reduced food abundance" and "loss of winter hiding space". Nowhere in the text or tables of Hicks et al. (1991) could the Department document information to support the OFIC report authors' statements. Natural Sediment Losses in Undisturbed Forests (page 92): For comparative purposes, the table presented on page 92 would be improved if the data were converted from "tons per square mile" to "tons per acre". Most references to erosion and sedimentation in this report are based on the latter standard of reference. A conversion of this data (below) aUows comparison to text references (BLM 1981; BLM 1983) of forest related sedimentation: road related sedimentation presented for these references appears to be 20X to 300X greater than the maximum PNW Average Range for sediment loss in undisturbed watersheds. A-35 242 DRAFT Miscellaneous Natural Sediment Losses in Undisturbed Forests (tons per acre f)er year)* Lowest Range PNW Average Range Three Alsea Watersheds Average Castle Creek, N. California N. Calif. Coast Marine Soils 0.003-0.031 0.23-0.55 0.49 1.46 3.13 Reproduced from the OFIC report; no verification of original data accuracy* Chemical Use. Agriculture and Forestry (pages 93. 164 and 174): The information presented in the table on page 93 is misleading, and does not appear to be reflective of the actual total use of chemicals by the forest industry. As noted by footnote "(b)" of the table, the chemical use attributed to "forestry" only includes chemicals applied by the U.S. Forest Service on National Forest lands and is, therefore, a vast underestimate of the total use of chemicals by the forest industry. The estimates for agricultural chemical use are extracted from an EPA report which presumably estimates total agricultural use within the entire nation. The authors of the original report from which this data is extracted (Norris et al. 1991) specifically note that: "these figures underestimate the total use of pesticides in forestry because they do not include pesticides applied by other U.S. agencies or by state or private forest management groups. " The "ratio comparison" prepared by the authors of the OFIC report is not valid since it is based on incomplete data, and should not be included within the report. Several other statements in this section of the report are also questionable: "These ratios [referring to the previously discussed table] could be applied to the land use acres for agriculture (5.3 million acres crops, 22. 7 million acres range) versus timberland (21.9 million acres). Application of the chemical use ratio estimates to the agricultural and forest land acreages would result in an inaccurate estimate of relative chemical use. "[Pesticide] application is often by aerial spray, except a large portion of herbicide is now hand sprayed. . . " (emphasis added) This statement is not substantiated by any literature citations, and is contrary to current forest management trends. The authors may be referring to U.S. Forest Service pesticide use being restricted to hand spray applications due to a nationwide ban on aerial application of these chemicals (Norris et al. 1991). Attributing this trend to all forest lands is not indicative of current land management practices. A-36 243 DRAFT Regulations and Practice^ rpages 95 and 169): The authors cite several provisions of the Oregon Forest Practices Act incorrectly: 'Buffers. . . were. ..maintained on state Class I streams to protect soils and provide 75 percent of shade. ' '. ..and streamside vegetation were to be in near natural condition. ..and provide for 75 percent pQU operation shade cover. ' (emphasis added) 'The 75 percent stream shade rule was retained with the addition of a 50 percent overstory canopy rule. . . Trees mav be cut in the RMA. if the actual riparian zone meets the 75 percent stream shade and 50 percent oversiorv canopy rules. ' (emphasis added) 'The 75 percent post operation shading rule was retained and a 50 percent canopy rule was added. . . Trees could be cut in the RMA if the 75 percent post operation stream shading and 50 percent canopy requirements were met. Otherwise, timber in the RMA was protected to meet the shade and canopy rules. ' (emphasis added) These rules are improperly interpreted and do not reflect the current management restrictions placed on timber harvest activities within Oregon riparian management areas (RMA). The correct language of these rules is as follows: OAR 629-24-546 (3) (a) Maintain an average of 75 percent of the preoperation shade over the aquatic area along Class I waters. OAR 629-24-546 (3) (b) Retain at least 50 percent of the preoperation tree canopy in the riparian area along Class I waters. Timber harvest activities are currently allowed to reduce existing shade and overstory vegetation to 75 percent and 50 percent, respectively, of preoperation conditions. These regulations are not currently based upon postoperation conditions as the report states. The authors also imply that timber harvest activities are restricted if preoperation conditions are less than 75 percent shaded and 50 percent overstory canopy closure: these restrictions are not a current requirement of the Oregon Forest Practices Act. For example, recent monitoring conducted by the Oregon Department of Forestry indicates that, on the average, shading on streams within the ODF Northwest Region was reduced from 83 percent preoperation levels to 61 percent following logging (ODF, Water Temperature document from technical workshops related to SB 11 25). This section should be rewritten to reflect the actual legal requirements of the Oregon Forest Practices Act. A-37 244 DRAFT Page 96, 2.2.4. Municipal - Industrial This section discusses point source pollution discharges by municipal and industrial entities, but presents tabular information that is very misleading. A table listing the number of stream miles "adversely affected" by such parameters as low dissolved oxygen, bacteria, turbidity, elevated stream temperatures, etc. is presented in a manner that implies that municipal and industrial sources are the cause of this pollution. However, the data in this table actually reflects an assessment of statewide nonpoint pollution problems from a multitude of land use activities. The report cited for this information (ODEQ 1990) indicates that municipal and industrial sources are a minor component of the pollution problems, and that the majority of stream miles affected are attributed to forestry and agricultural practices: a figure in the ODEQ report identifies the relative sources of pollution as forestry (17.4%), agriculture (17.4%), municipal (2.4%), industrial (0.8%), mining (5.2%), etc. "...some 1,062 miles of river reaches that do not support beneficial uses by point source municipal pollution. " ". ..some 386 miles of river reaches are listed as impaired by point source industrial pollution. . . " In the second statement, the actual number of miles affected by point source municipal pollution is reported as 368 miles by ODEQ (1990). If the analysis is restricted to basins containing anadromous salmonids (the focus of the OFIC report), the correct estimates of stream reaches impacted by point source pollution would be 1 ,036 miles for municipal pollution, and 342 miles for industrial pollution. Additionally, for comparative purposes it should be noted that the estimated river reaches impacted by nonpoint sources of pollution are 6,380 miles for forestry activities, and 5,915 miles for agriculture activities (excluding basins without anadromous salmonids). Page 98, 2.2.5. Mining This discussion of historical mining in Oregon provides very little information concerning the effects of mining activities on salmonid habitat or salmonid productivity. Additional literature review should be completed to assess the potential effects of these activities on salmonids. The authors cite ODEQ (1990) in stating that: ". . .some 2,280 miles of streams potentially adversely affected by non- point (sic) source mining problems. " The estimate of miles affected is correct if all basins in Oregon are considered. However, if the analysis is restricted to basins with anadromous salmonids the actual estimate of stream reaches affected by mining is 1,840 miles. A-38 245 DRAFT "This [gravel extraction] has probably contributed to the lack of recovery of pink and chum salmon stocks in coastal rivers. ' As discussed previously, pink salmon are not indigenous to Oregon, therefore, it is unlikely that mining has prevented the "lack of recovery" of these fish within this state. SectioD 2.3. Environmental Phenomena Page 100, 2.3.1. Natural Phenomena The following passage is inaccurate and misleading: Every two to seven years, a reversal in tropical Pacific wind and ocean currents generally occurs. This phenomena, termed El Nino, (sic) brings warm surface waters and easterly winds to the West coast of the Americas. Upwelling and subsequently primary productivity, is suppressed. . . " Whereas El Nifios are common in South America, contrary to the impression presented. El Ninos of a magnitude to bring warm water to the coast of Oregon have been rare. Only 4 times in the past 50 years has this happened: 1941, 1957-58, 1982-83, and 1992. Page 101, 2.3.2. Predation and Competition Introduction. Natural Predation (pages 101-102) These two paragraphs are one of the few places in the report where predation is accurately presented as a natural, important, or positive influence in biological systems: '...salmonids are also an integral component of a complex, natural ecosystem. ' "...they [salmonids] represent a food source to natural predators... ' 'Salmonids have always been exposed to predation. They coevolved with their predators in the natural environment without either completely avoiding or succumbing to them. ' However, these accurate descriptions of the significance of adaptive evolution, long- standing trophic interactions, and energy transfer immediately give way to the overriding premise that, due to various population and environmental changes, current predator-prey relationships in the marine environment have been "reshaped". The A-39 246 DRAFT report proceeds with the premise that such predation is no longer considered natural, but instead is a "human-influenced biological interaction" that has contributed significantly to declines and/or lack of recovery of Oregon wild salmonids. These conclusions are not supported by the information or analyses presented in the report. Freshwater System Alterations (pages 102-103): The following statements are questionable: "Die large numbers of hatchery juveniles may buffer predation on wild fish. ' The large numbers of hatchery juveniles may, conversely, stimulate predation via functional response (Vigg 1988). "Predator populations may be increasing simply because there is an ever increasing supply of prey. " Predator numbers are probably not regulated or affected by salmonids because these fish are a small fraction of the diet ration (Poe et al. 1991). Fish predation (pages 103-105): "TTiese predator populations would otherwise decline if forced to rely primarily on ever diminishing populations of wild native juvenile salmonids. " Predators don't rely on wild native juvenile salmonids, instead use resident feeds (invertebrates, sculpins, suckers, etc.) (Poe et al. 1991). "These results are similar to the findings of Uremovich et al. , (1980), who estimated that northern squawfish may have eaten 3. 8 million juvenile salmonids in theforebay of Bonneville Dam in a five-month period in 1980 (Table 1. 7-1). " Estimates by Uremovich et al. (1980) are greatly inflated because of sampling design problems. "Although no estimates of predation were given, Thompson and Tufts (1967) reported that northern squawfish predation was significant on juvenile sockeye salmon in Lake Wenatchee, Washington. " Incomplete... see Brown and Moyle (1981). A-40 247 DRAFT 'Studies by Poe et al. (1991) between 1983 and 1986 revealed that from April to August salmonids comprised (by weight) 67 percent of the diet of northern squawfish, 33 percent of channel c^sh, 14 percent of walleye, and four perceru ofsmallmouth bass. ' These results are skewed by disproportionate sampling in the boat-restricted zone (Poe etal. 1991). V. Petersen et al. (1990) observed that salmonids constituted from 73 to 99 percent (mean 91 percent) of the northern squawfish diet in July of 1988. • In the immediate vicinity of the dam which is not representative of the squawfish population. "However, if northern squawfish prefer dead and injured over healthy prey, then these fish may be more of a scavenger than an active predator. ' Clearly an active predator (Rieman et al. 1991): 1. Most loss occurs far from dams where fish are likely to be healthy. 2. Laboratory tests not corroborated in field where different conditions make it difficult to discern prey condition (by predators). Bird Predation (Pages 105-106) This section provides some information concerning bird predation on salmonids, however, it does not provide the information necessary to evaluate the relative contribution of this factor to the decline of Oregon's salmonid resources. While it is true that bird predation is a natural component of the freshwater and marine ecosystems, no information was presented to suggest that the loss of salmonids to this factor is increased above natural historic levels. Specific comments on the information presented are as follows: 'Ruggerone (1986) estimated that ring-billed gulls... consumed two percent of the salmon and steelhead trout passing Wanapum Dam. . . " Ring-billed gulls, as many gull species, are opportunistic feeders and are likely to exploit prey as the opportunity exists. The predation rates observed by Ruggerone (1986) may not be applicable to the overall gull population, however, as the information was collected in the vicinity of a dam. Salmonids at this location were A-41 248 DRAFT likely more susceptible to predation due to passage related injuries or disorientation. It is also likely that the gulls in this study were scavenging dead smolts below the facility. "Wood (1987) noted that mergansers may limit salmon production in nursery areas in British Columbia. He estimated that young merganser ducklings can consume almost one half pound ofchinook salmon fiy per day. Thus, a brood often ducklings could consume between four and five pounds offish daily during the summer rearing period. " The authors reference for Wood (1987) does not correspond to the information presented. Wood actually presented two studies in the referenced journal; the information presented app^s to be derived from Part n, not Part I as cited. Wood (1987a) concluded that merganser predation on seaward migrating salmonids was not likely to affect salmonid populations: "Juvenile salmon are more vulnerable to predation for a period of days, or at most weeks, during their downstream migration. A predatory species must be very abundant to inflict appreciable mortality ...the overall mortality rate due to mergansers was depensatory-mergansers were simply swamped by the output from spawning channels and hatcheries." "The mortality rate due to mergansers is very unlikely to have exceeded 8% for any particular stock during downstream migration.." "Probably no single species of avian predator is capable of inflicting compensatory mortality on juvenile salmonids during their seaward migration... it follows that predation by all fish eating birds, acting in concert must also be depensatory and that salmon populations cannot be regulated by avian predation during their seaward migration." The actual study the authors cite (Wood, 1987b), discussed merganser predation on stream-resident populations of salmonids. A major conclusion of this study was not reported: "It is not clear whether mortality due to merganser broods has any effect on the eventual size of smolt migrations in Vancouver Island streams. Because merganser ducklings kiU salmonid fry during summer months, there is ample opportunity. . . for compensation to occur if overwinter survival is further limited by food or habitat..." An analysis of the applicabili^ of this study to Oregon streams should consider whether the abundance of mergansers is similar to that observed in the British Columbia study area. A-42 249 DRAFT 'White (1938) found an inverse relationship between stream flow and percent of brook trout in the diet of kingfishers ... evidently the kingfisher experienced increased feeding efficiency in slower moving waters caused by stream diversions. ' Did White (1938) cite the cause of stream flow changes as water diversions, or did the study measure predation rates under natural fluctuations of stream flow? 'Studies (Mathews, 1983) have shown that the common murre... ' 'Thus, the estimated 40,(XX) birds that occur off the Oregon coast each spring could account for the loss of several million smoltsfor each month that their presence coincides with the arrival ofsalmonid smolts. " The referenced study is not included in bibliography, so we were unable to verify the accuracy of the cited information. In addition, we question whether the estitnated consumption of salmonids by common murres was reported by Mathews, or if this calculation was completed by the OFIC report authors. A listing of the assumptions inherent to this calculation should be provided so that the validity of the estimate can be evaluated. "McNeil et al. (1991) demonstrated that survival of hatchery-reared coho salmon could be markedly improved by transporting them in net- pens. ..avoiding bird and fish predation in nearshore waters. It is likely that wild salmon smolts would be susceptible to the same type of predation. ' While we agree that wild smolts would be susceptible to the same type of predation (birds and fish), the amount of predation on hatchery fish is likely to be markedly greater due to releases of large numbers of smolts within a short time period. These hatchery release strategies may attract predators due to the concentration of prey species (salmonids). The implication that wild smolt survival would be markedly increased in the absence of this predation (as reportedly occurred at the private hatchery) is unsubstantiated. Marine Mammal Predation (Pages 106-112) The report notes that protective legislation has resulted in increases in some marine mammal populations in the Pacific Northwest, and suggests that: '...these recent increases in marine mammal numbers are causing irKreased predation rates on salmonids. ' No reference or scientific substantiation is provided for this statement. While there are reports documenting increases in some mammal populations over time, there are no A-43 250 DRAFT comparable studies that examine changes in "predation rates on salmonids". The authors conclusion appears to be unsubstantiated. Harbor Seals (pape 107-108) The report refers several times to Chapman et al. (1991) as a reference source for harbor seal abundance estimates. This reference is a PNUCC report on Snake River Chinook, and is only an indirect reference for harbor seal abundance or population increases in the Columbia River area, Washington, or Oregon. The primai7 source of this information is ODFW, WDW, and NMFS (contract reports, administrative reports, and unpublished data). Some of the abundance estimates presented in this discussion are incoirect. The report references Olesiuk et al. (1990) in discussions of harbor seal predation on salmonids, but some of the information and conclusions from this study are omitted. For example, Olesuik et al. (1990) reported that the dominant seal prey items in British Columbia were hake and herring; 75% of the total diet combined. Salmonids made up just four percent of the diet and represented less than three percent of the mean annual escapement for the entire Strait of Georgia. This level of predation loss does not seem to be a highly significant contribution to salmon mortality, even though "predator" numbers apparenUy increased from 10,000 in 1970 to over 80,000 in 1988. Using the information from Olesiuk et al. (1990), and the same questionable methods of calculation found in this section, it could be hypothesized that if it took 80,000 seals in B.C. to consume 866,800 pounds of salmon, then the 10,000 seals in Oregon would take only one-eighth of that amount or just 108,350 pounds (12,312 salmon). This estimate represents only three percent of the 1990 Oregon salmon landings (as presented in the report) not 58 percent as suggested (page 108), or just six percent by weight, not 64 percent. "Harvey calculated that salmon represented almost 11 percent of the total biomass that harbor seals consumed. " The report referred to several Oregon studies that reported that salmonids can comprise between one and 12 percent of seal diets. The report then used a relatively high value of 1 1 percent (Harvey 1988) to complete statewide calculations of salmonid consumption. Not surprisingly, this analysis resulted in a greater estimate than would have been derived by using a median value of salmonid consumption from the various studies. A-44 251 DRAFT 'Harvey estimated that harbor seals consumed 1.3 million pounds of salmon in Oregon in 1980... ' 'Because the Oregon harbor seal population has increased to 10,000 animals since 1980. it would now consume approximately 1.8 million pounds of salmon... ' The report uses an estimate from Harvey (1988) that seals consumed 1.3 million pounds of salmonids in Oregon in 1980 to conclude that this represents 30 percent of the 1980 landings. This conclusion does not recognize that the majority of the salmonids Harvey reported to have been consumed by seals were steelhead, and not "feeder" chinook or coho as sUted in the report. The authors then use the (incorrect) figure of 10,000 seals in Oregon and extrapolate to estimate that 1.8 million pounds of salmon were consumed by seals in 1990. The report then incorrecdy uses this data (which includes Harvey's steelhead estimate) to compare these predation loss estimates to ocean commercial troll landings of salmon. The report uses incorrect figures and comparisons to report increases in pounds of salmon consumed by seals statewide and in the Columbia River between 1980 and 1990. These calculations do not constitute valid scientific methodology, and the conclusions drawn are not supported by the data. 'Numerically, salmon may represent less than one percent of the harbor seals diet. . . ' The report acknowledges that, based on Harvey (1988), salmon numerically comprise less than one percent of the seals diet in Oregon. However, the report suggests that salmon (by weight) can comprise at least 10 percent of the "diet requirement". This statement is misleading: if less than one percent of the fish eaten by seals is salmon, then, less than one percent of the fish eaten is salmon. Rephrasing the statement does not change the reality. Seals, nor any other marine mammal, require salmon in their diet. What is required is a certain biomass of food, usually fish, of which salmon is a relatively unimportant component in the overall diet. Other scientific data concerning harbor seal food habits were not presented in the report, including dau collected by ODFW and WDW in the Columbia River. In 1986, 1987, and 1988 the jgastrointestinal tracts of 84 harbor seals collected during winter salmon and steelhead run periods were examined for food habits analysis. Eulachon was the most important prey item, by frequency and by weight, occurring in 100% of the seal stomachs. Longfm smelt and lamprey occurreid in 14.3% and 9.5% of the samples respectively. Five other species of fish were consumed by these seeds. No salmon or steelhead had been consumed by any of the 84 harbor seals in this sample. This was the largest collection of seal stomachs for food habits analysis that has been completed in Oregon to date. This study of the Columbia River suggests that harbor seal predation on salmon and steelhead is minimal; however, it would not be valid to extrapolate these results to the entire Oregon coast for all seasons of the year to imply that harbor seals do not consume salmonids. A-45 252 DRAFT Sea Lions Tpages 108-110) "In their studies in the early 1980s, Beach (1982) reported maximum counts of 150 to 200 California sea lions in the vicinity of the Oregon coast. " Beach (1982) is not listed in the bibliography. Beach et al. (1985) would be the appropriate reference, and it is listed in the bibliography. However, Beach et al. (1985) only reported California sea lion numbers in the Columbia River area, not "in the vicinity of the Oregon coast". The authors erroneously imply that large increases in sea lion numbers were documented in Oregon through the 1980's. Neither the data in Beach et al. (1985) nor the information presented in this report support this conclusion. ODFW and WDW have unpublished data that suggests that numbers of California sea lions in Oregon and V/ashington during the winter have increased along with growing breeding populations in California. However, these data series are incomplete and are not highly useful in demonstrating trends in California sea lion numbers in Oregon. "The northern sea lion has a North American population of about 200,000 animals with most in the Gulf of Alaska (Olesiuk and Bigg, 1988). " The reference used for Steller sea lion population status in North America, and the estimates of abundance presented are not current. More recent information is available from the National Marine Fisheries Service, Seattle. "A maximum of 350 to 400 northern sea lions were recorded off the coast of Oregon in 1982 (Beach et al. 1982). ' Beach et al. (1982) is not referenced in the bibliography. Again, this reference is apparently used incorrectly by referring to numbers of sea lions reported in the Columbia River area as being "recordwl off the coast of Oregon". "...a resident population of from 200 to 400 northern sea lions in Oregon. . . (Robin Brown. ODFW personal communications, 4 March 1992). " In this statement the meaning of "resident" is unclear. The abundance estimates are inaccurate. This is an important point because these estimates and the "residency" status are used directly in the calculations of salmonid consumption by this species. Manipulation of these estimates and the use of the term residency could significantly A-46 253 DRAFT alter the outcome of such calculations. In reality, the number of Steller sea lions that occur in Oregon throughout the year is probably greater than the estimate of 300 used in Table 2.2.7-3, however, the actual number of sea lions present in any area at any time are nearly impossible to estimate with much accuracy. Therefore, any consumption estimates based on such numbers are also likely to be inaccurate. 'The sex ratio of the northern sea lions in Oregon is assumed to be 1:1. ' No reference is provided to support this statement. A 1 : 1 sex ratio may be accurate for newborn pups, but not necessarily for adults. This is an important consideration since greater prey consumption rates for larger males are weighted evenly with those of smaller females in the calculations wiUiin this report. In reality, large males probably make up a relatively small portion of the total population when compared to females, juveniles of both sexes, and pups combined. It is inappropriate to use average estimated consumption rates for adult males and adult females, and apply them to the total population (which includes hundreds of juveniles and pups) with equal weight. 'The diet of all wintering sea lions off southern Vancouver Island. . . (Olesiuk and Bigg, 1998). . . equals one percent of British Columbia's total annual commercial landings of salmon. " The report briefly cites this conclusion of Olesiuk and Bigg (1988) and then appears to ignore the implications of this conclusion. Assuming that British Columbia fisheries are managed properly, the total commercial landings should not be expected to have a significant negative impact on salmon populations. Therefore, the additional one percent of the harvest amount taken by sea lions should have a minimal, if not insignificant, affect on the commercial harvest, and an even smaller impact on total salmonid populations in British Columbia. If this is the case in British Columbia, it is difficult to believe that sea lions could play such a significant role in the reduction of salmonid populations in Oregon (as this report suggests). "Seasonal aggregations of California sea lions near the mouth of the Columbia River are believed to feed on large concentrations of smelt (Eulachon sp.) (Beach et al. 1985). ' (emphasis added) The tepon implies that there is some doubt regarding the importance of pinniped predation on smelt. Existing information supports that both seals and sea lions feed heavily on smelt. The large smelt run during winter months is believed to attract seals and sea lions into the Columbia River. Smelt is the most frequently consumed and important prey of seals and sea lions in the Columbia River at that time of the year (Beach et al. 1985; ODFW, WDW unpublished data). While some seals and sea lions do remove salmon from gillnets, free-swimming salmon constitutes a minor dietary component relative to Eulachon. A-47 254 DRAFT "However, almost 13 percent of the stomach contents of California sea lions taken in the Columbia River area in 1982 was salmon;. . . (Beach et al. 1985)" The report does not acknowledge that these samples were collected in an area where, and most often when, giilnet fisheries for salmon where taking place. There is no question that sea lions (and seals) prey on salmon in gillnets in this area. The resulting analysis of sea lion diets from such collections cannot be applied to sea lion numbers statewide to estimate salmon consumption over a broad geographic area because of the influence of this fishery on the diet of these species. The report notes that Jameson and Kenyon (1977) and Roffe and Mate (1985) showed that salmon made up a small part of sea lion diets and that predation had negligible impacts on Rogue River salmonid populations. It would also be invalid to use these studies to imply that sea lion predation has no affect on salmon numbers anywhere in the Northwest. 'Based on the above data, it would seem reasonable to assume that salmon could comprise... ocean commercial fishery in 1990. ' The calculations and consumption estimates presented in the report are not arrived at by defensible scientific methods. Because of the numerous assumptions and variables involved, the results presented are highly questionable and probably very inaccurate. For example, it is inappropriate to use predation estimates from a single study in British Columbia and broadly apply them to pinnipeds in completely different geographic areas where behavioral, biological, environmental and other factors affecting both predator and prey populations (including relative abundances) may be very different. Site specific studies are required to make valid estimates of this type. The calculations of salmonid loss to marine mammal predation are also affected by assumptions concerning salmonid (prey) availability. It cannot be assumed that salmon are available to every predator every day of the year (or every day that a pinniped is in Oregon waters). Nor can it be assumed that pinnipeds would selectively consume salmon when other more abundant, more easily caught and consumed prey are available (particularly for harbor seals). Many of the calculations in this report are based on the assumption that salmon are available to marine mammals 365 days of the year: estimated predation losses, therefore, likely over-estimate actual losses greatly. Other Marine Mammals ^pages 110-11 H This discussion mentions that several other marine mammal species have been known to consume salmonids at some time, but provides no information of the relevance of this fact to the decline of Oregon's wild salmonids. Of some 34 marine mammal species that occur in the northeastern Pacific, 10 have been known to consume salmon at some time (Fiscus 1980). In Oregon, less than five of these species have salmonids in their diets with any frequency. Three of those are the pinnipeds discussed previously. In geneial, marine mammals as a group are thought to have negligible effects on free-swimming salmon in the open ocean (Fiscus 1980). Killer whales are known to consume seals and sea lions, but the report only briefly mentions this fact. Certain groups of Orca are known to specialize on pinniped as A-48 255 DRAFT prey. Whereas the whales that feed mostly on salmonids tend to be resident of the northern Puget Sound and Vancouver Island area, these pinniped-eating whales are more migratory. It is suspected that the Orca observed regularly off the Oregon coast, and seasonally in coastal embayments, are part of these migratory, pinniped-eating groups. Consumption of pinnipeds by Orca has been observed at several Oregon locations in recent years. Marine Mammal-Fisheries Interactions Tpage 111) 'Thus, seal damage at this rate for the 1990 commercial catch. . . would have accounted for the loss of between 4,200 and 11, 200 fish from the fishery...' The rates of pinniped damage to gillnet caught salmon are misused in this analysis. The majority of fish in the studies referred to, while damaged (sometimes very slightly) were still salable, were sold by the gillnetters and thus were not "lost", and, therefore, carmot be compared to total commercial catches for the Columbia River. For example, less than one per cent of all fish caught in the Columbia River 1991 winter fishery were unsalable due to pinniped damage (Herczeg et al. 1991; ODFW unpublished data). This information contradicts the "three to eight percent" values that were broadly applied to the total annual Columbia River ^mon catches. 'They [Chapman et al. \99l] Jurther concluded that a total of 8, 100 fish had died as a result of these bites in 1990. . . " The report does not state how it was determined that 8, 100 fish "died" as a result of "seal marks". The information that was presented provides the reader no rationale for assessing the validity of this conclusion. However, the authors incorporate this estimate into their analyses without further discussion. This data, while attributed to issues related to Columbia River dams, also appears later in the report text and tables as "Oregon salmonid loss to seal bites". Summary rpaees 111-112) This section repeats the estimates of marine mammal predation and compares these estimates to fishery harvest statistics. These calculations are based upon simple mathematics, erroneous and misinterpreted data, and the erroneous assumptions identified in the previous portion of this review. The statistical significance of these estimates is likely to be very low, and, therefore, should not be compared to fishery harvest statistics that possess a much higher degree of accuracy. A-49 256 DRAFT "Because these marine mammal populations have been recently increasing. . .it is reasonable to assume that their consumption of salmonids has increased at a similar rate. ' It is not "reasonable", as stated in the report, to simply assume that the consumption of salmonids by marine mammals has increased at a rate similar to estimated increases in some of their population numbers. It is not scientifically valid to assume that there are simple, direct linkages between rates of population growth and rates of selected prey species consumption: predator-prey relationships are much more complex than this simple assumption portrays. '...it follows, then, that marine mammal predation has contributed to the receru decline in Oregon salmonid abundance. ' Contrary to this statement, it does not follow from the "data" presented in the report that marine mammal predation has contributed to the recent decline in Oregon sjdmonid abundance. This statement appears to be a conclusion of the authors that is not substantiated by the scientific information presented in the report. 'Seal and sea lion populations have been increasing in Oregon while salmonid fishery resources have been declining. " This statement is incorrect. The report does not present scientific information to suggest that a direct causal relationship exists between these two trends. While some seal and sea lion populations have increased, others have not; and while some salmonid populations have declined, others have not. It is impossible to prove that a direct causal relationship exists given the evidence providwl in this report. The complexity of salmonid declines has been linked to a variety of possible factors including freshwater habitat degradation, harvest, water diversion, dam construction, and other human activities. Given the multitude of possible factors, it is wrong to suggest that a direct causal relationship exists between these declines and marine mammal abundance. 'Presently, these marine mammals are consuming a higher proportion of salmonids than they did in the recent past. ' This conclusion is not supported by the scientific information presented in the report. A-50 257 DRAFT '...it is possible, ihough speculative, that if Oregon Indians in the past kept seal and sea lion populations low, then the present rate of marine mammal predation on Oregon salmonids may be at historically high levels. ' (emphasis added) As the authors' themselves state, it is speculation to suggest that Oregon Indians kept seal and sea lion numbers low. It could equally be true, and may be more likely, that pinniped numbers were higher before white men inhabited the west coast and began to hunt, harvest pinnipeds (including bounty harvest), harvest fish (pinniped prey) and alter freshwater fish habitat. Competition (page 1 15) Seals and Sea Lions (pages 115-116) This section of the report contains questionable calculations of prey consumption by pinnipeds; this time presenting pinnipeds as competitors with salmonids for herring. These questionable calculations suggest that by eating herring, Oregon pinnipeds are responsible for the loss of more salmonids than sportsmen caught in all Oregon coastal streams in 1990. The report continues to develop questionable estimates of salmonid losses because of dietary overlap between salmonids and other fish, pinnipeds, and birds. Questionable multipliers and energy conversion rates are applied to arrive at ambiguous and likely erroneous results. 'The point of this discussion is not to determine the degree of competition that salmonids experience in the ocean, but to draw attention to its existence and scope. ' The discussion does not provide the level of scientific accuracy necessary to evaluate the "scope" of these competitive interactions. These interactions are natural biological processes that have occuned for millions of years. No information is presented to document that these intenu:tions have increasied, or that these interactions are playing a significant role in the decline of Oregon's salmonids. 'And finally, the recent increases in pinniped populations suggest a commensurate increase in competition with salmonids to a level that did not exist in the recent past. This increase in competition could be contributing to the recent decline in the abundance of Oregon salmonids. ' As was discussed previously, the report does not provide any scientific evidence to conclude that marine mammal abundance has increased above natural historic levels, or A-Sl 258 DRAFT presented scientific studies that document increases in competition between salmonids and marine mammals. This conclusion is solely speculation. American Shad rpages 117-119): Competition for Food 'One obvious reason the American shad population has been increasing in the Columbia River system, while salmonids have been declining, is the absence of an intense fishery for the American shad as exists for salmonids. ' The increase in American shad numbers is unrelated to the fishery on them. If anything, the fishery on American shad has expanded as their numbers have increased. 'As stated previously in this chapter, the food base of the lower Columbia River has changed from a macrodetritus to a microdetritus source. * What are the references on this? 'Even if only one percent of the eggs produced viable young that migrated to the Columbia River estuary (the actual percentage is > probably much higher),.. . " The actual percentage is probably lower. Survival of eggs to postlarvae probably a small fraction of a percentage. I 'Juvenile American shad are a potential competitor with the juveniles of any pink. . . remaining in the system. . . ' As stated earlier, pink salmon are not indigenous to Oregon streams (Emmett et. al. J 1991). The inference that competition with shad is causing a "decline" of these species in Or^on is erroneous. A-52 259 DRAFT 'And even though the shad is primarily a plankton feeder, the overlap of beruhic prey in its diet and in the diets of other juvenile salmonids, such as Chinook salmon, coho salmon, and steelhead trout, provides ample evidence that competition is occurring, ..." This statement is not true. No conclusion can be drawn from overlap (it is unknown if food is limiting). The discussion of competitive interactions between American shad and anadromous salmonid juveniles is largely a hypothesis that the authors do not substantiate with scientific research. The major weakness in this argument is that the authors fail to document the extent of spatial and temporal overlap in estuary rearing habitat between these species, or demonstrate that food availability is limiting juvenile salmonid production in the Columbia estuary. The authors also fail to note that juvenile shad are a prey source of juvenile salmonids in rivers and estuaries (Emmett et al. 1991). An alternate hypothesis of this fact could conclude that the increased abundance of juvenile shad should have caused increased salmonid production because of an increased food supply (assuming that food supply is limiting salmonid production). Reduced Population Size Why is this subheading presented in the American Shad section? A-53 260 DRAFT RECOMMENDATIONS Management fpaye 123) 'Institute marine mammal (seal and sea lion) management" This is a vague and poorly thought out recommendation. While many would agree that limited actions to reduce pinniped predation on certain depressed fish stocks at localized sites would be desirable, the broader implications of the recommendation are not supported by the data. There is no evidence presented in the OFIC report to support the premise that population control or reduction of marine mammals would directly result in any real or measurable increases in Oregon salmonid populations. SUMMARY AND CONCLUSIONS Many of the previous comments concerning the presentation and interpretation of literature citations are pertinent to this section of the report as much of the report is repeated. For brevity, the Department has attempted to avoid repeating our comments in this portion of the review, and refer the reader to previous discussions. Manaflcment Factors (p. 128-139) Page 128, Historical Catch The following statement is inaccurate and unsubstantiated: Landings ofchinook salmon in southern Oregon ports doubled from a mean of 56.000 fish from 1971 to 1978. to a 1979 high of 107.000 fish. This was directly related to reduced spawner escapements of 47 percent from 1978 to 1979 (Rankel. 1980) ' The second half of this statement is not supported by escapement records for the two largest southern Oregon populations, the Rogue and Umpqua rivers (See Nicholas and Hankin 1988). The source for this statement (Rankel 1980) is not listed in the References. A-54 261 DRAFT Page 131, Escapement The following statements are inaccurate: Pape 131 and Table S-1: 'Overfishing is evident when one compares the survival rates to escapement for coastal coho salmon fiom the OPI ocean fishery from 1970 through 1983, which averaged 11 percent, to the 1984 through 1989 survival rates, which averaged 39 percent' The survival rates to escapement presented for coastal coho salmon here are incorrect. It appears that the authors mistakenly included catch, but not escapement, of Columbia River coho when they calculated these values. Based on the ODFW OCN database, average survival to escapement for 1970-83 was 25%, not 11%, and for 1984-89 was 58%, not 39% (text) or 26% (Table S-1?). Marked hatchery groups at Fall Creek Hatchery averaged 20% for the years 1978-83 and 38% for the years 1984-89 whereas marked groups from Salmon River Hatchery averaged 28.5% for the years 1979-83 and 48.5% for the years 1984-89. Page 132. and Fipure S-3: 'From the 1950s to the present, there is a significant downward trend in spawner escapements of coastal and Columbia River coho stocks ' The description of the trend in coho salmon spawners on the Oregon Coast and in the Columbia River is inaccurate. The declines began in the mid to late 1960s not the 1950s as claimed (See the ODFW Coho Plan Figures II C-5 & C-6). Page 133 and Figures S-4 and .<;-5! "...in each year that the escapement goal was not met, catch exceeded the escapemem goal by a factor of 2 to 5. In years when escapement goals were not met, catch of OCN coho salmon actually exceeded their escapement goal by factors of 0.54 to 1.37, not 2 to 5 as is stated. See the review of "Section 1.2.4. Spawning Escapement and Return to Rivers". It is not clear how Figure S-4 was derived. This figure is not present in PFMC (1991) as stated, and it is not possible that coastal coho were 2.5 million out of a 4 million OPI in 1976. The scale of Figure S-4 is about half what is needed, resulting in the impression that the difference between catch and total production is smaller than it really is. A-55 262 DRAFT 'Further, actual escapements year-to year are directly correlated with perceru survival from production to escapement for the same years (Figure S-5) This statement is false. Figure S-5 has the same errors in survival to escapement as discussed above for page 131 and Table S-1. A statistical test of the correct data demonstrates no relationship between the percent escapement from the fisheries and escapement. Harvest Rates fpaee 136): 'Forty to 60 percent harvest of wild salmonids is generally optimal for maximum sustainable yield,.. . ' The source for this statement is not stated. However, MSY harvest rates for OCN coho salmon have been estimated to be 61.8-72.8% (PFMC 1992, Table 1 and ODFW Coho Plan) not 40-60%. Actual ocean and river harvests for both chinook and coho salmon have ranged from roughly 70 to 90 percent... ' Except for one year, every year since adoption of the Coho Plan, harvest rates for coastal coho have been below 60%. F-nvirynmental Factors (p. 139-182) Page 139, Human-Influenced Biological Interactions Predation (pages 139-141) Predation and competition between naturally occurring species of fish and wildlife, including salmonids, are certainly "natural phenomena" but the report presents these relationships under the loosely defined category of 'human-ir0uenced biological interactions'. No scientific evidence was presented to support the contention that "human actions" have significantly changed overall marine mammal predation pressures on salmonids. Since there have been no measures of this "pressure" 100 years ago, 50 years ago, or even 10 years ago, it is not valid to suggest that such general predator-prey relationsriips and interactions in the majority of the habitat have changed. It is true that for specific fish stocks that have been depressed for reasons related to various human activities, and at sites where dams, ladders, water diversions or other human structures have restricted free movement of salmonids, pr^iation from pinnipeds can have significant impacts (e.g. Ballard Locks, Seattle). However, there is no information presented in the report that supports the premise that human actions have altered the A-56 263 DRAFT balance of the pinniped-salmon predator-prey relationship that has occurred in the open ocean for millions of years. 'Populations (marine mammals) have steadily increased in Pacific Nonhwest waters and these increased populations are now causing significant predation losses on anadromous salmonids. ' This statement is not supported by the scientific information or analyses presented in the repon. This statement appears to be an unsubstantiated conclusion of the authors. The scientifically questionable calculations of salmonid consumption by marine mammals are repeated within this section of the report. All the previous comments on the methodology employed, the assumptions inherent to these calculations, and the conclusions drawn from these analyses apply to this discussion also. Food Resources-Competition fp. 144-145) 'Assuming an eight percent efficiency of energy transfer, this could represent 850,000 pounds of salmon. ' This assumes 100% of herring not eaten by mammals is converted into salmon biomass. This is unlikely because salmon not limited by herring diet. Page 158, Agriculture General Comments This section is largely a repeat of the information presented on pages 76 through 86, and includes many of the same improper conclusions that were discussed previously. The only new information concerns reference to the Tillamook Bay "Erosion Sediment Study" which is discussed in both the agriculture and forestry sections of the summary. The Department has limited the discussion of this study to specific issues in the "agriculture" section, with a thorough analysis of the OFIC authors interpretation in the "forestry" summary review. Tillamook Bay Erosion Study (pages 160-162): [Please refer to the "forestry" section for a thorough review of this study] The authors discussion of this study (USDA-SCS, 1978) is incomplete. In addition. Table S-7 (page 160) appears inaccurate and does not correspond to information presented in the SCS re;>ort. A compilation and analysis of the information presented in the SCS rqx)rt is presented in Table 3: A-57 264 DRAFT Table 3. Estimates of annual erosion and sediment runoff into streams from agricultural lands in the Tillamook Bay Basin. Dau derived from 'Tillamook Bay Drainage Basin Erosion and Sediment Study, Oregon-Main Report" (USDA-SCS, 1978). Sediment Total Erosi<» Total Sediment Runoff /Erosion Subbasin Acres Tons Tons/ Acre Tons Tons/ Acre Ratio Miami 1.217 1431 1.18 1173 0.96 0.81 Kilchis 3.369 1948 0.58 1427 0.42 0.72 Wilson 4.124 2607 0.63 2018 0.49 0.78 Trask 10,697 4375 0.41 2752 0.26 0.63 Tillamook 9.375 3020 0.32 1441 0.15 0.47 BASIN 28.780 13.381 0.46 8812 0.31 0.67 This information is pertinent to the accuracy of text references: 'Total erosion averaged 0.6 tons/acre/year, 0.35 to 1.6 tons/acre/year range. Related stream sediment loading rates averaged 0.4 tons/acre/year. ' The Departments' calculations indicate that total erosion is estimated at 0.46 tons/acre/year, with a range of 0,32 to 1.18 tons/acre/year, and with sediment loading of 0.31 tons/acre/ year. More important, however, are the conclusions of the authors concerning the impacts of agriculture on sedimentation processes in Tillamook Bay: "Stream bank and channel erosion from cattle are serious sedimentation problems in the lower floodplain reaches of streams in the Tillamook Bay Basin (USDA, SCS. 1978). Ninety percent of stream sediments originating in these predominantly pasture lands come from stream bank and channel erosion sources. " 'Cattle move into channel bottoms... Banks and stream channel edges are broken down and direct sedimentation occurs. Subsequently in storm flows, stream bottom scour and constant bed gravel occur (ibid). ' This statement implies that sti^am bank erosion and the resultant sediment discharges are strictly a result of stream side catUe use. This statement ignores text from the SCS report which directly cautioned readers from making this assumption: "forest lands and croplands have been separated in the study for inventory and analysis. The two areas are not independent, however; upstream problems can either amplify or reduce downstream problems. The total sediment in the system is the crucial problem." The SCS study documented significant sediment loads originating from forest lands (51,603 tons/year), and that a high proportion (8 to 66 percent range) of this material was A-58 265 DRAFT fluvial bedload (large material). This material could have been accelerating the erosional processes in the downstream agricultural reach. The report also attributes the cattle-related sedimentation and stream bank erosion to the loss of pink and chum salmon populations: 'This could help amlain the loss of native pink and chum salmon populations in the lower reaches of coastal streams. ' (emphasis added) While we agree that sedimentation could have a role in the decline of Oregon's chum salmon populations, this statement is inaccurate for pink salmon in Oregon. Pink salmon are found in oceanic and coastal areas north of about 40° N latitude, and are not indigenous and only rarely observed in coastal streams of Oregon. The distributional range of this of this species is from approximately Skagit Bay, Washington, northward (Emmett et. al. 1991). Chemical Use. Agriculture and Forestry (page 164): The authors again present information (in a table on page 164) comparing the "ratios" of agriculture and forestry chemical use, only this time it is presented in the "agriculture" section. As discussed previously, this information greatly underestimates the use of chemicals on forest lands because it only includes chemicals applied on US Forest Service lands. The Department refers the reader to our previous discussion of this information. Page 165, Forestry General Comments There is no discussion of the effects of water temperature increases due to forest practices, and very little discussion of the effects of timber harvest on the instream supply of large woody debris. Significant amounts of scientific information exist for these topics. Again, there is no mention of the results of the Alsea Watershed Study (Moring 1975a, 197Sb; Moring and Lantz 1975) or the Carnation Creek Study (Hartman and Scrivener 1990; Holtby 1988) in this discussion of forestry. 'Logging slash. ..decreases dissolved oxygen demand. . . ' Logging slash increases dissolved oxygen demand (not decreases, as stated). The first paragraph on page 174 discusses sedimentation but give no specifics as to the relationships between forest practices and sedimentation, or sedimentation and salmonid A-59 266 DRAFT survival. The Alsea Watershed Study (Moring 1975a) documented increased sediment loading of 11-175% associated with logging and 54-205% associated with logging road building. Phillips et al.(1975) documented 80% reduction in survival of alevins with 50% fine sediment. Tillamook Bay Erosion Studv (pages 173-174): The authors use a portion of the information contained in the SCS report (USDA-SCS 1978) to imply that the agricultural industry is the primary contributor to sediment problems in the Tillamook Bay basin: 'Stream sediments from agriculture were twice that from forests in the Tillamook Bay drainage basin on a unit area basis (Table S-10). " "A significant difference between agricultural and forest stream sediment contribution was the relative amount of eroded materials that entered streams. In agriculture, 70 percent of eroded sediments become fluvial sediments; in forestry, however, only 20 percent become fluvial sediments. " These statements are based upon an incomplete discussion of the study, and ignore the contribution that sediments (particularly bedload material) from upstream areas can have on the acceleration of stream bank erosion in downstream reaches. The majority of the fluvial sediment originating from the agricultural lands was due to stream bank erosion (approximately 88 percent). The SCS report cautioned that: "forest lands and croplands have been separated in the study for inventory and analysis. The two areas are not independent, however; upstream problems can either amplify or reduce downstream problems." The SCS report further noted that terrestrial sources of sediment "...serves as an abrasive agent to increase the effectiveness of the flowing water as an erosive agent." The autfiors failure to recognize that upstream activities on forest lands may have affected stream bank erosion on agricultural lands results in conclusions that are not supported by the SCS study. An alternate analysis of the relative impact of each land use activity could be achieved by eliminating stream bank erosion from the total sediment estimates (Table 4): A-60 267 DRAFT Tmble 4. Estimates of sediment discharge into streams of the Tillamook Bay Basin resulting from upland erosion (stream bank erosion not included in this analysis). Data extracted from the SCS report 'Tillamook Bay Drainage Basin Erosion and Sediment Study, Oregon-Main Report' (USDA-SCS, 1978). Forest Land Non-Stream Sedimeat Agriculture Subbasin Acres Tons Tons/ Acre Acres Tons Tons/ Acre Miami Kilchis Wilson Trask Tillamook 24,290 43.320 121,110 101,940 33,570 1281 3003 5536 10981 4169 0.053 0.069 0.046 0.108 0.124 1217 3369 4124 10697 9375 59 126 144 397 370 0.048 0.037 0.035 0.037 0.039 BASIN 324,230 24,970 0.077 28,780 1.096 0.038 The SCS report noted that forestry is a significant contributor to the sediment problems in TiUamook Bay (USDA-SCS, 1978): "The total sediment in the system is the crucial problem. " "Erosion and sediment delivery rates on forest lands still make significant contributions to the problems of the basin. The mean annual gross erosion amounts to 286,245 tons. The mean annual fluvial [into the streams] sediment load is 51,602.6 tons from forest lands. These are 95.6 percent and 85.1 percent, respectfully, of the basin totals." The OFIC report failed to acknowledge these conclusions by the original authors. Regulations (page 175^: 'In 1972, forest practice rules began to slow down salmonid habitat and water quality degradation caused by forestry ope rations , and gradual improvemeru continued through 1986' This statement implies that logging is no longer a major cause of salmonid habitat degradation because of forest practices rules. On the contrary, data collected recently by ODFW Research and Development suggests that the productive potential for coho salmon of Deer Creek (Alsea Watershed Study stream - patch cut) has declined by 60% since 1966, whereas, the productive potential of Flynn Creek (uncut) has remained the same. A-61 268 DRAFT Agriculture (page 176): Again, according to the most recent data available from the U.S. Dq)artment of Commerce (1987 Census of Agriculture 1:37 Oregon State and County Data), there were 17.8 million acres of farmland in Or^on, not 28 million as stated here. Perhaps the difference here may be attributed to government grazing land leased on a per-head basis that is excluded from the Department of Commerce total, or perhaps the reference is to 2.8 million acres of harvested cropland. Who knows? Page 180, Natural Phenomena Climate and Catastrophes fP. 180-181): 'Storms of equal intensity will cause twice the erosion on agricultural lands as on forested lands (Sedell and Beschta 1991). ' As discussed previously, the source cited by the authors does not substantiate this statement. The contention that the research presented by Sedell and Beschta (1991) supports a differentiation between erosion rates on agricultural and manjiged forest lands appears to be a misinterpretation or misrepresentation of the scientific study by Hickin (1984). Ocean Productivity C?. 181-182): There is no discussion of the effects of temperature in non-El Nifio years {See Nickelson 1986). "...as ocean conditions changed with the development of the 1982-1983 El Nino. " The most recent series of years with poor ocean conditions actually began in 1976, upwelling was weak and a warming trend was apparent, well before the 1982-83 El Nino (McLain 1984; Nickelson 1986). 'There is a suggestion that native coastal coho salmon had more of a north-migrating tendency in the past than hatchery coho salmon, and were less affected by El Nino. . . ' The statement is not supported by the data presented in Fig. 1. 1-8, attributed to McKeman et al. (1950). The effects of the 1941 El Nifto are evident on the 1942 catch in all rivers. Natural Predation (p. 182): Lack of stream complexity resulting from l(^ing activities, especially log transport, probably contributes greaUy to predation in nvshwater. A-«2 269 DRAFT The following statement is not supported by data: 'It is likely that wild smolts are susceptible to murre predation. ' A study of murre predation in Coos Bay showed that, excq)t for the period during the summer when private hatcheries were releasing very large numbers of smolts, murres did not prey upon salmon (Daniel Varoujean, Coos Bay, Oregon, personnel communication, August IS^ - reports were pnxluc«l). REVIEW OF TABLES This section provides a review of a portion of the tables presented in the OFIC- sponsored report. The majority of the tables we reviewoj presented fishery harvest statistics. Page 200, Table 1.1-1. Life History of Native Oregon Salmonids This table provides a fiair representation of life histories of 10 species/runs. Five of the 50 life history cells in the table are in slight error. The stock status column denotes "declining" for all 10 species/runs: this is subjective and the table does not show how the determinations were made. The primary source for this table is the ODFWAVDF "Status Report, Columbia River Fish Runs and Fisheries, 1960-90." Yet the source citation says ODFW 1991a, which in the references is shown to be the Clackamas Subbasin Flan. This erroneous citation is rampant throughout the report. Page 201, Table 1.1-2. Historical Status of Major Runs of Columbia River Salmonids. This table is a synopsis of nine of the same 10 species/runs in Table 1.1-1. It shows eight or nine to be "decreasing" with fall chinook "Increasing." Several errors are presait in the "Notes" column. The primary source is ODFW and WDF (1991) which IS again erroneously cited. Page 202, Tabk 1.1-3. Columbia River Commercial Landings Chinook, Coho, Sockeye, Chum, and Steelhead since 1886. The primary source of 1866-1959 data is an NPPC "Compilation" rraort. The data for 1960-90 is from ODFW and WDF (1991). The data presented for 1938-59 agrees with ODFW data for chum salmon only. Data for 1960-90 contains three typos. Data for 1866-1937 was not verified. A-63 270 DRAFT Page 205, Table 1.1-4. Estimated Historical and Current Run Size of Columbia River Salmonids. This table purportedly reports historical and current run sizes of Columbia salmonids. However, the data presented in this table does not provide a valid comparison of trends. The data presented as "run sizes" for 1983, 1986, and 1990 only includes Columbia returns. The data for 1977 reports the total Columbia production (ocean catch and Columbia return). The data for the 1890's again only reports Columbia returns (this data set was developed prior to meaningful ocean salmon fisheries). These types of comparisons are not valid as presented. The following minor problems were also identified: (1) the Gunsolus citation misspells his name, and (2) the source for the 1983, 1986, and 1990 data is ODFW and WDF (1991) which is erroneously cited. Page, 206, Table 1.1-5. Brief Review of Historical Commercial Catch by Species of Columbia River Salmonids in Pounds and Numbers, 1866-1990. This table compares current year (1990) catches to low years, peak years, and initial year (1866). Data for current and low years is from ODFW and WDF (1991) (erroneously cited) and contains one error, several omissions, and several addition errors. Data for peak and initial years were not investigated. The "Source" reference lists ODFW 1971, which is not in the list of References, but which is probably FCO and WDF (1971): "Status Report-Columbia River Fish Runs and Commercial Fisheries, 1938-70". Page 207, Table 1.1-6. Incomplete Estimate of Sport Catches of Chinook Salmon from Tillamook Bay and Tributaries and Six Coastal Rivers, 1947-60. Data is this table was not investigated. The source is listed as Nichols and Hankin, 1989. This listing is not in the references. The references section does list a Nicholas and Haskin, 1989. Most probably the authors were referring to Nicholas and Hankin, 1988. Page 208, Table 1.1-7. Oregon Salmonid and Steelhead Trout Annual Tags Issued and Estimated Sport Salmon and Steelhead Trout Catch, 1978-90. This table lists number tags issued and salmon and steelhead catch by year from a report prepared by ODFW Fish Division, December 1991. There are several rounding errors in the table and the source is listed as ODFW, 1991a, which in previous tables has been actually referencing ODFW and WDF (1991). This report does not carry this data. The authors corrected an error in the Fish Division report. A-64 271 DRAFT Page 209, Table 1.1-8. Oregon Commercial Salmon and Steelhead Trout Catch 1978-1990. This table lists Columbia River (from ODFW and WDF 1991, erroneously cited) and ocean (PFMC 1991) salmon catch, and treaty Indian steelhead landings (from ODFW and WDF 1991, erroneously cited). There are three errors in the table. Page 210, Table 1.1-9. Columbia River Adult Salmonids Catch Numbers. This table lists the catch by species-run for commercial (lower river gill-net), sport (primarily lower Columbia), and treaty Indian (commercial and/or ceremonial and subsistence). The commercial landings are erroneous for five out of 17 entries. The sport landings listed are for lower Columbia main stem except fall chinook, which are basin-wide catches. Sport landings are erroneous for six out of 17 entries. Treaty landings are ceremonial and subsistence only for spring chinook and sockeye, which is correct as these were the only fisheries available to treaty frshers in 1990 yet the remaining landings are commercial only (ceremonial and subsistence is not included). One of the 17 entries is in error. The primary source is ODFW and WDF (1991) (erroneously cited). Page 211, Table 1.1-10. Current Status of Major Runs of Columbia River Salmonids. This table displays "Notes" relative to the current status of 15 species-runs of Columbia salmoriids. lliis table is deficient in that several runs of various species were not displayed and only mentioned in the "Notes" section. There are eight numerical errors and another error in the "Notes." There are estimates of the number of wild spawning coho in 1980, and in the present, that are not found in either of the sources listed. The primary source for this table is ODFW and WDF (1991) which is erroneously cited. Page 213, Table 1.1-11. Columbia River Commercial Landings of Salmon and Steelhead Below Bonneville Dam, 1960-90. This table is an accurate rqmiduction of Table 12 from ODFW and WDF (1991) though it is erroneously cited. A-65 272 DRAFT Page 214, Table 1.1-12. Number of Columbia River Gil (sic) Net Licenses Issued, 1960-90. Except for the title, this table is an accurate reproduction of Table 10 from ODFW and WDF (1991) though it is erroneously cited. Page 215, Table 1.1-13. Days Open to Commercial Main Stem Salmon Fishing Below Bonneville Dam, 1960-90. This table is an accurate reproduction of Table 11 from ODFW and WDF (1991) though it is erroneously cited. Page 216, Table 1.1-14. Columbia River Commercial Landings of Salmon and Steelhead Above Bonneville Dam, 1960-90. This table is an accurate reproduction of Table 15 from ODFW and WDF (1991) though it is erroneously cited. Page 217, Table 1.1-15. Days Open to Commercial Salmon Fishing Above Bonneville Dam, 1968-90. This table is an accurate reproduction of Table 14 from ODFW and WDF (1991) though it is erroneously cited. Pa^e 218, Table 1.1-16. Combined Oregon and Washington Angling Catch on the Lower Columbia River. This table is a reproduction of Table 3 from ODFWs "Lower Columbia River and Buoy 10 Recreational Fisheries" annual report for 1990 (Melcher and King, 1991). This t^le contains 14 errors when the authors mis-rounded exact numbers in ODFW's report to the nearest hundred. Page 219, Table 1.1-17. Combined Oregon and Washington Salmonid Angling Effect (sic) on the Columbia River, 1960-90. This table attempts to show the salmon catch per angler trip on the lower Columbia River. The authors use the word "Effect" in the title as a description of catch rate. This is a new term to us. The table is incorrect in that the authors have taken the total annual catch of salmonids and divided it by the annual totals for angler trips that not only included salmonid trip totals, but those for shad and sturpeon as well. In most recent years the annual totals for sturgeon angler trips has exceeded that for salmonids. This leads to more than a 50% under-estimate of "effect." Finally, the authors have used an incorrect annual salmonid catch total for 1979. A-66 273 DRAFT Page 220, Table 1.1-18. Sport Catch, in Numbers, of Salmon and Steelhead Trout in the Oregon Tributaries of the Columbia River, 1978- 90. This table lists catch estimates from ODFW's angler-returned salmon/steelhead catch record. There are four errors. Paee 221, Table 1.1-19. Buoy 10 Sport Effort and Catch of Pacific Salmon, 1982- 90. The data in this table is from Melcher and King (1991). There is one error. Page 222, Table 1.1-20. Current Status of Major Runs of Oregon Coastal River Salmonids. This table attempts to describe the status of Oregon's coastal salmon populations using three categories; decreasing, no trend, and improving. The status for several populations is labeled "unknown". Sources are Nicholas and Hankin (1989) (in list of References this source is Nicholas and Haskin, 1989); ODFW 1982 (Coho Plan); and ODFW 1985 (not listed in References). The following deficiencies were identified: The table's footnote states the table is laid out as in Nicholas and Hankin (1989) yet the authors did not follow that format. The status for Yachats chinook is not decreasing but is unknown. The "notes" for Trask and Tillamook chinook are wrong. In the coho section reference is made to 36 stocks, perhaps this actually refers to the 36 chinook stocks previously described. The coho section is extremely deficient in that all stocks are lumped together and given one status description~"decreasing." It is unknown to the reader which data in the table can be attributed to the three sources listed at table's end. Finally, the table title is misleading in that it says "....Status of Major Runs " The runs described in this table number from 100 to 100,000 fish. A-67 274 DRAFT Page 225, Table 1.1-21. Sport catch of Salmon and Steelhead Trout in Oregon Coastal Streams, 1978-90. This table lists catch estimates from ODFW's angler-returned salmon/steelhead catch record. There are four errors. Page 226, Table 1.1-22. Oregon Ocean Salmon Commercial Troll Landings and Effort, 1991 (sic)-90. This table is derived from PFMC's "Review of 1990 Ocean Salmon Fisheries." There are two errors. Additionally, the pink salmon catches for the 1970's uses two 5-year averages when the actual pink landings by year were easily available on an adjacent table in the PFMC report. Note the title says " 1991-90." The actual years are 1971- 90. Page 227, Table 1.1-23. Oregon Ocean Salmon Sport Catch and Effort, 1971-90. This table is derived from PFMC's 1990 report. There are no errors. As in the troll table, pink salmon catches for the 1970' s uses two 5-year averages when the actual pink catches by year were easily available on an adjacent table in the PFMC report. Authors used a 5-year average for 1976-80 angler trips and divided it into actual year by year catches to derive annual salmon/angler trip. The salmon/angler trip for these years are erroneous and likely not even similar to actual. These statistics should not have been shown. Page 228, Table 1.1-24. Indirect Causes of Mortality to Commercial and Sport Fisheries in Oregon for 1990. This table shows percentages and numbers of mortalities. The table headings do not say mortalities of what. The title suggests mortalities to fisheries. Assuming it is fish, three categories of indirect causes are listed. The authors refer the reader to the text "for expluiation." 1) Ocean Troll shaker loss - text explanation: '...an annual shaker morality (sic) value of between 30 and 40 percent seems appropriate for Oregon. ' The table lists 1990 harvest as 582,000. This figure is the total sport and commercial catch of Chinook and coho in Oregon ocean waters. Using the author's 30-40% that "seems appropriate" results in mortality numbers of 174,400 to 232,500 salmon in Oregon's ocean fisheries in 1990. PFMC estimates the 1990 commercial troll coho loss at 54,300, 21 % of the total catch Goss plus landed) of 259,200. PFMC accounts for troll hooking mortality in their catch-quota decision-making. There are no estimates for commercial troll chinook or sport fishery losses in the PFMC process nor does there seem to be a need to do this as losses from these fisheries are regarded as low. A-68 275 DRAFT 2) Columbia River gill-net dropout loss - text explanation: '...it seems reasonable to assume an annual dropout mortality rate of between 4 and 8 percent for the Columbia River commercial net fishery. ' The text explanation for these estimates were based on the Klamath River tribal fishery and the Puget Sound gill-net fishery. The table lists harvest as 257,000. This figure is the total commercial landings in the Columbia from Zones 1-5 gill-net, Youngs Bay terminal, and tribal set-net fishery above Bonneville Dam of all species including Indian-sold steelhead and includes all landings by Washington fishermen. There have been no studies on gillnet dropout in the Columbia. Gillnet dropout is believed by ODFW to be low and the mortality rate for dropped-out fish varies considerably by species, by gillnet type, and by time of year. 3) In-river sport loss - text explanation: '...it would be reasonable to assume a minimum loss rate of between three and nine percent for the in-river sport fisheries of Oregon. . . ' These estimates were based on steelhead studies conducted in British Columbia. Applying this study to Oregon's catch and release program for wild winter steelhead, ODFW reportedly assumes a loss of 3% using barbless hooks and 9% using barbed hooks, and assumes losses are higher for summer steelhead because of warm water and low flow. The table lists harvest as 241,000. This includes the sport catch in Oregon's coastal streams, Oregon's tributaries of the Columbia River, the Oregon and Washington catch in the lower Columbia, and Oregon and Washington catch in the Buoy 10 fishery. The majority of the catch in the Buoy 10 fishery is made by Washington anglers. This facet of the table is completely faulty in that it assumes the 241,000 catch is all released to later die at a 3-9% rate. In fact, the catch is all kept. Estimates of caught and released fish are not considered. Most caught and released fish are wild or unmarked hatchery steelhead (1,425 in 1990). The Buoy 10 fishery handles some sublegal salmon. A few Columbia Chinook are caught and released during the summer steelhead fishery mid- May to July. Applying "hooking mortality" estimates to harvest data firom fisheries which are not regulated as "catch and release", or where fish are not regularly released, is erroneous. Page 229, Table 1.1-25. 1990 Catch Numbers of Individual and Combined Oregon Salmonid Fisheries. The table lists the individual catch total of all of Oregon's salmonid fisheries in 1990 at 1,080,000 fish. The table is deficient in that it does not include the sport catch in Oregon's Columbia River tributaries (100,100 fish in 1990) as an entry; however, the 1(X),100 fish are included in the total. The authors have included the Washington catch in the Buoy 10 and main-stem lower Columbia sport fisheries. The Oregon and Washington cutthroat trout catch in the main-stem lower Columbia sport fishery is also included in this table. A-69 276 DRAFT J In the "Combined Fisheries" section of the table, the authors have separated catches into marine and freshwater and commercial and sport. The authors have included the Buoy 10 catch in the marine category. The states and PFMC separated the Buoy 10 fishery from the ocean in 1982 and since 1982 have considered it a freshwater " (Columbia) fishery. Page 230, Tables 1.2-1. to 1.2-4. The source for Tables 1.2-1, 1.2-3, and 1.2-4 is noted at the bottom of the tables as NPPC (Unpublished). The Department did not attempt to verify these tables. The source for Table 1.2-2 is noted as PNNC (Unpublished). The Department is not familiar with this acronym and it is not listed in Glossary. The Department did not attempt to verify this table either. Page 234, Table 1.2-5. Ocean Coast and Columbia River 1990 Salmonid Catch and Escapement Numbers. This table lists various species-runs of salmonids with total catch compared to escapement goals and actual escapement. A fifth column provides "Notes" relative to the results for each species-run. The table has two parts, Oregon Coast and Columbia River. This table has considerable problems. The "apples and oranges" comparison problem seen in some earlier tables is present here too. For example, in presenting data for wild coho salmon the total Oregon marine catch of all stocks of coho (hatchery and wild) is reported as 322, 3CX). This catch is then compared to an escapement goal of 161,000 (the 1990 goal for wild Oregon Coastal Natural coho) and an actual escapement number of 68,600 which again is OCN coho. The actual harvest of wild coastal coho was 171,100 (not 322,300), and the escapement was 104,200 (not 68,600, a preliminary estimate by PFMC (1991)). Hatchery coho harvest should not have been included in these estimates. These comments are also pertinent to errors discovered in Table 1.2-8. The "apples and oranges" comparison problem also applies to data for Orcjgon Coast Chinook and several Columbia species-runs. However, for Columbia species-runs it is difficult for us to determine which are "apples" and which are "oranges" as there are so many errors in the data presented. For example, total catch is listed for 17 Columbia species-run. Of the 17 entries, seven listings are correct and 10 are incorrect. Some of the errors list catches 600% higher than actual. This table lists 1990 escapement goals for three coastal and 17 Columbia species-runs. Three Columbia goals are incorrect. In the listings of actual escapements versus goals there are seven errors for the 17 Columbia species-runs. Several of the notes offer erroneous information. Even the column listing species-run is in error in that the authors have assumed all upriver spring and summer chinook and upriver bright fall chinook are wild. In fact the majority of upriver spring and summer chinook are hatchery produced. Other errors are also present. There is no mention of Columbia River hatchery summer steelhead returns. This species-run has performed well recentiy with some returns exceeding 300,000 annually. Coastal hatchery coho is also not mentioned. There are indentation problems in the column for species-run leading to reader A-70 277 DRAFT confusion. The sources include ODFW and WDF (1991) (erroneously cited) and ODFW (1992) not listed in References. Page 235, Table 1.2-6. Summary of 1990 Oregon Salmon Escapement Goals, Compliance for the Major Coastal lUvers and Columbia River Stocks, and Compliance Status of Eight Wild Salmon Stocks. This is a two-part table. The first part is a summary for salmon only (does not include steelhead) from the previous table. This table shows eight salmon stocks met the escapement goal and six did not meet the goal. With all the problems we listed earlier for Table 1.2-S we have no confidence at all in the accuracy of information displayed here. The second part of the table is more clear in that * 1990 Wild Salmon Stock Escapement Compliance" is rated under headings of "goal met" or "goal not met. " Under the headings are listed the species-runs. The ratings are accurate for 1990 for seven categories. However, for three of the seven we point out the species-runs listed are not wild but are a combination of hatchery and wild fish. The eighth category is Snake River spring Chinook and it is listed as "goal not met." The Department certainly concurs but points out that this category is double-counted in that it is a component of upper Columbia spring chinook and that category is also listed as "goal not met." It is the extremely low level of the Snake River component that causes the upper Columbia spring Chinook category to fall into "goal not met." Page 236, Table 1.2-7. Oregon Coastal Fall Chinook Index. This table continues the "apples and oranges" comparison observed in previous tables in that it shows Oregon coastal chinook catch (ocean sport and commercial catch and, since 1978, tributary sport spring chinook catch - the authors probably intended to include the tributary sport fall chinook catch) compared to esc^ment based on adults per mile from stream surveys. The spawning escapement data is an accurate reproduction of Table B-12 from the 1990 "Review Report" from PFMC. The "apples and oranges' comes into play in that north-migrating Oregon coastal fall chinook comprise a very small percentage of Oregon's ocean chinook catch. Furthermore to include coastal tributary spring chinook catch as a factor in whether Oregon's coastal fall chinook escapement goal is met is wrong. Page 237, Table 1.2-8. Estimated Total Escapement and Goals of Oregon Coastal Coho Salmon and Total Freshwater and Ocean Catch of ' Sport and Commercial Fisheries, 1971-90. This table lists total ocean catch and coastal tributary sport catch of hatchery and wild coho compared to the Oregon Coastal Natural (OCN) escapement. The escapement is compared to the goal to determine a yes or no annually if the goal was met. It is not clear where th^e catch estimates were derived as they do not resemble those presented in PFMC (1991), Table 111-4. These estimates appear to be inflated if they are intended to rqnesent the catch of wild coastal coho. A-71 278 DRAFT A comparison of the total coho catch to OCN escapement is irrelevant in that the majority of the ocean catch is comprised of Columbia River hatchery stocks. A relevant comparison would be the ocean and coastal tributary catch of OCN compared to OCN escapement. These data problems were also identified and discussed for information presented in Table 1.2-5. Page 238, Table 1.2-9. Numbers of Upriver Wild Spring Chinook Salmon Adult Catch and Estimated Escapement for the Columbia River, 1970-90. The intent of this table is to display Columbia River wild spring chinook runs relative to the escapement goal. Catch is also displayed. All the data shown are combined hatchery and wild spring chinook. There are four typos and one error in the data. Furthermore, the escapement number for 1971-90 is compared to a goal established in the mid-1980's. This comparison then yields a "Yes or No" determination if the goal was met. The error (1986) yielded an inaccurate determination. The escapement goal used for determination (115,000) is the combined hatchery and wild goal. Considering earlier escapement goals, several of the "No's" for earlier years would be "Yes." The source for the data is ODFW and WDF (1991), erroneously cited. Page 239, Table 1.2-10. Numbers of Upriver Wild Summer Chinook Salmon Adult Catch and Estimated Escapement for the Columbia River, 1970-90. This table suffers from many of the same problems as the previous table. The data presented is for the hatchery and wild components combined. The authors have listed the correct hatchery and wild goal and their determination if "Yes" or "No" for goal met are all correct. However this 100% correctness rate is nearly magical considering there are 16 data errors in the table. The source is ODFW and WDF (1991), erroneously cited. Page 240, Table 1.2-11. Number of Lower River Wild Fall Chinook Adult Catch and Estimated Escapement for the Columbia River, 1980- 90. This table lists catch, escapement, and whether goal was met. The table is an accurate reproduction of Table 38 from ODFW and WDF (1991) but is not listed as the source. The curious thing about this table compared to the previous two is that all of the data is correct, but a fictitious escapement goal is used by the authors for comparison. This goal is three times the actual goal. Using the correct goal yields "Yes" for all years under the "Met" column. A-72 279 DRAFT Page 241, Table 1.2-12. Numbers of Upriver Wild Fall Chinook Salmon Adult Catch and Estimated Escapement for the Columbia River, 1971-90. This table compares Columbia upriver bright fall chinook catches and escapement and determines annually if the escapement goal has been met. The authors have erroneously assumed all URB are wild. Data is from PFMC's 1990 "Review Report." There are two errors in the data presented. The escapement goal used to compare to escapements beginning in 1971 was established in the early 1980's. Page 242, Table 1.2-13. Numbers of Upriver WUd Sockeye Salmon Adult Catch and Estimated ELscapement for the Columbia River, 1970- 90. This table (similar to the previous four) lists sockeye catch and escapement and compares it to a goal (a goal that was established in the early 1980" s). This table is an accurate reproduction of 1970-90 data from Table 41 in ODFW and WDF (1991), erroneously cited. To compare 1970's data to an early 1980's goal does not make much difference in this situation as the 1970's sockeye returns in most years were below fishable levels even under the 1970's goal. Page 243, Table 1.2-14. Estimated Harvest Rates for Selected Oregon Adult Salmonids, 1961-90. This table attempts to show total fishery harvest rates on total Columbia coho (early and late stock combined), lower river wild fail chinook, and upriver bright fall chinook production. It should be noted that the table is titled "Oregon Adult Salmonids"; however, over half of the Columbia River coho originate in Washington as does the vast majority of lower river wild and upriver bright fall chinook. The Department checked the harvest rates using ODFW's data sources: 7. Ocean harvest rates for coho; 1961-69 Did not investigate 1970-89 Agree for 1 1 years and for the remaining 9 years disagree, but only by .01 each year 1990 ODFW estimates .61 8. Columbia River coho; 1961-69 Did not investigate 1970-89 Agree for 17 yean and for the remaining 3 years disagree, but only by 0. 1 each year 1990 ODFW estimates .45 9. Total coho l%l-69 Did not investigate 1970-89 Agree for 19 vean and for the remaining year disagree, but only by .()1 A-73 280 DRAFT 1990 ODFW estimates .79 The coho total harvest rate estimates assumes there is a direct 1:1 transfer of adult coho from the ocean to the river and no natural mortality occurs. 10. Ocean chinook salmon < The Department did not verify 11. Lower river fell chinook (river) 1980-90 Agree for 8 of the 1 1 years 12. Lower river fall chinook (total) 1980-90 ODFW disagrees 13. Upper river fall chinook (river) 1970-90 Agree for only S of the 20 years and only if dam passage loss is not a factor 14. Upper river fall chinook (total) 1970-90 ODFW disagrees The Department disagrees with the method the authors used to calculate the chinook total production harvest rates. Their method is flawed in that no adult equivalency factor was applied to the ocean catches to make them relative to the return to the Columbia 0-3 years hence if the fish were not caught. Page 244, Table 1.2-15. Oregon Provisional Anadromous Salmonid Population Summaries. This table is an accurate reproduction of a table from ODFW's Wild Fish Management Policy-Biennial Report presented to the Oregon Fish and Wildlife Commission in January 1992. The auUiors list the source as ODFW (1992), but it was not included in the References. Page 259, Table 2.2.7-3 Estimated Adult Salmonids Consumed by Seals and Sea Lions in Oregon Waters, 1990. The estimated losses of salmonids from marine mammal predation presented in this table are likely to be highly erroneous. This table is simply a set of roughly estimated numbers multiplied by more roughly estimated numbers, and so on. The assumptions inherent to these calculations are questionable: for example, it can not be assumed that a pinniped would eat 2.S lb. of salmon per day for 36S days; it is incorrect to assume A-74 281 DRAFT that salmon are available to all pinnipeds each day of the year; etc.. In addition, the outcome of these calculations can be altered significantly by changing a few of the estimates slightly. For example, there are probably a lot more than 200 California sea lion over-winter migrants and more "resident" northern sea lions. Increasing these numbers would increase the estimated consumption and alter the percentages given. On the other hand, if more accurate consumption rates for Steller sea lion sex and age classes were used, the estimated consumption for this species would decline. These types of estimates are very inaccurate and imprecise. A wide range of desired outcomes could be achieved depending upon the information used, and the assumptions incorporated into the analysis. Extreme caution should be used when comparing these estimates to "hard* estimates such as commercial fishery landing data. REVIEW OF HARVEST FIGURES The review of the figures presented in the report was primarily limited to figures presenting fishery harvest information. Figures not discussed in this section were not verified for accuracy. Page 265, Figure 1.1-1. Lower Columbia River Landings of Chinook Salmon. This figure appears to be an accurate representation of chinook landings in pounds for the entire Columbia (Indian and non-Indian) commercial fishery. However, the title of the figure is misleading in that it says lower Columbia (indicating below Bonneville Dam). Also, the title does not indicate these are commercial landings only. Three sources are cited; however, only two are listed in the References. Plage 265, Figure 1.1-2. Lower Columbia River Landings of Sockeye Salmon. This figure has many problems. The intent is to show total Indian and non-Indian commercial landings from the entire Columbia. Similar to Figure 1.1-1 the title does not say this. Both axis are mis-labeled. The y-axis is supposed to be millions of pounds and it is graduated from 0 to 50 million (a 10-fold exaggeration). Clearly, it should be graduated from 0 to 5 million. This is a very critical feature of the figure in that it portrays an image of historic landings plummeting from 40-50 million pounds annually to 0 in the present. Compounding the problem is that the authors failed to mention there had been no commercial sockeye fishery in 12 of the last 18 years. Additionally, the authors display landings for the early years that do not agree with our records. On the x-axis the early years do not match the peak catch years as we know them and a typo exists for 1900. In addition, three sources are cited; the first is accurate and listed in References, the second is not listed in References, and the third (as was the case for this source in many of the harvest tables) is erroneously cited in that it refers to the Clackamas Subbasin Plan, when in fact the data is from ODFW and WDF (1991). This error is carried through on many of the following harvest figures. A-75 282 DRAFT Page 266, Figure 1.1-3. Lower Columbia River Landings of Steelhead Trout. This figure has the same title and source errors as Figure 1.1-2. The data for the early years do not agree with our records. The figure does not state that steelhead landings by non-Indians have b^n prohibited since 1975. Page 266, Rgure 1.1-4. Lower Columbia River Landings of Coho Salmon. This figure has the same title and source errors as Figure 1.1-2. The data for the early years match up reasonably well with our records. It appears the x-axis (years) is off slightly. Page 267, Figure 1.1-5. Lower Columbia River Landings of Chum Salmon. This figure has the same title and source errors as Figure 1.1-2. The data for the early years match up reasonably well with our records. It appears the x-axis (years) is off slightly. Page 267, Figure 1.1-6. Lower Columbia River Total Landings of All Salmonids. This figure has the same title and source errors as Figure 1.1-2. The data for the early years match up reasonably well with our records. Similar to the previous figures it appears the x-axis (years) is off slightly. Page 268, Figure 1.1-7. Steelhead Trout Oregon Coastal River Landings. Data trends match our records, but the y-axis scale seems to be off approximately 100,000 pounds. This figure shows landings declining steadily to near 0 in the late 1940' s. The decline is primarily the result of season closures, which prevented fishing for steelhead. This should be acknowledged by the authors. Page 269, Figure 1.1-8. Trends of Salmon Populations in Oregon. This figure is a perfect tracing of Figure 3 in McKeman, et. al. 1950. Unlike McKeman et. al.'s footnote, the authors misspelled deviation. In the References, McKeman, et. al. is wrongly attributed to transactions from a "conference." A-76 283 DRAFT Page 270, Figure 1.1-9. Columbia River Commercial Indian Catch of Salmon and Steelhead Trout. This figure is an accurate depiction of the treaty commercial landings. The source is ODFW and WDF (1991), but once again the citation is erroneous. Page 270, Figure 1.1-10. Columbia River Commercial Landings of Salmon and Steelhead Trout. This figure is an accurate depiction of percentage catch by Indians and non-Indians. The source is ODFW and WDF (1991), erroneously cited. Page 271, Figures 1.1-11, 1-1-12, and 1-1-13. Pacific Coast Annual Landings of Troll Caught Salmon. Annual Troll Chinook Landings by Area; Annual Troll Coho Salmon Landings by Area. The Department could not verify these tables as the source (PSFMC, 1990) is not listed in the references. A-77 284 DRAFT LITERATURE CITED Andrus, C.W., B.A. Long, and H.A. Froehlich. 1988. Woody debris and its contribution to pool formation in a coastal stream 50 years after logging. Can. J. Fish. Aquat. Sci. 45:2080-2086. Beidler, W. M., and T. E. Nickelson. 1980. An evaluation of the Oregon Department of Fish and Wildlife standard spawning fish survey system for coho salmon. Oregon Department of Fish and Wildlife, Fish Division Information Report 80-9, PorSand. Beschta, R.L., R.E. Bilby, G.W. Brown, L.B. Holtby, and T.D. Hofstra. 1987. Stream temperature and aquatic habitat: fisheries and forestry interactions. In: Streamside Management: Forestry and Fishery Interactions. College of Forest Resources, University of Washington, Seattle, Washington. Bilby, R.E., and J.W. Ward. 1989. Changes in characteristics and function of woody debris with increasing size of streams in western Washington. Trans. Am. Fish. Soc. 118:368-378. Bilby, R.E. 198 1 . Role of organic debris dams in regulating the export of dissolved and particulate matter from a forested watershed. Ecology 62(5): 1234-1243. Bisson, P.A., T.P. Quinn, G.H. Reeves, and S.V. Gregory. 1992. Best management practices, cumulative effects, and long-term trends in fish abundance in Pacific Northwest river systems. In: Watershed Management, R.J. Naiman, ed., pp 189-232. Bisson, P. A., R.E. Bilby, M.D. Bryant, C.A. Dolloff, G.B. Grette, R.A. House, M.L. Murphy, K.V. Koski, and J.R. Sedell. 1987. Large woody debris in forested streams in the Pacific Northwest: past, present and future. In: Streamside Management: Forestry and Fishery Interactions. College of Forest Resources, University of Washington, Seattle, Washington. Brown, G.W., G.W. Shank, and J. Rothacher. 1971. Water temperature in the Steamboat drainage. USDA Forest Service, Pac. NW For. and Range Exp. Sta., Portland, Oregon, Res. Paper PNW-119. Brown, L.R., and P.B. Moyle. 1981. The impact of squawfish on salmonid populations: a review. N. Am. J. of Fish. Management 1:104-111. Bustard, D.R., and D.W. Narver. 1975. Aspects of the winter ecology of juvenile coho salmon (Oncorhynchus kisutch) and steelhead trout (Salmo gairdneri). J. Fish. Res. Board Can. 32:667-680. Carlson, CD., G.M. Matthews, D.E. Weitkamp, R.P. Whitman, R. Raleigh, and D. Chapman. 1989. Fish transportation studies. Priest Rapids Dam 1988, Annual report. Public Utility District No. 2 of Grant County, Ephrata, Washington. ChUcote, M., C. Dale, K. Kostow, H. Schaller, and H. Weeks. 1992. Wild fish management policy biennial progress report. Oregon Department of Fish and Wildlife, Fish Division, Portland, Oregon. A-78 285 DRAFT Cleaver, F.C. 1951. Fisheries statistics of Oregon. Oregon Fish Commission. Contribution No. 16. 176 pp. Portland, Oregon. Columbia Basin Fish and Wildlife Authority (CBFWA). 1990. Integrated system plan for salmon and steelhead production in the Columbia River basin, public review draft. Portland, Oregon. Craig, J. A., and R.L. Hacker. 1940. The history and development of the fisheries of the Columbia River. Bulletin of the United States Bureau of Fisheries. No. 32:133-216. Washington DC. Duston, J., R.L. Saunders, and D.E. Knox. 1991. Effects of increases in freshwater temperature on loss of smolt characteristics in Atlantic salmon (Salmo salar). Can. J. Fish. Aquat. Sci. 48:164-169. Emmett, R.L., S.L. Stone, S.A. Hinton, and M.E. Monaco. 1991. Distribution and abundance of fishes and invertebrates in west coast estuaries. Volume II: species life history summaries. ELMR Rep. No. 8. NOAA/NOS Strategic Environmental Assessments Division, Rockville, MD, 329 p. Fiscus, C.H. 1980. Marine numimal-salmonid interactions: a review. In: Salmonid Ecosystems of the North Pacific, W.J. McNeil and D.C. Himsworth, editors. Oregon State University Press, Corvallis, Oregon, pp. 121-131. Fish Commission of Or^on and Washington Department of Fisheries (FCO and WDF). 1971. Status report-Columbia River runs and commercial fisheries, 1938-70. Vol.1, No. 1. 87 pp. Clackamas, Oregon and Olympia, Washington. Hartman, G. F., and J. C. Scrivener. 1990. Impacts of forestry practices on a coastal stream ecosystem, Carnation Creek, British Columbia. Canadian Bullitin of Fisheries and Aquatic Sciences 223, Ottawa. Heifetr, J., M.L. Murphy, and K.V. Koski. 1986. Effects of logging on winter habitat of juvenile salmonids in Alaskan streams. N. Am. J. Fish. Management 6:52-58. Hercz^, B.A., B.L. Troutman, A.L. Ashenfelter, and M.S. Tork. 1992. Final report on the 1991 winter Columbia River salmon gillnet fishery. Unpublished. Oregon Department of Fish and WildlifeAVashington Dqxartment of Wildlife, contract r^rt to National Marine Fisheries Service, Seattle, Washington. Hicks, B.J., J.D. HaU, P. A. Bisson, and J.R. Sedell. 1991. Responses of salmonids to habitat changes. In: Influences of Forest and Rangeland Management on Salmonid Fishes and their Habitats, W.R. Meehan, editor. American Fisheries Society Publication 19: 483-518, Bethesda, MD. Hold)y, L.B. 1988. Effects of logging on stream temperatures in Carnation Creek, British Columbia, and associated impacts on the coho salmon (Oncorhynchus kisutch). Can. J. Fish. Aquat. Sci., Vol 45: 502-514. A-79 Afi— 1epartment of Fish and Wildlife, Fish Division Information Report 88-1, Portland. Nickelson, T.E.,J.D. Rodgers, S.L. Johnson, and M.F. Solazzi. 1992. Seasonal changes in habitat use by juvenile coho salmon (Oncorhyncus kisutch) in Oregon coastal streams. Can. J. Fish. Aquat. Sci. (in press). Nickelson, T. E. 1986. Influences of upwelling, ocean temperature, and smolt abundance on marine survival of coho salmon {Oncorhynchus kisutch) in the Oregon Production Area. Canadian Journal of Fisheries and Aquatic Sciences 43:527-535. Nickelson, T. E., M. F. Solazzi, and S. L. Johnson. 1986. Use of hatchery coho salmon {Oncorhynchus kisutch) presmolts to rebuild wild populations in Oregon coastal streams. Canadian Journal of Fisheries and Aquatic Sciences 43:2443- 2449. Norris L.A., H.W. Lorz, and S.V. Gregory. 1991. Forest chemicals. In: Influences of Forest and Rangeland Management on Salmonid Fishes and their Habitats, W.R. Meehan, editor. American Fisheries Society Publication 19: 207-296, Bethesda, MD. Northwest Power Planning Council (NPPC). 1987. Columbia River basin fish and wildlife program, amended February 11, 1987. Northwest Power Planning Council, Portland, Oregon. 246 pp. Oregon Department of Environmental Quality (ODEQ). 1988. 1988 Oregon Statewide Assessment of Nonpoint Sources of Water Pollution. Oregon Department of Environmental Quality, Water Quality Division, Portland, OR. Oregon Dei»rtment of Environmental Quality (ODEQ). 1990. Oregon 1990 Water Quidity Status Assessment Report, 305b Report. Oregon Department of Environmental Quality, Portland, OR. Oregon Department of Fish and Wildlife and Washington Department of Fisheries (ODFW and WDF). 1991. Status report-Columbia River fish runs and fisheries, 1960-90. 154 pp. Clackamas, Oregon and Battle Ground, Washington. Oregon Dqwrtment of Fish and Wildlife (ODFW). 1986. Steelhead management plan, 1986-1992. Oregon Department of Fish and Wildlife, Portland, Oregon. Oregon Department of Fish and Wildlife (ODFW). 1982. Comprehensive plan for production and management of Oregon's anadromous salmon and trout, part II., coho salmon plan. Ch^gon Department of Fish and Wildlife, Fish Division, Portland, Oregon. Oregon Department of Fish and Wildlife (ODFW). Unpublished data: Marine Mamnud Project data files, located at the ODFW Marine Region Office, Newport, Oregon. A-81 288 DRAFT Pacific Fisheries Management Council (PFMC). 1992. Oregon coastal natural coho review team report: An assessment of the status of the Oregon coastal natural coho stock as required under the definition of overfishing. Pacific Fisheries Management Council, Portland, Oregon. Pacific Fisheries Management Council (PFMC). 1991. Review of 1990 ocean salmon fisheries. Pacific Fisheries Management Council, Portland, Oregon. Pacific Salmon Commission (PSC). 1987. Chinook Technical Committee report to the November, 1987 meeting of the Pacific Salmon Commission. Report TCCHINOOK (87)-5. October 23, 1987. Phillips, R. W., R. L. Lantz, E. W. Claire, and J. R. Moring. 1975. Some effects of gravel mixtures on emergence of coho salmon and steelhead trout. Transactions of the American Fisheries Society 104:461-466. Poe, T.P., H.C. Hansel, S. Vigg, D.E. Palmer, and L.A. Prendergast. 1991. Feeding of predaceous fishes on out-migrating juvenile salmonids in John Day Reservoir, Columbia River. Trans. Am. Fish. Soc. 120:405-420. Rieman, B.E., R.C. Beamesderfer, S. Vigg, and T.P. Poe. 1991. Estimated loss of juvenile salmonids to predation by northern squawfish, walleyes, and smallmouth bass in John Day Reservoir, Columbia River. Trans. Am. Fish. Soc. 120:448-458. Ringler, N.H., and J.D. Hall. 1975. Effects of logging on water temperature and dissolved oxygen in spawing beds. Trans. Am. Fish. Soc. 104(1): 111-121. Robison, G.E., and R.L. Beschta. 1990. Characteristics of coarse woody debris for several coastal streams in southeast Alaska, USA. Can. J. Fish. Aquat. Sci. 47:1684-1693. Sedell, J.R., and R.L. Beschta. 1991. Bringing back the "bio" in bioengineering. In: Fisheries Bioengineering Symposium, J. Colt and R.J. White, editors. American Fisheries Society Symposium 10: 160-175, Bethesda, MD. Solazzi, M. F. 1984. Relationships between visual counts of coho, chinook, and chum salmon from q>awning fish surveys and the actual number of fish present. Oregon Department of Fish and Wildlife, Fish Division Information Report 84-7, PorUand. Solazzi, M. F., T. E. Nickelson, and S. L. Johnson. 1991. Survival, contribution, and return of hatchery coho salmon (Oncorhynchus kisutch) released into freshwater, estuarine, and marine environments. Canadian Journal of Fisheries and Aquatic Sciences 48:248-253. Ursitti, V.L. 1990. Riparian vegetation and abundance of woody debris in streams of southwestern Oregon. Masters Thesis, Oregon State University, Corvallis, Oregon. U.S. Department of Agriculture-Soil Conservation Service (USDA-SCS). 1978. Tillamook Bay drainage basin erosion and sediment study, Oregon. Main Report. Portland, OR. A-82 289 DRAFT Van Hyning, J. 1973. Factors affecting the abundance of fall chinook salmon in the Columbia River. Fish Commission of Oregon, Research Report 4(1): 1-87. Portland, Oi^on. Vigg, S. 1988. Functional response of northern squawfish predation to salmonid prey density in McNary tailrace, Columbia River. In: Predation by resident fish on juvenile salmonids in John Day Reservoir, 1983-1986. T.P. Poe and B.E. Rieman, editors. Pages 174-207. Final Report (contracts DE-AI79-82 BP34796 and DE-AI79-82BP35097) to Bonneville Power Administiation^ Portland, Oregon. Washington Department of Fisheries and Oregon Department of Fish and Wildlife (WDF and ODFW). 1992. Stahjs report-Columbia River fish runs and fisheries, 1938-91. 224 pp. Battle Ground, Washington and Clackamas, Oregon. Wood, C.C. 1987a. Predation of juvenile Pacific salmon by the common merganser (Mergus merganser) on eastern Vancouver Island. I: Predation during the seaward migration. Can. J. Fish. Aquat. Sci. 44:941-949. Wood, C.C. 1987b. Predation of juvenile Pacific salmon by the common merganser (Mergus merganser) on eastern Vancouver Island. II: Predation of stream- rcsidont juvenile salmon by merganser broods. Can. J. Fish. Aquat. Sci. 44:950-959. A-83 290 Coordinated Tribal Water Quality Program A Proposal Submitted To The United Stmes Congress And United States Environmental Protection Agency By The Federally Recognized Indian Tribes In Washington Slate 291 Table Of Contents Executive Summary 1 Introduction '. 4 Tribal Water Quality Concerns '. 9 Program Framework: Roles And Responsibilities , 12 Tribal Governments 14 Regional And Watershed Coordination 15 Statewide Coordiriation , 16 Program Implementation Schedule.., 17 Stages In Detail 18 Appendices Appendix A; Program Accomplishments: FY 91 .-. 24 Appendix B: Excerpts From The United States Of America National Report To The United Nations Conference On Environment And Development 32 Figures And Tables Program Design And Implementation Schedule 3 Indian Tribes In Washington State..; 10 Reservation Sizes/Popuiations 11 Staging Within The Coordinated Tribal Water Quality Program 23 For More Information Contact: Northwest Indian Fisheries Commission 6730 Martin Way E., Olympia, WA 98506 (206)438-1180 Covw Art By Pan Thompson 292 Executive Summary: To address water quality issues affecting their reservation and off-reservation re- sources, the federally recognized tribes in Washington state have developed the Coordinated Tribal Water Quality Progrtun. The program, currently in Stage D of development, will address water quality issues through a cooperative watershed approach. Western Washington tribes that took part in the program's development are the Chehalis, Hoh, Jamestown S'Klallam, Lower Elwha Klallam, Lummi, Makah, Muckieshoot, Nisqucilly, Nooksack, Port Gamble S'Klallam, Puyallup, Quileute, Quinault, Sauk-Suiattle, Shoalwater Bay, Skokomish, Squaxin Island, Stillaguamish, Suquamish, Swinomish, Tulalip and Upper Skagit. All of these tribes, except for the Chehalis, Shoalwater Bay cind Hoh, cu« members of the Northwest Inditin Fisheries Commission. Eastern Washington tribes that took part in developing the program are the Colville, Kedispel, Spokane cind Yakima. Together these tribes have recognized management and co-management rights that extend to nearly all of the main water- sheds and marine waters in Washington state. The need for new approaches to water quality problems stems from a simple fact: Water pollution threatens survival of the fish, wildlife and other natural resources on which the tribes depend, endjingering the economic and cultural core of tribeil life. The tribes feel these issues must be resolved cooperatively and in partnership with federal, state and local governments rather than through litigation. The tnbes in Washington state are dependent on clean water for the natural resources that are the basis of our cultural, economic arxj spiritual health. The Coordinated Trita! Water Quality Program represents our tiest efforts to develop a statewide tribal water quality program that will allow us to successfully address the many water quality problems tftat we confront' - Bll Frank, Jr., Chairman, Northwest Indian Fisheries Comnrission The Coordinated Tribal Water Quality Program is built upon four flexible, interconnected stages that are driven by funding, not by time. The stages do not imply that each tribe would arrive simultaneously at the same point in program development. That would be impossible because of differences in tribal sizes, needs 2ind water quality problems. The stages do, however, outline what the tribes think can be accomplished through planned effort, coordinated budgeting, inter- governmental goodwill, and appropriate funding. A full discussion of the staging within the Coordinated Tribal Wa^er Quality Program begins on page 17. Stage 1 consisted of program development that was conducted on the basis of inter- views with tribeil policy makers and technioil staff at each federally recognized tribe in the state. These interviews: • Outlined water quality issues eiffecting reservation and off-reservation waters; • Identified tribal programs currently in place to address water quality issues; • Identified actions needed to combat water qu<>lity issues; and • Determined change in relations with other governments that could lead to comprehensive, coordinated and cooperative efforts to address water quality issues. I 293 Stage II of the program provides infrastructure for each tribe to integrate its specific issues into the overall program guidelines. The tribes, through this initial infrastruc- ture development, will also be able to refine and complete the program development by acquiring needed expertise and staff. Stage III of the program has three components. The first allows each tribe to imple- ment the base-level water quality program designed in stages I and II. These basic programs would include the staff, equipment, and support costs necessary for the tribes to begin addressing water quality issues affecting their reservatior^s and treaty- protected resources, and accomplishing program goals. The second would extend tribal water quality programs, implement regional programs and increase statewide programs. The third component provides for maintenance of tribal programs, extension of water quality education efforts and planning of tribal watershed demonstration projects. Each of these components are inter-dependent, and when combined create a meaningful mechanism for water quality protection efforts. The Coordinated Tribal Water Quality Program rises from a comprehensive, cooperative natural resource management process tfiat is becoming institutionalized in Washington state. The federally recognized tribes in Washington state have been a driving force behind this process, wfiich is already being used to manage smeni ol ntial Ihbal and coordiialed italaMde programs Extend utel wakr quaity programs and enact regional programs and VKreaae Maiitain Iriial programs and Add special trtel prefects t6«00,000 SegtN FY94 hi impiementalian o< national bibal model water qioily program iioMO.ooo 295 Introduction: The shining water that moves in the streams and rivers is not just water but the blood of our ancestors. 1/ we seU you our land, you must remember that it is sacred, and you must teach your children that it is sacred, and that each ghostly reflection in the clear water of the lakes tells of events and memories in the life of my people. The water's murmur is the voice of my father's father. The rivers are our brothers, they querKh our thirst. The rivers carry our canoes, and feed our children. If we sell you our land, you must remember, and teach your children, that the rivers are our broth- ers, jmd yours, and you must henceforth give the rivers the kindness you would give any brother." - Chief Sealth during treaty times. Water pollution threatens tribal health. It also threatens the survival of natural and cultural resources on which the tribes depend. To safeguard their health and those resources, the federally recognized tribes in Washington state want to exercise their treaty and other powers to protect, restore and enhance watersheds of tribal concern and their associated ecosystems. Individually, each tribe intends to continue to exercise its sovereign authority on a govemment-to-govemment basis with other tribes, as well as federal, state and local governments to achieve common goals. At the heart of the effort, each tribe is at- tempting to inventory, assess, prioritize, regulate and eliminate water poUution within its waters of concern. Equally important, however, lies the recognition that addressing water pollution requires cooperative, coordinated efforts in alliance with other governments. Water pollution ignores jurisdictional boundaries. Tribal jurisdictions border and interlock with other jurisdictions, including those of the most densely populated and industrialized arejis of Washington state. The tribes realize that alone they caimot successfully combat water pollution. Prevailing against water poUution requires concentrated, sophisticated and both technical and political methods. The tribes therefore have committed themselves to the development of a model coordinated tribal water quality program outlined in this report. Intergovernmental coordination between tribes, federal, state and local governments and other entities is crucial to controlling water poUution. The tribes need consid- erable financial and technical assistance in evolving and expanding their water quality programs - financial help that is sufficient and consistent. The tribes want to secure sufficient, predictable federal funding to guarantee develop- ment and implementation of their water quaUty programs and to institutionalize congressiorvil and executive support. Perhaps more than other governments, the tribes understaixl from long experience that limits apply to funding. To meJce every dollar work to its fullest, they plan to multiply the effects of the doUars they receive by joining with other governmental entities and organizations in coordinated, coop- erative efforts to address impacts on water quality. WeU before 1987, when Congress authorized federally recognized tribes to attain the status of "states" under the Clean Water Act, the tribes in Washington had taken a 296 lead in developing comprehensive, cooperative and coordinated agreements with state and local governments cind private interest groups to protect and manage natural resources, especially those resources essential to the survival of salmon jmd trout. The drive for such agreements arose out of decades of successful litigation brought by treaty tribes and the United States against the State of Washington to protect tribal fishing rights to salmon and other fish, including the right to fish off-reservation in usual! and accustomed fishing cu-eas. Decisions in federal courts so far have not only ensured these tribal treaty fishing rights but have established the treaty tribes as co- managers of the fisheries resource. In the process, courts also declju-ed that the tribal fishing rights are meaningless if there are no fish to harvest. The courts noted that certain environmental conditions are prerequisite to the survival of salmon. These conditions include; • Access to and from the sea; • Sufficient and suitable gravels for spawrung and incubation of eggs; • An ample supply of food; • Sufficient shelter in aO stages of development; and • An adequate supply of good quality water. A federal court ruling which held that state and federal governments must refrain from degrading fish habitats put the matter this way: "Were this trend to continue (environmental degradation), the right to ttike fish would eventually be reduced to the right to dip one's net into the water and bring it out empty." From the Washington State Attorney General's office then caime the observation that the ruling could confer upon treaty tribes the power to co-manage all activities in many of the state's watersheds: "...the ruling could lead to the tribes' having veto power over real estate projects, logging practices, highway construction and the use of pesticides in the western half of the state..." Such litigation, however, taxed tribal time, staffs and treasuries. It also taxed the State of Washington and complicated already highly complicated fisheries. Tribal and other participants all observed that litigation was not producing any more fish, nor was it making the state's fresh cind marine waters any cleaner. More broadly, out of the actioiis in the courts, some of them still ongoing, grew an earnest desire among tribal leaders to seek coordinated cooperative agreements on managing ruitural resources that would achieve the same management ends as litigation. The same desire arose within present and past administrations of the State of Washington. Private obser/ers of how the court decisions might impact their enterprises, especially those hjirvesting timber, also became interested in such an approach. 297 What followed were agreements - unique in the nation - that brought previously contending tribes and other parties together in a voluntary process to serve mutual needs. In summary, the evolution of cooperative resource management so far has produced: • Tribal/state ongoing plans for cooperative management of Puget Sound fisheries. These plans join the tribes involved and the state departments of Fisheries and Wildlife in mutual concerns about water quality and streamside and in-stream habitat. The Pacific Salmon Treaty between the United States and Canada, which resulted in 1985 from joint efforts by tribes, state government, sport sind commercial fishing groups and federal fisheries officials. The treaty set up an administrative mechanism ~ in which the tribes have a strong voice — for cooperative management and protection of each nation's fish. A cooperative system of watershed planning developed in 1986 by the tribes and the state Departments of Fisheries and Wildlife. The process aims to manage and enhance salmon fisheries on a watershed basis. The tribes and the state departments solicited public comments, held hearings, developed sub-regional work teams that identified goals and objectives and problems and opportimities for each watershed, jmd have since developed Comprehensive Resource Production and Management Plans for each drainage. These plans receive constant updating in light of results and changes in resource conditions. Such cooperative, ongoing planning £uid management efforts accord with tribal aims through the Coordinated Tribal Water Quality Program to apply cooperative techniques to solving water quality problems on a watershed or ecosystem basis. The Timber/ Fish/ Wildlife Agreement of 1986 by which tribes, state agencies, environmentalists and private timber owners seek to find regulatory and voluntary ways to protect streams and watersheds from the impacts of logging. Water quality impacts from timber harvest practices remain a main concern of all the tribes. The Timber/ Fish/ Wildlife Agreement affords a cooperative way to apply best-management practices to timber harvests. 'We are very encouraged by and support the Itilies' ettoils to expand their paitidpalion. Invotvemenl and expertise in water quality issues We advocate coordinated cooperative etiorts to develop solutions to water pollution problems on a watershed/ ecosystem basis The resources of the stale will be served by greater participation by tribal governments in protecting water quality ■•• Joseph Btom, D/recfor, Washington Department ot Fisheries The protection of ourstate's natural resources requires that the slate and tribes worit closely together. It Is imperabve that the tribes obtain the level ot funding needed to make this partnership wot1( Without this support the natural resources of our stale will surely be seriously diminished." -• Curt Smilch, Director, Washington Department ot WUdlite The Centenrual Accord of 1989 between the tribes and the State of Washington, which recognizes and respects the sovereignties of tribes. The pact also institutionalizes a govemment-to-goverrunent relationship between the state and the tribes. This agreement infuses tribal determination to deal with water quality problems in coordinated, cooperative approaches that tremscend boundaries. Tribes have played a key rde in our consensus approach to controversial natural resource issues in Washington slate. Their partk:ipat)on benefits ml just tf« tribes, but everyone in our state wtw is concerned about protecting our environment II is critical that they have the funding to continue their important contributions.' ~ Brian Boyle. Washington State Conmissioner ot Public Lands. 298 'Ecokigy shares the tribal goab to resolve cross- tioundary and shaied-resource environmertal issues through Intergovemmental approaches. In o(def lor this to tie successful, tribes must have the stall resources to eflectivelyparticipale in the many torums affecting thera' - Chuck Clarite, Director, Washinglor) Deparlment ol Ecology The tribal/state Environmental Memorandum of Understanding of 1989 by which the state recognizes tribal sovereignties and pledges to work on a govemment-to-govemment basis to protect, restore and enhance fish and wildlife habitats. Tribal participation in the governance and work activities of the Puget Sound Water Quality Authority, created in 1985 to develop a comprehensive plan for protecting the water quality of Puget Sound. Tribes in the Puget Sound basin put restoring the water quality of Puget Sound as a main priority to be achieved through their cooperative efforts in the Coordinated Tribal Water Quality Program. "Water is, and will continue to be, ol overwhelming importance to this state. It is absolutely necessary that the tribes be able to participate in the dedsion- neking processes, and we support your efforts to obtain hiving ' - C. Alan PeWbone, Director, Wastiinglon Department ol AgrtcuHure • The Puget Sound Estuary Program, established with the designation of Puget Sound as an Estuary of National Signjficeince. The program is co-managed by EPA, the tribes, the Washington [>epartment of Ecology and the Puget Sound Water Quality Authority. The tribes are represented on tfie Authority as co-managers of Puget Sound waters and serve on the estuary program's management committee. • The Chelan Agreement of 1990 by which the tribes, the state, environmental groups, agriciilturalists, counties and cities and other water users seek cooperative ways to protect and enhance water resources. Water shortages loom in all parts of Washington and the quantity of water frequently determines the quality of water. All of these agreements and programs deal with evolving processes. The tribes and other participants hope that these processes will lead to environments that protect fish, wildlife and other resources, thereby enriching the common quality of life for tribal people and all others. Tribes - whether they live on Puget Sound, the Pacific Coast or along the drainages of the Columbia River in eastern Washington — are conunitted to managing water quality on a watershed /ecosystem basis that transcends jurisdictions. This approach commits all jurisdictions to plan together, to act together and in doing so to respect each other's powers and dignities. The tribes are not blind to history. Until lately, and only after they went to court to protect their rights, they were often the last jurisdictions invited to manage such common resources as water. On a local level they are still sometimes overlooked in planning that impacts reservations and tribal lerate hatcheries and other fish-rearing facilities to supplement stocks of wild fish. These facilities produce 50 million juvenile fish amnually. Some marine tribes also operate facilities to grow and prepare shellfish for market. Nonpoint source pollution degrades waters on tribal reservations and in off-reserva- tion waters over which treaty tribes have co-management rights. It also degrades waters outside of the direct scope of tribal management that produce or harbor salmon and trout that transit tribal waters and are part of the tribcil catches. Cotvil* KaHap^ Spokana 10 302 Indum Tribes In Washington State Resen^ation Sizes/Populations BESEKVATION USERVATION TBDB rwuLA-noN Oidialis 7.0 491 CohrUk 2,116.6 6951 Hoh 0.7 96 Jamestown ** ai 22 Lower Eiwba 0.1 137 Lammi list 3.147 Makah 42.7 U14 MocUeiboot &1 3.841 NiaqnaDy 73 S78 Nooback 42 556 PMtGamUe IS 532 PnyallDp 2U 32.406 Qmleute 1.6 381 Quioaolt 325.2 1.216 Sauk Stnanle 0.1 124 Sboalwaier 12 131 8.2 327J 614 1.502 Spokane Sqoaxin bland 2J 157 ai 174 Soqaamish 11.7 4334 Swinonmh llA 2.282 Tnlalip 352 7,103 l^iperSkacU 02 180 Yakima 2.137.6 27.668 1 TOTAL 5.099.9 96,343 • oompltd ckfkiQ ontto MMvtowi. AiMfciiriWmmiiibOT — nolntiimiiliHhW«U.SC»Mm difcfaren-nnivilDnpnpiMlnni. AooraMHaM*iwnlMro( Nonpoint source pollution is pollution that flows from a variety of sources. The EPA, for regula- tory purposes, has characterized nonpoint sources as "diffuse sources that are not regulated as point sources." Nonpoint source pollution includes, but is not limited to, siltation from logged hillsides; fecal bacteria from septic tanks and farm cinimals; pesticides and fertilizers; and municipal and industrial discharge. Under the Clean Water Acfs National Pollutant Discharge Elimination System (NPDES), the federal government, state govern- ment and tribes with state status under the Clean Water Act can regulate pollution from point sources such as a single pipe discharging pulp mill wastes. The federal government, however, chooses to use educational pro- grams cind best -management practices as the primary methods of controlling nonpoint source pollution. Ths Agency believes that where an ecosystem crosses polHical boundaries, effective regulation caHs tor coordination and cooperation among all governments having regulatory roles impacting the ecosystem." - EPA. 'Federal, Tribal and State Roles in the Protection and Regulaton ol Reservation Emironments,' 1991, p. 5. The NPDES does not, however, regulate all point sources. The Cletin Water Act fails to include water pollution from many agri- cultural sources under the system's scope. Consequently, an irrigation canal that daily dis- charges millions of gallons of water laden with bacteria and agriculture wastes into the Columbia River or Puget Sound qualifies only as a non- point source. Tribes also are impacted by point source pollution from industrial operations and from municipal sewage-treat- ment plants. In some cases, it is difficult to distinguish, except in the narrow legal sense, between nonpoint sources of pollution and point sources. 11 303 Program Framework: Roles And Responsibilities The Coordinated Tribal Water Quality Program outlines what relationships the tribes could generate among themselves and with other governments if sufficient funding is forthcoming from Congress. The intergovernmental and programmatic relation- ships indicated in the discussion that follows show what the tribes plan to accom- plish oiKe funding begins to flow. The Coordinated Tribal Water Quality Program is built upon the following frame- work: • Each participating tribe will develop and administer a water quality program for itself through a govemment-fo-govemment relationship with the EPA and with other tribes and other governmental entities. Such programs would prioritize watersheds for implementing actions, identify those actions, identify other responsible agencies and groups, estimate costs and propose action schedules and milestones. • Participating tribes would establish or expand existing cooperative arrangements with each other and with federal, stale and local entities to address nonpoint source and other water quality problems on a watershed basis. • To get the Coordinated Tribal Water Quality Program under way, participating tribes initially would coordinate general water quality policies through the Environmental Policy Committee of the Northwest Indian Fisheries CommissiorL Each participating tribe would be represented on the committee. Monthly meetings of the committee would be staffed and facilitated by the Northwest Indian Fisheries Commission. At least one committee meeting each quarter would be devoted solely to water quality matters. In Fiscal Year 1993 the participating tribes would discuss whether they want to continue using the Environmental Policy Committee as the forum for coordinating water qucility policies. • As an additional measure to launch the progrjim, the Northwest Indicin Fisheries Commission would render technical, educatioruil and other services to the Coordiiwted Tribal Water Quality Program, including forums for techiucal discussions of water quality matters. • Through the Enviroiunental Policy Committee, the Northwest Indian Fisheries Commission would offer the participating tribes an avenue for discussing water quality matters with the federal, state and other governments. • Following adoption of the Coordinated Tribal Water Quality Program, the participating tribes and Northwest Indian Fisheries Commission would make a joint annual report to Congress and to the EPA on the program's evolution, progress and achievements. 12 304 • Four years after the adoption of the Coordinated Water Quality Program, the participating tribes would review the program's entire coordinating htimework to see if framework changes might improve the joint tribal water quality efforts. Experience has convinced the tribes that the only reasonable and efficient way to address nonpoint source and other water pollution is on a watershed, ecosystem basis that transcends jurisdictional boundciries. No single governmental entity has been able by itself to confront all of the water quality problems facing Washington state and the treaty Indian tribes. Only comprehensive, coordinated efforts can cleanse waters, restore habitat and sensitize the public about why and how to prevent water pollution. The tribal commitment to watershed management and plaiming dovetails with the stated goals, objectives and guidance of the Clean Water Act. In addition, the water- shed management approach to water quality concerns furthers those objectives of the Clean Water Act that do not require - but would benefit from - the watershed planning process zmd approach as envisioned by the tribes and State of Washington. Some of the tribal programs would iiKlude efforts to: Inventory, assess and protect wetlands to achieve a net gain of wet- land areas; Protect and restore tribal spiritual and cultural areas affected by water pollution; Upgrade reservation waste treatmail systems; Institute cooperative programs for managing active, orphaned and abandoned logging and other roads; Identify, classify and monitor ecosystems and biotic communities unique and important to the tribes; Coordinate tribal land-use ordinances with those of neighboring governments; Have the EPA appreciate and recognize tribal off-reservation rights and authorities; Prevent development within riparian areas and flood plains and to feicilitate coordination of buyout programs for those living in flood plains; Seek increased funding for the water pollution enforcement divisions of tribal, state and local agencies; Work with other governments to develc^ social, political and financial incentives, so that private efforts to curb and stop pollution will be rewarded; and Work with other governments to secure funding for research on the water quality and water quantity impacts of silvicultural, agricultural, industrial, and development activities, so that the results of this research will be built into decisions about water quality programs. 13 305 As individual jurisdictions, the participating tribes face the necessity to begin prepar- ing themselves with the staff and staff support to take on a full role in dealing with water quality concerns on a watershed basis. The pljin the tribes present here for a Coordinated Tribal Water Quality Program recogt\izes that until 1991 most of the tribes had little money and small or no staffs for handling nonpoint source and other water quality problems. Tribsd Governments: The framework for the Coordinated Tribal Water Quality Program rests upon the sovereign status of each tribe. The basic unit of the program is and must be the individual tribe. Each tribe will exercise its sovereignty over its efforts to control and eliminate water pollution. In interviews and intertribal forums, the tribes have expressed that in their individual areas of governance, the Coordinated Tribal Water Quality Program shall reflect these principles: • Each trit)e intends to staff, develop, implement and administer its own measures to control water pollution. • Each tribe intends to begin to ir\stitute its water quality progrsim Jis soon as it receives from EPA the funding to hire at least one staff member with the expertise to begin developing a minimum level water quality prognun. Tribes may agree to pool staff or jointly contract for staff. • As part of its water quality program, each tribe intends to inventory its waters, assess nonpoint and other sources and prepare a plan targeting and prioritizing source controls within its waters of concern. • Each tribe may institute or expand its own facilities for water quality monitoring, assessment and testing. For the sake of efficiency and reduced costs, such water testing progRims as far as possible shall complement tribal water testing programs for drinking water, fisheries and shellfisheries. • Each tribe shall establish its own on-reservation policies emd decide for itself the form of the water quality program it chooses to adopt to meet tribal goals. Under EPA regulations, a tribe may request EPA to administer water pollution control measures for the tribe. A tribe may adopt Jind seek to enforce all or part of the State of Washington's water quality standards; or it may agree to let the state enforce authority in tribal mcinagement areas. It may adopt and seek to enforce standards of its own that are congruent with the requirements of the Clean Water Act. • Each tribe adopting on-reservation water quality standards and an implementing program shall ensure that it has in place a tribal administrative code. The code will delineate hearing, appeal and other procedures governing adoption of standards and the implementing progRim and other tribal ordinances. These procedures are necessary to give full legal foundation to the adoption and enforcement of water quality standards and progrctms. 306 • Each tribe shall maintain its govemment-to-govemment relationship with the EPA and all other governmental entities. No organization shall speak on water quality policy matters for ciny tribe unless that tribe agrees to be so represented. • Each tribe intends to institute for itself an educational program on how to prevent and control water pollution. The tribes recognize education as a major tool for preventing water pollution, especially nonpoint source pollution. Educational programs carrying the tribal voice have strong effect on tribal members and furthermore act to make the tribal voice heard in neighboring non-tribal communities. Regional And Watershed Coordination: Circumstimces amd experience convince the Washington tribes that the success of any water quality program depends on coordinated, cooperative pollution control efforts eunong the tribes themselves and between the tribes and other governments. The tribes agree that ongoing and new efforts to protect, restore and enhance the purity of waters within the state must continue to be cooperative and must continue to be carried out on a watershed basis. Watershed programs usually involve a multi- plicity of tribal and nontribal governments. As part of the Coordinated Tribal Water Quality Program, the tribes intend: • Individually, cind as groups, to strengthen and institutionalize ties between the tribes and the counties and municipalities in combatting water pollution. • Individually, and as groups, to strengthen their govenunent-to- goverrunent relations with such state agencies as the state departments of Ecology, Natural Resources, Fisheries, Wildlife, Agriculture, Health and Community Development and with the Puget Sound Water Quality Authority. Many tribes already involve themselves in tribally-directed regional organizations that have evolved from the necessity to jointly manage off-reservation fisheries and other resources dependent upon water quality. These organizations include the Ska^t System Cooperative (Swinomish, Upper Skagit and Sauk-Suiattle tribes). Point No Point Treaty Council (Skokomish, Port Gamble S'Klallam, Jamestown STClallam imd Lower Elwha Klallam tribes) and Upper Columbia Uruted Tribes (Spokane and Kalispel tribes). With the development and initial funding of the Coordinated Tribal Water Quality Program, these organizatior\s take on additional importance as both technical and policy structures for dealing with nonpoint source and other water pollution. As intra-tribal water quality programs broaden jmd deepen, these organizations should develop further importance as chief regional tribal entities focusing on watershed water pollution problems in cooperation with non-tribal governments. Along with the the Skagit System Cooperative, Point No Point Treaty Council and Upper Columbia United Tribes organizations, other options exist for formal and concentrated tribal cooperation in water quality progtcuns. These iiKlude: 15 907 The Nooksack River drainage, involving the Lummi and Nooksack tribes; The Stillaguamish and Snohomish river drainages, involving the Tulalip and Stillaguamish tribes; The heavily populated drainages in King County and the Kitsap Perunsuia, involving the Suquamish and MuckJeshoot tribes; The south Puget Sound drainages in Pierce, Thurston and Mason counties, involving the Puyallup, Squaxin Island and Nisqually tribes; The Olympic Peninsula coastal drainages, involving the Makah, Quileute, Hoh, and Quinault tribes; The central Columbia River drainages, involving the Yakima Indian Nation and other tribes; The Chehalis River drainage, involving the Chehalis and other tribes; cuid The Willapa Bay draiiuiges, involving the Shoalwater Bay and other tribes. Statewide Coordination: The Coordinated Tribal Water Quality Program would include one or more central- ized offices to provide participating tribes with coordinated technical aid and infor- mation. A forum also would be provided at which the tribes may discuss cind de- velop joint water quality policies and from which they may communicate their shared views on water quality concerns to other governments. The tribjiUy directed Northwest Indian Fisheries Commission has served as the central body for the participating tribes for coordinating the funding, planning and development efforts in the first phase of the Coordinated Tribal Water Quality Pro- gram. Based in Olympia, Washington, the commission was formed in 1974 by the western Washington treaty Indian tribes that were party to U.S. v. Washin^on. Mem- ber tribes are Jamestown S'Klallam, Port Geunble S'Klallam, Lower Elwha Klallam, Lummi, Makah, MuckJeshoot, Nisqually, Nooksack, Puyallup, Quileute, Quinault, Sauk-Suiattle, Upper Skagit, Skokomish, Squaxin IsUmd, Stillaguamish, Suquamish, Swinomish and Tulalip. The commission operates on a democratic basis representing the treaty drainage areas of the tribes. Its role is to provide coordination, share information between member tribes and other parties, and provide a unified tribal voice on fisheries management and habitat. The commission maintains a professional staff that pro- vides extensive technical support, public outreach and inter-tribal coordination to member tribes. The commission's constitution provides direction for outreach to non- member tribes as well. Input from non-member tribes is coordinated through the commission's Environmental Policy Committee. 16 308 In 1991, in the second phase of the tribal water quality program, the Northwest tribes received funding from the EPA to provide techrucal coordination to participating tribes for one year. The commission currently employs a water resource coordinator to help render technical services to those tribes requesting assistance in developing and expanding their water quality programs. Through the Coordinated Tribal Water Quality Program, the commission will continue to provide statewide policy coordi- nation, intergovernmental coordination, technical coordination, water quality testing, information management and education services. Framework Summary: In summary, the Coordinated Tribal Water Quality Program would operate as fol- lows: • In all respects it would be tribally directed. • Each participating tribe would develop its own water quality program through its govemment-to-govenunent relationships with the EPA, other federal agencies, and state and local governments. • Neighboring tribes would seek to begin or expand existing comprehensive, cooperative water resource programs with other tribes and with local, state and federal agencies, with particular focus on watershed or regional programs. • The participating tribes would coordinate their water quality efforts through the Environmental Policy Comnuttee of the Northwest Indian Fisheries Commission. • The Northwest Indian Fisheries Commission would undertJike to provide centralized coordinating and techiucal service programs for participating tribes and to provide a forum by which participating tribes might arrive at a unihed voice on water quality concerns. • The Coordinated Tribal Program, now just beginning, would develop in stages as fimding allows. Coordinated Tribal Water Quality Program Implementation Schediile: Full development of the Coordinated Tribal Water Quality Program will occur over four stages. The staging recognizes that not all parts of the program will occur simul- taneously with all tribes. Some tribes already have parts of a water quality program in place. Others are just beginning to develop water quality programs. The drcumstances, water quality needs and indirect costs of the tribes vary. Some tribes nught choose to use initial program funding for maintairung two water quality staff: One person to be concerned with developing water quality policy and to liaison with other tribes and goverrunents; the other to be a techrucal field person. Other tribes might choose, depending on circumstance, to use initial funding to support the program needs of one techrucal field person. Still others might choose to pool their funds in water quality efforts. 309 Stages In Detail: Stage I: Program Development Timeline: September, 1990, to January, 1992 Funding: $194,000 With funding from Congress through the EPA, Stage I has led to the development of the joint program and its strategies, which are the subjects of this report. Interviews were conducted with policy makers and technical staff at each of the tribes to outline water quality issues affecting reservation and off-reservation waters. The interviews included discussion of tribal activities to combat these problems and on changes in relations with other governmental bodies needed to develop comprehen- sive, cooperative anti-pollution efforts. At the beginning of the program tribes could not afford to hire and keep a water quality expert on staff, although hiring and increasing such expertise rarJted among the highest tribal priorities. Stage II: Providing Minimal Water Quality Infrastructure For Each Tnbe And Beginning Statewide Water Quality Coordination Efforts Timeline: September, 1991, to October, 1992 Funding: $1,500,000 While Stage 1 work began to develop a coordinated tribal water quality plan, partici- pating tribes sought funds from Congress to provide each tribe with enough money to hire or contract for the equivalent of at least one person to begin working specifi- cally on water resource issues. Congress appropriated $1,500,000 in Fiscal Year 1991 for Stage D purposes. In cor«ul- tation with the tribes, EPA Region 10 outlined how and for what purposes tribes could seek grants from the $1300,000 total. In the summer and fall of 1991, tribes begem receiving individual grant approvals from the EPA. Most hired or contracted for their first true water quality staff. Some began expanding water quality programs. Simultaneously, the Northwest Indian Fisheries Commission received EPA funding approval to hire a water resource cocrdiruitor and to begin a statewide technical coordination program for tribal water quality programs. While tribes were able to hire water quality staff, the goal of pro- viding infrastructure was not achieved at all 26 tribes because of inadequate funding. Coordination was limited to a minimal level of support. At the tribal level, the Stage n funding of $1,500,000 to fund minimal water quality programs is allowing individual tribes to begin to inventory, monitor, assess, priori- tize and target nonpoint source pollution and other water quality problems within its waters of concern. It also is allowing some tribes to start to update, upgrade or develop water quality standards and water quaUty programs for achieving those standards for waters within the reservation. This minimal funding, however, only starts the development and implementation of individual tribal programs. 18 310 Beyond providing each tribe with minimum water quality infrastructure. Stage D also sets the stage for each tribe to begin to integrate its approaches to particular water quality problems into the overall tribal water quality program. Under Stage n devel- opment, tribes began to intensify participation in: Cooperative resource management progrcuns involving water qucility; Statewide coordination of water quality goals, objectives and methods; Addressing multi-media issues dealing with water quality; Coordinating off- £md on-reservation activities and programs; and Exploration of alterr\ative cooperative tribal mechanisms for developing and administering on-reservation environmental protection programs. Stage n also has increased the tribes' ability to participate in water quality processes conducted by federtil, state and local governments. SUge III: The Coordinated Tribal Water Quality Program Development Of Initial Tribal And Statewide Programs: Timeline: FY 93 Funding: $6,000,000 Per Year Tribeil policymakers determined that an initial water quality program for each tribe deonands funding for the equivalent of two full-time staff. Stage n would provide a basic water quality program for each tribe that could include: • Continuing the inventorying, monitoring and assessment of waters within its waters of concern; • Attending technical meetings of water resource staff; • Having water quality staff and tribal policymakers participate in deliberations of the Environmental Policy Committee; and • Implementing controls, on a watershed level when possible, on water quality problems. In addition, individual and neighboring tribes also would undertake with each other and with the EPA, state, municipal and other entities the development of new strate- gies and agreements to prevent and control nonpoint source and other water pollu- tion on a watershed or regional basis. These initiatives would include: • Implementing feasibility studies to develop regional and statewide cooperative water testing laboratories to reduce testing costs and maintain standardized testing methodologies; 19 311 • Developing a centralized water quality database to be shared by all tribes and other entities; • Developing an educational program on how to prevent and stop water pollution, especially nonpoint source pollution. The program would also acquaint Indian cmd non-Indian people of tribal efforts to combat water pollution and why clean water is so important to the tribes; • Continuing to disseminate water quality information quickly and uniformly among tribes; and • Helping tribes coordinate their activities with natiorul Indian organizations. Developing water testing laboratories and data management programs would carry high front-end planning and equipment costs. Developing and beginning to operate all of these centralized progrjuns would require additional staff. Individual Tribal Programs And Implementation Of Cooperative Programs: In Stage III the individual tribes would continue to develop, maintain and implement their basic water quality programs. All tribes intend to have water quality standards and water quality programs enacted into ordinances and regulations in this phase. In addition, with the experience of several years of developing water quality programs and with basic water quality staff in place, tribes sharing watersheds and/or treaty or other rights concerning the same waters would undertake to develop, formalize and implement joint intertribal water quality programs. Such cooperative developments among tribes will not necessarily all occur at the same time. The tribes involved in the Skagit System Cooperative, Point No Point Treaty Council and Upper Columbia United Tribes orgaiuzation, to some degree, already have developed joint water resource efforts. Many other tribes, the Stillaguamish and the Tulalip for ir\stance, have enjoyed long working relations with each other on water matters affecting shared drainages. It will be in this point of Stage HI, however, that the participating tribes would devote concentrated effort to bring about closer cooperation among themselves in given watersheds or management areas. This effort will require considerable discussion jmd formed planning. To take advantage of cost savings juid the multiplied positive effects of regional programs, such regional opportunities could include: • Development of watershed, regional and statewide intertribal water p>ollution response plans amd teams, especially for deeding with oil spills; • Development of staff expertise to use on a watershed or regional basis; • Development of specific watershed or regional water quedity plans; and • Development of watershed or regional water-testing laboratories. 20 312 Intimately connected and complementary to such tribal efforts would be tribal under- takings to expcind or initiate joint watershed and regional water quality programs with federal, state and local governments and other entities. Many tribes already are involved in such watershed programs with other govenunents. In this point of Stage m, the participating tribes would reach out to further expand and develop such progrcims. To develop, implement and maintain such progreims requires constant effort cind expense. Stage HI funding is intended, among other things, to provide participating tribes with the resources to match their governmental neighbors in the ability to share common expenses. In addition, through the Northwest Indian Fisheries Comnussion, participating tribes would undertake full-scale implementation of centrcilized water testing laboratory, data management, educational and public relations programs necessary to successful functioning of the Coordinated Tribal Water Quality Program. The tribes n-State Sctiool Programs X ln(eitrit>al Coonfination X X X National Cooninainn X X SPECIAL PROJECTS: Model Watershed Projects X Staff Exchaiges X 23 I 315 Appendix A Coordinated Tribal Water Quality Program Accomplishments: FY 91 Following is a list of tribal accomplishments during Fiscal Year 1991 of the Coordinated Tribal Water Quality Program. The Coordinated Tribal Water Quality Program is de- signed to allow the tribes to address water quality issues affecting their reservation lands and treaty protected resources. The program is designed to create individual, tribally-directed programs as part of a statewide coordi- nated program. In addition to the individual tribal program accomplish- ments outlined below, the tribes worked as a whole at both techrucal and policy levels in the development and early implementation efforts of the program. Some of those accomplishments included: • Technical coordination on the compilation of information regarding current water quality issues and program needs. • Policy decisions on program content cmd direction. • Integration of the Coordinated Tribal Water Quality Program into the tribal strategy to manage treaty protected resources. • Development of support statements from individual tribal governments for the Coordinated Tribal Water Quality Program. Colville Confederated Tribes: • Hired a Database Manager (tribal member). Sauk River near the Sauk-Suiattle Tribe Reservation, Updated Water Resource Database into an Arc/Info System. Once on- line it will be immediately available to approximately 100 resource managers. This information management system is designed to be shared with land managers, decisionmakers, landowners, and used in technical processes such as nonpoint source assessments and water quality morutoring. The system was designed to be a transferrable demonstration type project. 24 316 Hoh Tribe: Purchased water quality investigation equipment. Conducted an in-depth water temperature study of eight streams within the tribe's area of concern to analyze the effects of logging on water temperature. The study will be incorporated into the Sensitive Issues Action Plan for the Hoh River basin, an inter-agency resource management plan. The Washington State Department of Ecology (DOE), Department of Natural Resources (DNR), Department of Fisheries (WDF), Washington Environmental Council (WEC), and the Hoh Tribe are cooperators in this plan. The study utilizes thermal pollution sttmdards developed by EPA. Jamestown S'Klallam Tribe: Staff Reorganization: Existing staff was assigned to water resources issues. New staff was hired to backfill previous assigrunents in fisheries management. PIE Grant: The tribe secured a $20,000 Public Involvement and Education grant from the Puget Sound Water Quality Authority to prepare educational materials for a "State of the Dungeness River" presentation. Participation on Community Watershed Planning and Growth Management Committees: The tribe has actively participated on the Sequim and Dungeness Watershed N/lanagement committees and the Clallam County Critical Areas Committee. Dungeness/Quilcene Water Resources Pilot Project: The tribe successfully nominated the Dungeness/Northeast Olympic Peninsula region as a water resource pilot project under the Chelan Agreement. Using a combination of EPA and DOE support, the tribe has acted as the interim coordinating entity for the project on behalf of the two tribes, two counties, two cities and two utility districts. The tribe is coordinating with the Point No Point Treaty Council on two planning efforts that will assist in development of a water quality work plan for the Jamestown S'Klallam Primary Area. The first project, funded through the state Centennial Clean Water Fund, involves water quality monitoring in the Point No Point Treaty Area. The second project is being conducted as part of the implementation of the Strait of Juan de Fuca Management Plan. As part of this effort, the tribe is developing water quality and fisheries habitat profiles for each Strait of Juan de Fuca tributary. The profiles will outline habitat conditions, problem areas and potential actions. 25 317 Lower Elwha Klallam Tribe: • Hired Wafer Quality Technician, increased the number of tribal staff working on water quality issues, and created a tribal Water Quality Office. • Identified existing tribal resources; conducted needs assessments and review of reservation watersheds. • Assisted in establishing a public environmental education program. • Assisted in establishing the Adopt-A-Stream program within the tribal Summer and After School Program. • Completed Phase I of a drinking water survey and conducted several water supply workshops for tribal members. • Worked to establish a Comprehensive Watershed Monitoring Plan. Lummi Tribe: Collected Nooksack River Basin data sources on water quality hydrology and drainage; conducting analysis of man-made modifications and quality to flow. Identified and conducted initial assessment of reservation water resources; drainage and groundwater studies underway. Draft water code under review, initial work begun to develop reservation infrastructure including water quality standards. Verne Johnson, Lummi Tritje Environmental Policy Representative, examines a water sanple. • ARC/lnfo System in place and operating. A Geographic Information Specialist was hired and currently is working on application of state Department of Natural Resources (DNR) data. • Acquired spatial coverages for streams, wetlands and anadromous fish resources for the tribe's Geographic Information System (GIS) database. Makah Tribe: • Hired Senior Water Resources Planner. • Developing an existing conditions section of a sewage treatment plant siting plan. 26 318 Working on a restructviring of the pleinning department to accommodate growth and development, including water quality issues such as permitting. Muckleshoot Tribe: Hired full-time Water Quality Program Plaiuier to begin developing Water Quality Environmental Protection Project. Developing conunent letters on issues threatening tribeil waters of concern. Active participation in the adoption of the Soos Creek Community Plan. Developing a threat assessment of issues affecting tribal waters of concenv Analysis of federal, state, local and tribal frjimework in which the tribe must function, including regulatory, jurisdictional and plarming processes relative to water resource issues. Nisqually Tribe: Developed Ambient Water Quality Monitoring Program for Nisqually River basin, with stations on the Nisqually River and five tributaries. Three cooperating agencies have been identified. Initiated collection of water quality data from 11 monitoring stations, established three gauges to measure in-stream flow and, as a cooperator, one new U.S. Geological Survey (USGS) gauge. Developed water resources conunittee for Nisqually River Council; provided staff coordination for the committee. Initiated assessment of water quality problems both on- and off-reservation; developing approaches to address problems. Developed and submitted to DOE a $250,000 Centennial Clean Water Act grant application for nonpoint pollution investigation on two tributaries. Nooksack Tribe: Established a water quality literature loan library and reading desk for tribal reference. Began educational outreach to schools and organizations on trib2il water quality issues. Coordinated regulatory design with local governments on water quality components of Growth Ivlanagement Planning Act docimients. 27 319 Briefed tribal council and inter-tribal policy personnel on priority water quality issues and long-term planning. Assembled data and constructed initial files for long-term water quality program development. Port Gamble S'Klallam Tribe: • Hired an Envirorunental Program Director to address water quality concerns of the tribe. • Developed a political, social, and regulatory approach to water quality protection on the tribe's area of interest. • Participated on Hood Canal Coordinating Council (composed of three counties cind two tribes) and cooperative water quality efforts on Hood Canal. • Pcuticipating, jmd regularly meeting with 12 envirorunentiil and community groups to increase effectiveness in addressing local water quality concerns. • Developing on-reservation water quality standards to address forestry and land -use issues. Puyallup Tribe: • Hired an additional Water Quality Technician to build tribal expertise and to assist in the development of the Puyallup Tribal Water Quality Management Program. • Continued development of Puyallup Tribal Water Quality Management Program. • Began initial assessment of Puyallup River system. • Began initial water quality assessments of Midnight and Slide creeks (at confluence with the Greenwater River) to implement fisheries enhancement projects. Quileute Tribe: • Hired Environmental Policy Analyst and a Water Resources Biologist. • Started water resource planning for the 640-square mile Bogachiel watershed. Effort iiKludes water quality and fisheries habitat studies. Quinault Tribe: Developed contract with the University of Washington to take four sediment core samples at Lake Quinault to determine productivity changes in the lake. The samples are scheduled to be taken in late March 1992. 28 320 • Established the hjU-time position of Freshwater Ecologist in the tribe's Fisheries Division. • Assigned the Fisheries Division Deputy Division Officer as the interim point of contact for EPA grant-related water quality activities to ensure continuity until such time as the Freshwater Ecologist assumes responsibility for the task. Skagit System Cooperative (SSC) Swinomish, Upper Skagit and Sauk-Suiattle tribes: • Established a water quality task list with specific program descriptions and time lines from July 1991 through June 1992. • Completed a comprehensive review of historical water quality data for the SSC area of interest. Submitted review in report format to identify known problem areas cmd un-monitored areas, both freshwater and marine. • Conducting a data review addressing water quality issues of concern in SSC area of interest. • Arranged and participated in goverrunent-to-govemment meetings with Skagit County commissioners to present tribal off-reservation issues of concern in SSC area of interest. • Actively participating with local county planning department on policy and technical levels concerning local nonpoint source pollution Skokomish Tribe: Filled position to perform and coordinate water quality activities. Hired a half-time Water Quality Techrucian Divided water quality program into surface and groundwater areas; set up monitoring program for both areas to develop baseline information. Purchased water quality equipment and lab services. Comparing monitoring data regarding surface and drinking water with past USGS data to assess water quality trends. Developing groundwater data to substantiate environmental/health needs, such as wastewater treatment and drinking water. Implementing the Skokomish Environmental Protection Act. Developing an integrated flood management plan with Mason County and Washington state. 29 321 Squaxin Island Tribe: Established full-time Water Resource Plaimer position in tribal Natural Resources Department. Program framework has been developed and written for the tribe's water quality program. Initiated organizational and coordirwtion meetings between the tribe's on-reservation planners and habitat biologists. Active participation on local watershed councils and other water quality and land-use planning processes has been maintain through out the tribe's area of interest. Stillaguamish Tribe: Compiling information on land-use in the Stillaguanush watershed. Land-use directly affects water quality cind quantity in the Stillaguamish basin. Information on land-use within the watershed is scattered among many departments in county government, with no central location for the information. The tribe is beginning to compile this information, enter it into a database and begin mapping all land- uses within the watershed. The data will eventually be entered into a GIS. This information will be used to give a detailed description of land allocation witfun the river system and indicate where problems with water quality could be occurring. The tribe is working in conjunction with the Tulalip Tribes to begin water quality morutoring on the north and south fork of the Stillaguamish River. The tribe is awaiting the completion of water quality lab facilities, which should be completed by March 20, 1992. Completed on-reservation water conservation project that included installation of low-flow toilets, faucet aerators and low-flow shower heads. Establishing database of all water rights applied for and/or granted in the Stillaguamish basin. Compiled all well logs that pertain to the watershed. Will be entering logs into a database. The logs show public systems with fewer than six connections. Those with more than six connections should be indicated on water rights application. Recorded water rights have been plotted on maps. These show withdrawal type (irrigation, domestic, etc.) and indicate study sites that would be affected during serious drawdown. Suquamish Tribe: 30 Continued participation on Sinclair Inlet Watershed Managemoit Committee. Participation on Foss Creek Comprehensive Management Plem steering committee. 322 Participated with DOE on a tour of the Puget Sound Naval Shipyard to review the approximately 100 stonnwater outfalls. Continued participation as chair of Kitsap County's Solid Waste Advisory Committee. Continued review of Superfund documents relating to Navjil Submarine Base Bangor. Tulalip Tribes: Hired an Environinental Program Analyst. Developed scope of work for the tribal water quality program. Designed Phase 1 Study: Water Quality Data Review; Currently implementing the study. Richard Miller, Tulalip Tribes Water Quality Technician, records dissolved oxygen levels in Quilceda Creek. Upper Columbia United Tribes (UCUT) Spokane and Kalispel tribes: • Water quality program contract with the Kalispel and Spokane tribes was signed and subcontracted to UCUT on March 1, 1992. The limnologist/hydrologist position for this contract will begin on April 1, 1992. Yakima Indian Nation: • Established a full-time position for a hydrologist to work on off- ^jBservation issues. Hiring for this position is in process. • Increased participation in development of Yakima River Basin Water Quality Plan, which covers an area that lies totally within the Yakima Ceded Area £md includes reservation lands. Northwest Indian Fisheries Commission: • Developed consensus-based regulatory rules to address cumulative impacts to fish and water quality as a result of forest practices on state cind private lands. • Coordinated state/tribal and federal/tribal meetings to address water quality issues cind to help facilitate implementation of the Coordinated Tribal Water Quality Program. • Coordinated inter-tribal meetings to help facilitate implementation of the Coordinated Tribal Water Quality Program. 31 323 Appendix B Excerpts From The United States Of America National Report lb The United Nations Conference On Environment And Development The United States produced this report as part of the preparations for the Uruted Nations Conference on Environment and Development to be held in Brazil in June 1992. "One of the most comprehensive and successful examples of tribal/state/federal cooperation in resource management is the management of salmon resources in the state of Washington. Tribal fishing rights guaranteed by treaty are found in a series of treaties negotiated in the 1850s by Territorial Governor Isaac Stevens with a number of tribes in the Northwest. These Indian fishing rights were ignored in the settlement and development of the region, leading tribes to seek redress in the courts. "Fisheries management in the area was changed fundamentjdly in 1974 when Judge George Boldt issued his ruling in U.S. v. Washington. In this decision, Indian treaty fishing rights were reaffirmed and tribes were established as co-managers of the resource. Legal battles with the state of Washington continued into the 1980s, how- ever, as a the salmon fishery resource continued to decline. By default, fishery man- agement fell to the court, with state and tribal biologists constantly at odds. It was soon apparent to all parties that if the fish resource was of primary concern, the job of managing it must be removed from the hands of the court and placed back into the hands of professional tribal and state managers. "In 1985 a tribal/state plan for coof)erative management of fisheries in Puget Sound was jointly developed jmd approved by the federal court under U.S. v. Washington. Today, litigation over fisheries is the exception rather than the rule in managing tfus key resource. "The tribal contribution to this partnership is substantial. In 1976, tribal hatchery releases for the 20 treaty tribes who are members of the Northwest Indian Fisheries Commission (NWIFC) in the state of Washington totalled 9,929,000 fish. In 1990, the tribal release totalled 42,779,000 fish. In addition, tribal biologists participate in all facets of fishery mimagement jind are expanding their efforts into broader water quality programs as well. This is reflected in the 1990 Lake Chelan agreement for comprehensive water resources management, and in the non-point source pollution control project currently being conducted by the NWIFC in cooperation with state and local governments, with funding from the U.S. Environmental Protection Agency." "...In addition, tribes that meet requirements under U.S. Environmental Protection Agency (EPA) regulations may receive primary enforcement authority for program functions and join with EPA as partners to ensure effective compliance with federal environmental laws. Under this program, tribes may establish environmental man- agement codes and regulations, issue federally enforceable permits, and join with the federal government in taking appropriate enforcement actions. These partnerships are similar to those that state governments are eligible to develop with the federal government." 32 324 COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION 729 N.E. Oregon. Suite 200. Portland. Oregon 97232 Telephone (S03) 238-0667 Fax (503) 235-4228 March 19, 1993 The Hon. Elizabeth Furse, Member of Congress 316 Cannon Building U.S. House of Representatives Washington, D.C. 20515 RE: Written testimony concerning salmon restoration through habitat protection and hatchery reforms relevant to the Committee on Merchant Marine and Fisheries, Subcommittee on Environment and Natural Resources, Hearing on the Roles Watershed Management and Hatchery Practices will play in the Restoration of River Ecosystems in the Pacific Northwest, March 9, 1993. Dear Rep. Furse: Pursuant to your request of March 15, 1993, to Mr. Ted Strong, Columbia River Inter- Tribal Fish Commission (CRTTFC) Executive Director, I am submitting the following comments on the testimony presented to the Subcommittee on March 9. I have asked my colleague, Mr. Jon Rhodes, a hydrologist and expert on habitat protection, to join me in these comments so that the Subcommittee would have access to Mr. Rhodes' perspectives on the importance of habitat protection, and the benefit of some highly specific information on the role of habitat protection in salmon restoration. We open with comments on hatchery reforms, followed by a discussion of the importance of habitat protection. We conclude with specific recommendations for habitat protection actions that can be taken on federal and private lands. The Need for Hatchery Reform In concert with all the members of the scientific panel, we agree that hatchery technology has a role to play in the restoration of river ecosystems in the Pacific Northwest. We also agree with Dr. Kapuscinski that hatchery reforms are essential in order for hatchery technology to play an effective and positive role in recovery of Columbia basin salmon populations. In the Columbia River basin and elsewhere, state and federal agencies have used federal money for hatcheries to raise the wrong species and stocks of salmon with the wrong technology and released them in the wrong locations for too many years. Hatchery reform is necessary so that technologies can be applied to restore, and to maintain for as long as necessary, the biological and genetic diversity of salmon in the Columbia River basin. Hatchery reform is necessary to restore the historical species composition of salmon to the localities where they were once locally abundant. Hatchery 325 Rep. Furse re: Hatchery Reform and Habitat Protection, Mumfy and Rhodes Page 2 reform entails relocating points of hatchery releases, re-designing and re-directing the fish culture technologies, and increasing both the number of species and life history types of salmon that are protected within hatchery programs. In his testimony, Dr. Koenings provided a good overview of how proper supplementation can aid in restoring salmon populations. Our Columbia River perspective is different firom that of panel member, Mr. Higgins, of California, in that we do not believe that salmon restoration is possible without reformed hatchery programs to sustain salmon stocks until the their habitats can recover. We know that at least 65 populations of salmon have been extirpated from their habitat in the Columbia River basin above Bonneville Dam and another 32 populations have been sharply declining for 15 or more years (CRITFC, 1992). Too many salmon populations have been extirpated over the years when no hatchery programs were put into place to preserve them. Snake River basin coho salmon, upriver chum salmon, and sockeye salmon have been totally lost due to die lack of any hatchery, or other aquaculture, programs to incorporate and preserve their genetic materials. In contrast, Snake River fall Chinook salmon, and spring chinook from above the Hell's Canyon Dam complex have been saved from extirpation by hatchery programs. In the history of the Columbia River basin, wherever hatchery programs have been denied, genetic material from salmon popidations in the area has been irretrievably lost. Thus, our expeiieace dictates that the risks to salmon recovery of neglecting hatcheries are far greater than risks incurred by applying these technologies. Our practical experiences, and those of the CRITFC member tribes, in selecting and applying appropriate technologies to salmon recovery are reflected in a large volume of documents which we and other tribal technical employees have produced over the years. These include: Subbasin Plans, Integrated System Plan, Salmon Recovery Proposal for the Columbia Basin, Upper Grande Ronde River Anadromous Fish Habitat Protection and Restoration Plan, numerous analyses of forest management plans. Regional Assessment of Supplementation, Integrated Tribal Production Plan Volume 1: Snake River, Yakima Basin Fisheries Master Plan, the Nez Perce Tribal Hatchery Master Plan, and the Genetic Risk Assessment for the Hood River Basin, among others (for copies of any of these documents, please contact Roberta Stone, Ray Hecocta, or Sandra Petersen, 503-238-0667). As pointed out by a number of panel members, restoration technologies need to be evaluated on a case-by-case basis in each watershed; no single hatchery technology could be appropriate for all cases. Of course, we strongly agree with all the members of both the Watershed Management and Hatchery Panels that habitat restoration and protection are essential to long-term recovery of salmon and their ecosystems. The CRITFC member tribes, as proprietors of fisheries resources, have a long history of working with all other govenmients and other concerned entities to manage natural resources in a sustainable fashion. In particular, the tribes have identified watershed management as an important tool for salmon recovery. Watersheds are the building blocks of the ecosystem, and the ecosystem must be healed, and kept whole, for the salmon to recover. We agree with the panels that the role of the federal govenmient is to unite Columbia basin watershed management plans under principles that permit recovery of the ecosystem at a reasonable pace, while respecting the interests of the stakeholders in each watershed. We caution that recovery of the ecosystem must not, however, continue to be sacrificed to special interests. 326 Rep. Furse re: Hatchery Reform and Habitat Protection, Mundy and Rhodes Page 3 The activities of all governmental and private entities must be aligned and coordinated to effect recovery. All government agencies must have missions that are compatible with the restoration of river ecosystems. In this regard we recommend a broad ecosystem initiative based on watershed protection and restoration that would inform the public about their dependence on the resource, and that would integrate biological, social and cultural values. Such a comprehensive approach is essential to replace existing government programs now aimed at salmon recovery which are too narrowly conceived and imperfectly implemented to be of much help. We point out that comprehensive restoration programs are essential to align policies of federal land management agencies to protect key habitats. Such restoration programs could work by developing landscape-wide riparian protections, among other measures proposed by panel members on March 9. In order to be effective, these programs must have evaluation criteria that focus on measures of the health of the watershed, along with incentives for cooperation of private land owners. The Importance of Habitat Protection As scientists, we know that suitable and sufficient natal habitat is a critical to restoring naturally reproducing fish stocks. Unfortunately, non-point source pollution generated by land uses such as tilled agriculture, grazing, logging, road construction and mining have already significantly degraded extensive portions of the spawning and rearing habitat throughout much of the Columbia basin (Theureretal., 1985; Plattsetal., 1989; IDHW, 1989; ODEQ, 1989; NPPC, 1990a; NPPC, 1990b; NPPC, 1990c; CRTTFC, 1991a; CRTTFC, 1991b). AvaUable data consistently indicate that the degradation of natal habitat has severelv reduced the survival of the few salmon that successfully run the hydroelectric gauntlet. In concert with the high levels of mortality at Columbia basin hydroelectric facilities, the reduced survival in degraded natal salmon habitat has fostered the dramatic declines in salmon and other fish populations throughout the Columbia over die past five decades. There is a pressing need not only to protect habitat firom fiirther degradation, but also to take measures that will allow salmon habitat to recover naturally to the point where salmon survival is, once again, at levels conducive to rebuilding the salmon runs. Very little high quality habitat remains. Protection of the remaining high quality habitat must be a priority. We know that habitat protection is far more effective and inexpensive than habitat restoration. Habitat degradation is a pervasive problem in the Columbia. Outside of wilderness and roadless areas, riparian areas are in poor condition. Most 'managed" watersheds retain only a fraction of their original natural fimctions as the degraded conditions offish habitat, water quality and fish populations grimly attest. It is abundantly clear that the mere maintenance of the current degraded status of salmon habitat will hamper or defeat efforts to rebuild the salmon rtms. In fact, if existing conditions are maintained, it is probable that salmon and resident fish populations will continue to dramatically decline and ultimately disappear from many streams throughout the Pacific Northwest. Unfortunately, over most of the Columbia basin, management aimed at habitat restoration and protection is not even on the horizon. There are very few watersheds that are currently in recovery mode, yet degradation of fish habitat continues on an vast scale. 327 Rep. FuTse re: Hatchery Reform and Habiuu Protection, Mundy and Rhodes Page 4 While there is a constant need to improve the information base for habitat management decisions, enough is currently known to better protect fish habitat and water quality. These measures must be implemented immediately because although watersheds and fish habitat can recover naturally from degradation, the impacts are long lasting. Full ecological recovery of degraded habitat requires approximately 25 to 200 years depending on the type of the impact (Gregory and Ashkenas, 1990). However, damaged habitat can never recover imless the causes of the degradation are arrested. Unfortunately, the needed protection and restoration measures are not yet in place within any regulatory firameworic. Healthy riparian areas are critical to the maintenance of productive fish habitat. The importance of riparian vegetation to fish production cannot be overemphasized. Riparian vegetation provides stream shading to keep streams cool, filters sediment from upslope sources, stabilizes stream banks, and provides the large woody debris that forms the large pools and complex physical structure needed by anadromous fish throughout their fireshwater life stages. Impacts to riparian vegetation are not consistent with either the maintenance or improvement of fish habitat. If riparian areas are not protected, salmon populations cannot be protected or restored. Unfortunately, riparian vegetation along natal salmon habitat does not currently receive adequate protection under any land ownership in the Columbia basin outside of wilderness and roadless areas. The greatest degradation of fish habitat in the Q)Iumbia basin is generally caused by removal of riparian vegetation by livestock grazing, road construction, mining, logging, and tilled agriculture (Theurer et al., 1985; IDHW, 1989; ODEQ, 1989; Platts et al., 1989; NPPC, 1990a; NPPC, 1990b; NPPC, 1990c; CRTTFC, 1991a; CRTTFC, 1991b). This degradation has caused or resulted in chronic sedimentation, elevated summer water temperatures that are lethal to salmon, arid huge losses in large woody debris and pools. Data consistently indicate that in poor habitat salmon mortality is about 10 times higgler than in less degraded habitat, regardless of how few salmon make it into the habitat. While riparian protection is critical to the protection and restoration of the salmon habitat, it is not a panacea for avoiding habitat damage caused by upland impacts. Mining, grazing, logging, road construction, and tilled agriculture outside of riparian areas still deliver significant amounts of non-point pollution to fish habitat. Sediment is the dominant pollutant contributed from these sources; however, mines also contribute considerable chemical pollution and, in many cases, render salmon habitat unusable (NPPC, 1990c; Nelson et al., 1991). The catastrophic sedimentation of the South Fork of the Salmon River provides a well- documented example of the effect of habitat degradation caused by land disturbance at the watershed scale and its effect on salmon. The sedimentation of the South Fork of the Salmon River was primarily caused by logging-related land disturbance (IDHW, 1991). The sedimentation caused catastrophic declines in salmon and resident trout populations in the Soudi Fork of the Salmon River which had once been the most fecund summer chinook salmon habitat in the entire Columbia basin (Platts et al., 1989). Summer chiiKX)k salmon runs in the South Fork of the Salmon River dwindled from more than 10,000 fish to mere hundreds, after the catastrophic sedimentation event. The summer chinook salmon of the South Fork of the Salmon River are now listed as 'threatened" under the Endangered Species Act. 328 Rep. Purse re: Hatchery Reform and Habiua Protection, Mundy and Rhodes Page S Recommendations on Habitat Protection Actions 1. Federal Lands. Lands under United States Forest Service (USPS) ownership provide approximately 50-70% of the remaining spawning and rearing habitat in the Columbia basin (Sedell and Everest, 1990). Therefore, it is critical that the USPS provide adequate protection for these habitats, if salmon populations are to be restored. Unfortunately, Porest Plans for the Columbia basin forests will cause more, not less, habitat degradation. Under every Forest Plan, there will be an increase in road mileage and watershed distuibance that will cause increased sedimentation. Every plan also calls for continued logging, grazing, mining, and road construction in riparian zones. Recent evaluations of some Forest Plans by die USPS's own scientists, at the behest of Congress, indicate that there is a very low likelihood of continued viability of d^>ressed populations of salmon and resident fish if diese Forest Plans are tiilly implemented (Johnson et al . , 1991). Our own analysis of the Forest Plans concluded similarly that degradation of fish habitat would be severe under all of the Forest Plans. Accordingly, the memeber tribes of CRTTFC were put in the unfortunate and undesirable position of having to file administrative appeals of IS Forest Plans in the Columbia basin in an effort to improve the protection for fish habitat. At least four credible and scientifically developed management scenarios for protecting salmon habitat in the Columbia basin already exist. These are: 1) die South Fork of the Salmon River Step Plan (Payette National Forest, 1987); 2) the components of land management evaluated by Johnson et al. (1991) as necessary for a high likelihood of continued viability of fish populations; 3) the Upper Grande Ronde River, Fish Habitat Protection, Restoration, and Monitoring Plan (UGRRMP); 4) CRTTFC's technical recommendations for ttie management of critical spawning and rearing habitat in the Snake basin (CRITFC, 1991b). Notably, all four habitat management scenarios contain similar components, indicating that there is a great deal of consensus among the scientific community. We strongly recommend that Bureau of Land Management (BLM) and USPS land management plans for the Columbia basin be immediately amended to incorporate the provisions contained in diese four approaches to protecting fish habitat The components recommended by Johnson et al. (1991) include: 1) a system of reserve watersheds with high-valued fish production that are not to be roaded and logged; 2) the elimination of riparian zone logging; 3) an aggressive program to remove riparian roads and reduce the road mileage in all watersheds; 4) a program to improve road drainage; 5) the use of low impact logging systems such as helicopter logging; and 6) an iiKrease in the rotation length of timber harvest. Although the report by Johnson et al. (1991) is now almost two years old, die USPS has failed to adopt any of the recommendations. Similar to the provisions of Johnson etal. (1991), the UGRRMP calls for complete riparian zone protection, an aggressive program of road obliteration and road improvement, full protection of existing roadless areas, and short term elimination of grazing in degraded riparian zones. The UGRRMP also sets performance standards for fish habitat components; until the standards are met, fiirdier impacts to the watershed are prohibited. The UGRRMP also calls for rigorous monitoring of fish habitat conditions and usage. 329 Rep. Furse re: Hatchery Reform and HabiUU ProUction, Mundy and Rhodes Page 6 CRITFC's recommendations for the management of critical habitat in the Snake River basin (CRITFC, 1991b) which include: 1) elimination of riparian zone impacts; 2) an aggressive road obliteration program; 3) revision of all grazing allotments in the Snake basin; 4) limitations the frequency, intensity, and amount of land disturbance in watersheds; and 5) the elimination of grazing on degraded riparian areas until full ecological recovery has occurred. The South Fork of the Salmon River Step Plan placed a moratorium on all land disturbance within the degraded watershed. The moratorium is to remain in effect until stream sediment standards in fish habitat are met. The South Fork of the Salmon River Step Plan also developed a program of sediment reduction through road obliteration. Notably, the South Foric of the Salmon River Step Plan is the only one of the four approaches that has been implemented. It is also the only degraded stream in the Columbia basin that has been documented to have improved over the past 25 years. The EPA has now officially adopted the South Fork of the Salmon River Step provision as the primary means of implementing the Clean Water Act Provisions for streams that have been identified as "Water Quality Limited." The message that is common to all four of tiiese approaches is that protection of salmon habitat and populations requires that we limit watershed disturbance Qogging, grazing, mining and road construction) and eliminate the degradation of riparian vegetation. We agree with the testimony of the panel that these principles must be the cornerstones of comprehensive watershed management aimed at restoring salmon populations. 2. State and Private Lands. The states of Idaho, Oregon, and Washington have fiailed to control non-point source pollution and enforce their water quality standards developed under the Clean Water Act (CRITFC, 1991a). These states have also failed to develop water quality standards that fully protect fish habitat. In tandem, this has allowed severe degradation of fish habitat on federal and private lands. Most of the problems existing in fish habitat are attributable to the failure of regulatory agencies to enforce the Clean Water Act. The Forest Practices Rules in Idaho, Washington, and Oregon are inadequate to fully protect salmon habitat. At a minimum, these Forest Practices Rules will have to be amended to require full protection of riparian vegetation, if salmon populations are to be protected and restored. The states should begin to fully enforce existing water quality standards and immediately develop Total Maximum Daily Loads for streams that have been identified as "Water Quality Limited" under the Clean Water Act. The state water quality authorities should also rigorously review existing data and identify all streams as "Water Quality Limited" where existing water quality standards are not being met and the beneficial use of the water by anadromous fish is impaired. The water quality agencies should also immediately develop and adopt water quality standards that are biologically based, and that are designed to fully protect fish habitat. These agencies should also develop and adopt mandatory management practices for agriculture and mining. The states also need to analyze water right applications for their effect on fish habitat 330 Rep. Furse re: Hatchery Reform and Habitat Protection, Mundy and Rhodes Page 7 production capability. The states should cease issuing permits for water withdrawals that adversely affect the production potential of fish habitat. Instream flows have been significantly reduced on thousands of miles of salmon-bearing streams; hundreds more miles of streams have been completely de-watered. Conclusion Hatchery production and habitat protection and restoration can and should play complementary roles in restoring the salmon populations of the Columbia basin. We agree with the scientific panel's testimony that current hatchery and land management practices both need to be immediately reformed to incorporate our existing knowledge so that we can restore the Columbia basin salmon populations before more salmon stocks are lost. The science is available to accomplish the reforms. It is solely a matter of using the best scientific information available and implementing readily available plans that have been based on this information. If you or die Subcommittee needs any additional information or has any further questions, we stand ready to provide assistance. Thank you for the opportunity to comment. Sincerely, Phillip R. Mundy, Ph.D., Manager Fisheries Science Department Jon Rhodes, M.S., Hydrologist Fisheries Science Department Attachment: List of Literature Cited 331 Rep. Fune re: Hatchery Reform and Habitat Protection, Mundy and Rhodes Page 8 Literature Cited (For copies of any of these documents, please contoct Roberta Stone, Ray Hecocta, or Sandra Petersen, 503-238-0667) Gregory, S. and Ashkenas, L., 1990. Riparian Management Guide Willamette National Forest. CRTTFC, 1991a. Sept. 9. 1991 Letter From Ted Strong to NMFS: Comments on Proposed Rule for Spring and Summer Chinook in the Snake River. Unpublished. CRTTFC, 1991b. November 14. 1991 Letter From Ted Strong to NMFS: Comments on Critical Habitat for Petitioned Salmon Species in the Snake River. Unpublished. Idaho Dept. of Health and Welfare, 1989. Idaho Water Oualitv Statas Renort and Nonooint Assessment 1988. Idaho Dept. of Health and WelfJMe, 1991. South Fork Salmon River Problem Assessment and TMDL. Unpublished. Johnson, N.K., Franklin, J.F., Thomas, J.W., and Gordon, J., 1991. Alternative? for Management of Late-Successional Forests of the Pacitic Northwest-A Report to the U.S. House of Representatives. Unpublished. Nelson, R.L., McHenry, M.L., and Platts, W.S., 1991. Mining. Influences of Forest and Rangeland Management on Salmonid Fishes and Their Habitats. Am. Fish. Soc. Special Publ. 19: 425-457. Nordiwest Power Planning Council, 1990a. Grande Ronde River Subbasin Salmon and Steelhead Plan. NPPC, Portland, Or. Northwest Power Planning Council, 1990b. Clearwater River Subbasin Salmon and Steelhead Plan. NPPC, Portland, OR. Northwest Power Planning Council, 1990c. Salmon River Subbasin Salmon and Steelhead Plan. NPPC, Portland, OR. Oregon Dept. of Environmental Quality, 1989. 1988 Oregon Statewide Assessment of Noniwint Sources of Water Pollution. Portland, Or. Payette National Forest, 1987. Land Management Plan. McCall, ID. Platts, W.S., Torquemada, R.J., McHenry, M.L., and Graham, C.K., 1989. Changes in salmon spawning and rearing habitat from increased delivery of fine sediment to the South Fork Salmon River, Idaho. Trans. Am. Fish. Soc.. 118: 274-283. 332 Rep. Furse re: Hatchery Reform and Habitat Protection, Mundy and Rhodes Page 9 Sedell, J. R. and F. H. Everest, 1990. Historical changes in pool habitat for the Columbia River Basin salmon under study for TES listing. Unpublished briefing paper. USDA-FS, PNW Research Station, Corvallis. Theuier, F.D., I. Lines, and T. Nelson, 1985. Interaction between riparian vegetation, water temperature and salmonid habitat in the Tucannon River. Water Res. Bull.. 21:53-64. 333 NANCY PELOSI •TH CHSTIVCT CALlFOHNlA COMMITTEE ON APPROPRIATIONS tUICOHMITTCCt LAtOa-HEALTH AND Human SfRvicfs-EouCATiOH 240 CuMOM 8u«iMi*0 „„:,,» «.r'°' CongreW of ttje l»»-4»2 OFFICIAL CONDUW nsTWCT OfflCI FIMKAL BU'lOtMC 4ftO GOiOiN G«T1 AVIMUt March 11, 1993 '•owckissional WOBKIWe Gbouf "^ China. Chair The Honorable Gerry E. Studds Chairman House Merchant Marine and Fisheries Comiaittee 1334 Longworth House Office Building Washington, D.C. 20515 For inclusion In the proceedings of the hearing on watershed management practices and the role of hatcheries in the recovery of salmon populations. Dear Mr. Studds, The winter run Chinook salmon are listed as "threatened" under the Endangered Species Act and "endangered" under California law. There is current consideration by the National Marine Fisheries Service to also list the species as "endangered" under federal law. Because of this dire situation, I am writing to bring to your attention the Winter Run Chinook Salmon Captive Broodstock Program, a program to preserve the population of the winter run Chinook salmon of the San Francisco Bay-Delta Estuary. The winter run Chinook has a unique gene adaptation to the Sacramento River. In the 1969 this species numbered more than 100,000 fish, enjoyed spawning grounds far upstream and flourished in a relatively healthy ecosystem. This has all changed and the Chinook spawning population has declined to 191 fish in 1991. The captive broodstock program is already underway. As of September 1992, 1,000 juvenile salmon are being raised in captivity for 3 years until maturity when they will be spawned and their progeny fish will then be returned to the wild. Research of the fish during the adult stages of their life history is also being conducted and has provided original methodology for genetic identification. The program has a projected 10-year life span, hopefully enough time so that habitat conditions can be sufficiently Improved and the population can thrive once again. The program has been Implemented in order to genetically preserve the species by supplementing the natural population, and as part of a comprehensive and cooperative effort to restore water quality and a habitat that can support the natural wildlife of the region. Actions already taken to protect winter run habitat include: reduction of water diversion at the Glenn- Colusa Irrigation D4,gt?riM^pRMA*iiW J*ftRR*i««MM» °^ striped bass 334 March 11, 1993 Page Two in the Sacramento Delta, bypassing the powerhouse at Shasta DeUB to provide cool water in the upper Sacramento River and monitoring the permit process for the dredging of the ports of San Francisco and Oakland. This program is the result of a cooperative effort by representatives from the Department of the Interior, National Marine Fisheries Service, U.S. Fish and Wildlife Service, Pacific Coast Federation of Fisherman's Associations, California Department of Fish and Game, California Department of Natural Resources, U.S. Bureau of Reclamation, California Water Commission, Golden Gate Sportsf isherman's Association, University of California Bodega Bay Marine Laboratory and the California ^Academy of Science's Steinhart Aquarium in San Francisco. 1 We have a problem in our region that encompasses the many different animals, plants, fish, rivers and streams that maXe up a complex ecosystem throughout the Bay-Delta Estuary. These problems need to be treated with a comprehensive, coordinated effort that aligns the policies of the different agencies involved. The Winter Run Chinook Salmon Captive Broodstock Program is an example of just such an effort. I am currently in the process of drafting legislation that would authorize funding for the remaining nine years of the program and help to alleviate this serious problem for the Bay Area. Consideration of this authorization by your Subcommittee would be greatly appreciated. Thank you for including my letter in your subcommittee's hearing record for March 9, 1993. I look forward to working with you on this important project for the Bay Area. Best Regards, \ \ajv\ Nancy Pelosi o fiR-T^R ^^441 BOSTON PUBLIC LIBRARY 3 9999 05982 605 5 ISBN 0-16-040956-X 9 780160 409561 0000