NFS

N A T I V E F I S H S O C I E T Y

Conserving biological diversity of native fish and protecting their habitats

November 16, 2005

Todd Alsbury, District Fisheries Biologist

Oregon Department of Fish and Wildlife

17330 SE Evelyn Street

Clackamas, OR 97303

RE: Comments on the Sandy Hatchery HGMP for summer steelhead

Dear Mr. Alsbury,

The Native Fish Society appreciates the opportunity to comment on this important HGMP for the Sandy Hatchery summer steelhead program. I request that these comments be included in the record among the many that you have gotten on this important subject. I thank you for writing this most complex paper in a way that is clear, logical and readable, no small task given the subject.

Page 2. 1.2: This section should note the source of the summer steelhead (SS) stock by including its origin as a composite of Washougal and Klickitat wild summer steelhead brought into cultivation in 1956.

Page 5. 1.7: It would be helpful to include a summary of the U.S. v Oregon agreements, so that they are in the record and provide a context for hatchery operations.

Page 7. The HGMP does not make a claim that the summer steelhead hatchery program is consistent with the NFCP in this section near the top of the page but I see it is stated near the bottom. It would be useful to provide some examples of this compliance for reference.

Page 8. 1.10.2: Performance indicator 6a: State the survival guidelines used.

(Note: This comment holds for numerous parts of the HGMP. Since this is a snap shot of the present operation protocol there should be more detail so that people coming along later can use this document for a reference. )

Page 8. Performance standard 7: Pathogens in hatchery effluent are not monitored or treated. This poses a risk to native fish in the river.

Page 9. Performance standard 9: ODFW assumes that risks associated with hatchery-wild salmonid interactions are addressed with attention to smolt condition and time and area of release. Impacts from predator attraction to the release of hatchery smolts and potential impacts on wild fish and ecological interactions such as competition with and predation on native fish are not addressed. These factors should be included in the performance standards on risk.

Page 12: Issue 1: Explain the ODFW standards on stray rates for hatchery summer steelhead. Will stray rates be determined based on the number of hatchery SS spawning naturally in the whole basin? Will stray rates apply only to the river above the Marmot Dam site? If stray rates are greater than the standard above Marmot, but are below the standard for the whole basin, and the standard is met, then is the stray rate in compliance? I ask this question because the basin above Marmot has been managed as a wild fish reserve and it would seem important to make sure that this portion of the basin, specifically, is in compliance with the standard for stray rates.

The NMFS held a technical workshop on stray rates and the recommendation of this workshop was that non-native fish stray rates be 5% or less, saying, “The panel found no genetic justification for allowing gene flow from non-native fish at levels as high as 5%.” (Grant 1997) The SS are a non-native fish, and once Marmot Dam is removed these fish will have access to the upper basin and interact with wild winter steelhead, a listed species. The ODFW stray rate standard is 10%, but the NMFS uses this standard only for integrated hatchery fish using native broodstock.

The HGMP should state what stray rate standard will be used and where and how it will be applied.

Since wild winter steelhead spawn in the Sandy River below Marmot Dam and are subject to interbreeding and ecological interaction with non-native summer steelhead, the stray rate should be 5% or less for this portion of the river as well. I am still concerned that if the stray rate standard is for the whole basin, it could mean that certain portions could have more than a 5% stray rate as long as the standard is met for the entire basin.

Page 12: Issue 2: The only way to avoid the issue of passing non-native naturally produced summer steelhead above Marmot Dam once it is removed, is to eliminate releases of hatchery summer steelhead in the Sandy basin.

Kostow (2003) found in her research on the Clackamas River that this same summer steelhead stock did in fact reproduce and generated smolts, but the smolt to adult survival was low and produced very few adults. The hatchery release of smolts did however, produce adults, so in order to keep the fishery going, the hatchery was essential. In Kostow’s research the interaction between non-native summer steelhead and wild winter steelhead was primarily ecological, affecting the juvenile stage. When summer steelhead spawners were removed, the wild winter steelhead smolt yield doubled (Doug Cramer, PGE, personal communication).

It is likely that the same scenario is happening on the Sandy, depressing the production of wild winter steelhead through ecological interactions with non-native hatchery summer steelhead releases.

Under natural conditions winter and summer steelhead populations occupy different portions of a single watershed and this separation is normally caused by a hydrologic feature such as a waterfall. The water fall is a barrier to winter steelhead adults, but during low flow periods, summer steelhead can gain access to the river above the falls (Wither 1966). Marmot dam serves as that barrier now, but once it is removed, the two races of steelhead will have access to the same spawning and rearing environments and be in direct competition.

Page 12. Issue 4: Evaluation of recycled anadromous fish should be a research project noted in this HGMP. ODFW and other agencies recycle hatchery fish to provide more angling opportunity, but the biological effect of recycled steelhead is unknown. It could lead to increased catch of non-target species (wild winter steelhead), increasing the incidental mortality potentially take under the ESA. As stated in the HGMP, recycled fish may also stray and increase interbreeding and ecological competition.

My recommendation is to not recycle summer steelhead so that these biological and take impacts are not increased on ESA-listed winter steelhead.

Page 12. Alternative 1: The HGMP suggests ways to modify the summer steelhead hatchery program to potentially reduce the impact of these non-native fish on ESA-listed fish, but funds are not available to accomplish this work. Given this problem it is suggested that ODFW could reduce summer steelhead smolt releases, but this could affect the recreational fishery. Adjustments in management of hatchery summer steelhead and impacts on the fishery seem to be the driving concern of ODFW in this HGMP. Given the status of native wild populations of winter steelhead, coho, spring chinook, and fall chinook, all ESA-listed species, it is time for ODFW to think outside its traditional box and adopt as its priority the recovering ESA-listed species.

Page 12. Alternative 2: This alternative would eliminate the release of non-native summer steelhead in the Sandy basin and would “eliminate all potential risks to the wild winter steelhead population due to potential interactions with summer steelhead.” ODFW worries about the impact on the recreational fishery and sums up by saying, “There is currently no information to document that this program is impacting wild winter steelhead in the basin.”

This conclusion can be taken two ways. 1) ODFW looked at the scientific literature, conducted research and found nothing; or 2) ODFW did not look and did not conduct any scientific evaluation in the basin and concluded there was no information to document an impact. This conclusion is ambiguous. The HGMP should state what ODFW did to determine that there is no information to document an impact to ESA-listed winter steelhead.

It is surprising that ODFW “found no information to document” an impact when their own staff published research on the Clackamas River, an adjacent watershed, and evaluated the impact of this same summer steelhead stock on ESA-listed winter steelhead. Based on this research there is very likely an impact on ESA-listed winter steelhead caused by non-native hatchery summer steelhead.

Other research confirms the findings of Kostow (2003). For example, steelhead research on the Kalama River shows that wild steelhead perform better than the hatchery fish in the stream, producing more smolts and returning more adults per female. Ecological risks remain a concern since the hatchery fish do spawn and produce juveniles and may be replacing wild juvenile production through competition for food and space. (Patrick Hulett, WDFW, personal communication)

Given the risks and the apparent lack of a rigorous research, monitoring, and evaluation program by ODFW regarding interactions between wild and hatchery steelhead, the only logical conclusion is to eliminate the release of hatchery summer steelhead in the Sandy Basin.

Page 13. Alternative 3: This alternative proposes a study to determine whether hatchery summer steelhead are reproducing naturally in the basin and the potential impacts on wild ESA-listed winter steelhead. However, no funds have been identified for this research.

The ODFW could elect to have Mark Chilcote and Kathryn Kostow conduct a literature review of the key science questions to be addressed by this proposed study. This literature review would provide information needed to develop management options. This approach would cost less, take less time, and provide the results needed to inform a management decision.

Page 13. Alternative 4: Residualization of summer steelhead smolts are recognized as a potential problem that should be investigated. The concern is that these smolts that do not leave the river are effective competitors and predators on juvenile wild salmonids in the river. However, no funds are available for conducting this evaluation.

ODFW could, alternatively, conduct a literature review and contact scientists that have studied residualization and its effects. The Kalama Research Station has conducted research on steelhead residualization using the same summer steelhead stock being released in the Sandy River. Results so far show a residualization rate of 1.5% to 4.7% (Native Brood stock winter steelhead) of the number of fish stocked. Based on this study, native broodstock hatchery fish have a higher residualization rate than more domesticated hatchery fish because the native brood stock fish survive better (Patrick Hulett, WDFW, personal communication).

The ODFW sums up each section under the alternatives saying: “…elimination or reduction of the program (hatchery summer steelhead) could impact a popular recreational fishery and result in opposition from the sports fishing industry and anglers. This boiler plate repetition suggests that all anglers would oppose a management decision to protect ESA-listed winter steelhead. This is not universally true. I am aware of a number of organizations that would support this change, including Trout Unlimited, the Federation of Fly Fishers, and Native Fish Society among others. If the agency would explain the situation and ask anglers for their response, there may be more agreement than the statement claims. Using the angling community and merchants to avoid conservation management and recovery of ESA-listed species is not consistent with the law or the mission of the agency. ODFW has been critical of sister agencies that pander to their constituents or use them as an excuse to not protect streams and fish habitat. How is ODFW any different when it uses its constituency for the same purpose?

Page 13. Alternative 5: The study on summer steelhead natural spawning and juvenile production and potential impacts on ESA-listed wild native winter steelhead is needed to inform management and recovery efforts. However, a review of the Kostow (2003) study evaluating the interaction of non-native summer steelhead on native and listed wild winter steelhead in the Clackamas would be informative. It is likely, based on this information and that is produced by research on the Kalama River, that additional research would not be necessary on the Sandy River. Kalama River steelhead research did show a genetic exchange between hatchery summer steelhead and wild winter steelhead. This research showed that there was a low level of gene flow between hatchery summer steelhead and wild winter steelhead for four brood years (Patrick Hulett personal communication).

It could be stipulated that non-native summer steelhead do spawn naturally and do suppress natural production of winter steelhead. If these completed research were extrapolated to the Sandy River situation, the expense of additional research could be avoided. In addition, since this kind of research requires several years to complete, the delay in taking action on resolving the ecological impact of summer steelhead on winter steelhead could also be avoided. In this way the department could take immediate action.

Page 14. 1.16.3 Research-reform and investments: All these research proposals are sound and are important to inform summer steelhead management alternatives. As stated above some of this research has already been done and could be used to inform decisions on the Sandy, eliminating the expense and the delay in taking management action.

Once Marmot Dam is removed non-native summer steelhead (and other hatchery salmonids) will have access to the wild salmonid sanctuary portion of the river above the dam location. In order to prevent this threat to wild salmonids it is important to develop a barrier to hatchery fish passage, acclimate hatchery fish to reduce straying, or eliminate hatchery releases. What is unknown is whether strays can be controlled by acclimation. Until this is monitored and evaluated, this strategy remains a critical uncertainty. It should be added to the research section of the HGMP.

In the short term, hatchery releases should be reduced or eliminated until critical uncertainties are resolved.

Page 20. The proportion of wild and hatchery steelhead spawning naturally below Marmot Dam is not now quantified. The NFS has never accepted the notion of managing only the river above the dam for wild steelhead and ignoring the wild steelhead spawning in the river below the dam. This bifurcated structure imposed on the river is an artificial construction that is not related to the actual distribution of wild steelhead in the basin. However, since this bifurcation scheme was adopted the wild steelhead below the dam have been ignored. A research program to identify the numbers and distribution of wild steelhead below the dam is needed and it is important to determine the interactions between hatchery and ESA-listed wild steelhead below the dam in this HGMP. Until there is a commitment through this HGMP to determine the impact of hatchery fish on wild salmonids spawning below the dam, and the management response, the HGMP is flawed.

The hatchery program impacts on wild fish populations below Marmot dam are un-quantified, so the take of ESA-listed species below the dam remain un-quantified. This HGMP should address and resolve this issue.

Page 27. Competition: The HGMP recognizes that “…there is little data to substantiate whether competitive interactions are occurring in the Sandy basin,” between hatchery and wild salmonids. This data gap represents a critical uncertainty that the HGMP must resolve. In addition, competition assessments should not be confined to the Sandy basin. Impacts of hatchery fish on wild and ESA-listed species in the Columbia River should also be evaluated. The impact of hatchery steelhead on ESA-listed chum, chinook, sockeye, and steelhead are of concern. Perhaps this points out a limitation of the HGMP concept, for it tends to be limited to evaluating subbasin impacts, leaving hatchery related impacts in the Columbia River and estuary unevaluated and unresolved.

Page 28. Disease: If bacterial, fungal, or viral diseases have been identified in the Sandy River hatchery programs, these should be identified in a table by disease, species involved, and date of the event.

Page 28. Predation: According to the HGMP predation from hatchery fish or from predators attracted to hatchery fish and impacts on wild fish are un-quantified. This data gap should be included in a research plan for resolving critical uncertainties associated with this HGMP. Again, the effect of hatchery releases on predator attraction in the Columbia River is not addressed.

Page 28. Positive benefits of the hatchery program: The HGMP states that “Hatchery production has the potential for playing a role in the population dynamics of predator-prey relationships and community ecology during low productivity and shifting climatic cycles.” The HGMP should expand upon this claim by providing some examples and whether there has been any evaluation.

Page 29: Hatchery fish screens: The HGMP states that the hatchery fish screens are “non-compliant to current NOAA Fisheries…criteria.” This problem should be addressed and a time line presented for bringing screens into compliance.

Page 30. 4.2: The hatchery barrier has blocked 12 miles of spawning and rearing habitat on Cedar Creek. Passage for wild fish at this barrier should be included in the HGMP as a priority action with a specific timeline for completion.

Hatchery effluent is not monitored for pathogens, but poses a potential impact to wild salmonids downstream. The HGMP should include monitoring of pathogens in hatchery effluent as a priority action with a specific timeline for completion of a treatment solution.

Page 54. Research: In the comments above I have identified a number of research opportunities that should be included in the HGMP. There are a number of data gaps identified in the HGMP that could have an effect on ESA-listed salmonids. For example, the document states: “While there may be competition between hatchery smolts and naturally-produced smolts in the mainstem Sandy River, these effects have not been quantified.” (page 21) Also, “No quantified data exists for the total number or proportion of hatchery and wild fish spawning naturally below Marmot Dam.” (page 20)

Thank you again for the opportunity to review and comment on this HGMP.

Sincerely,

Bill Bakke, Director

References:

Cramer, Douglas, personal communication

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

Hulett, Patrick, personal communication

Kostow, K. E., Anne R. Marshall, and Stevan R. Phelps. 2003. Naturally spawning hatchery steelhead contribution to smolt production but experience low reproductive success. Trans. Am. Fish. Soc. 132: 780-790.

Withler, I.L. 1966. Variability in life history characteristics of steelhead trout (Salmo gairdneri) along the Pacific coast of North America. J. Fish. Res. Bd. Canada, 23(3).