NATIVE FISH SOCIETY


P.O. BOX 19570


PORTLAND, OREGON 97208


503/977-0287											


June 20, 1997





Mark Chilcote


Fish Conservation Program Leader


Oregon Department of Fish and Wildlife


P.O. Box 59 


Portland, Oregon 97207





Dear Mark:





Thanks for asking for my comments on the department's report Conservation Status 


of Steelhead in Oregon.  You asked for my comments on listing and de-listing 


section and recommendations.  In addition, I would like to address some other 


portions of the report such as the methods and Mid-Columbia River ESU section.





METHODS:





To begin, I read the Methods Section regarding the model used to determine the 


status of native steelhead in Oregon.  While this model may be a useful tool in 


assessing native steelhead status, it relies on a larger number of assumptions, a 


poor data base on native steelhead populations such as abundance, no discount for 


hatchery fish reproductive success, a poor data base on native steelhead age 


composition by population and other data problems.  These data problems would mean 


the model is able to create a general frame of reference to compare native 


populations, but the power of the model to describe the actual status of 


populations and therefore ESUs would seem to be weak. Given the poor data base one 


has to try and assemble what is known and do the best possible evaluation.  


However, I would hesitate to use the model as a means to describe status of native 


populations or ESUs.  I believe that the problems of this model show up in the 


assessment of the Mid-Columbia ESU where in the summary section the model fails to 


adequately describe the condition of the Deschutes summer steelhead.  On page 81, 


the following statement is made:





	"...extinction for the seven populations examined for this ESU is zero over 


the next 100 years.  However,...this is probably the wrong conclusion for the 


Deschutes population because of the dramatic reductions in productivity that have 


occurred during the last 3 years."





	The Deschutes summer steelhead data base is relatively rich compared to data 


on most other streams, populations, and ESUs, such as the SW Washington ESU, so I 


am forced to wonder how well the model is able to describe the status of native 


populations where the data is poor and the problems are more subtle.  


This model should be verified before it is used as a tool to assess the status of 


native steelhead and the assumptions should be critically reviewed.  The model 


should be subject to independent scientific peer review before ODFW uses it as a 


definitive tool to describe steelhead status.  





MID-COLUMBIA ESU:





This section overlooks the effects of ten years of drought on populations in the 


John Day and Deschutes rivers.  The years 1982 and 1983 were abnormally wet years.  


This wet, cool weather cycle improve freshwater rearing and migration conditions 


over the preceding years.  If one looks at the smolt survival passage at mainstem 


Columbia River dams and resulting adult returns in the Snake River, there is a 


positive response with increasing adult returns.  Likewise, if one looks at the 


spawner counts in the John Day River (page 77) there is a similar response in 1 


and 2 salt adult returns following this wet cycle in 1986, 1987, and 1988.  


Following this wet, cool period, there is a ten year drought and poor ocean 


productivity.  Both the freshwater and ocean rearing conditions deteriorated and  


native salmonid populations declined to low levels again.  The cool, wet cycle of 


1996 and 1997 will probably improve rearing conditions and if the ocean 


productivity is relatively good, the adult spawner numbers in the John Day and 


Deschutes should increase.





The problem as you point out is: Are the populations exhibiting enough resilience 


to respond to favorable environments ?  This is the key point.  In your assessment 


of the John Day you say, the " lower mainstem tributaries and  South Fork show the 


least indication of bouncing back to equilibrium abundance levels" (page 78).  


That is predicable given the  poor habitat conditions in those areas. The 


combination of habitat degradation, drought, poor ocean survival, predation, 


mainstem passage, and harvest become more than a population can withstand.  Their 


reproductive potential is not enough to compensate for these combined stresses.  


Eventually, these populations lose resilience and are unable to respond to 


favorable environmental conditions.  On the Deschutes, one more complication you 


mention is also a factor, that is, the disorganizing effect of out-of-basin strays 


on the native gene pool and the resulting lowered survival of hatchery/wild 


crosses in the natural environment.





On page 76 you say:  "The environmental conditions within the Deschutes basin have 


remained relatively unchanged over the last 10 years.  Because of this observation 


and the ecological similarity between resident rainbow and steelhead, it is 


difficult to hypothesize habitat loss and degradation has been the cause of the 


wild steelhead decline over the last 10 years. "  This is true if you only 


consider the mainstem, but it may not true if you consider the small tributaries 


entering the mainstem.  Many of these small tributaries flow in March through 


June, then they dry up entirely or in their lower mile or two.  Lets look at one 


tributary that fits this profile, Eagle Creek at Dant ( I am enclosing a review of 


this stream with this letter).  This stream during cool, wet cycles is open to 


steelhead spawners in March and for outmigration of parr until mid-June.  The 


lower two miles of stream go dry as the water subs-out into the gravel in June.  


However, above this point the stream flows year round and supports juvenile 


steelhead.  In the next March this stream opens up and juveniles and smolts can 


enter the Deschutes.  My recent visit to this stream revealed thousands of parr 


rainbow/steelhead in the first two miles of this stream.   I would suggest that 


these streams have selected for a  steelhead life history similar to Rogue River 


summer steelhead described by Fred Everest. 





These small tributaries to the lower Deschutes could be very important to wild 


steelhead productivity.  The ten year drought, however, did have a large effect on 


the productivity of these small streams, many of which were not accessible to 


adult spawners.  The mainstem then, becomes the alternative for spawning. 





Recent work by Chris Zimmerman on early life history interactions between 


steelhead and resident rainbow has shown that steelhead smolts from Ten Mile 


Creek, a small tributary of Trout Creek, produces juveniles that are twice the 


size and are in better condition than juveniles of the same age in the mainstem 


Deschutes.  The warm water environments of these small streams may be giving the 


steelhead that use them a competitive advantage during early life history. 





Is it possible that these small streams are vastly more important to wild 


steelhead production than thought?  Could the effects of drought on these small 


streams be a factor in wild steelhead decline?  Are these small streams also a 


refuge for the native gene pool of wild Deschutes steelhead where they are less 


affected by strays from other Columbia River streams and hatcheries?  These 


questions are important to assessing the status of Deschutes River native 


steelhead.


 


	I believe the assumption that the Deschutes was "relatively unchanged over 


the last ten years" is wrong because it does not consider the effect of drought on 


tributaries during the last ten years and the effect on wild steelhead 


productivity that these tributaries represent. 





Your point about the resiliency of the population, however, is valid as is the 


effect strays may be having on the reproductive potential of native Deschutes 


steelhead.  I believe your assessment of stray steelhead is important and this is 


a factor affecting the Deschutes more than other mid-Columbia tributaries you 


evaluated.  I have supplied you with my letter to the National Marine Fisheries 


Service where I review the increased stray


rate of steelhead exposed to truck transport on the Columbia using their own 


technical reports.  The stray rate can be reduced considerably in the Deschutes if 


trucks are no longer used to transport steelhead.  This would allow the native 


steelhead in the Deschutes to reorganize and increase their fitness to the 


environmental conditions of that system.  This, in combination with improve 


habitat conditions on small tributaries in the lower Deschutes, would be the path 


of choice for restoring native steelhead in that system.  As you note, the 


situation is severe and action must be taken immediately. 





The long-term health of native steelhead is a major issue for all systems 


evaluated.  I was encouraged by your assessment of the Umatilla steelhead and the 


apparent lack of degrading effect of the hatchery program using native stock.  


However, the lack of effect may be a factor of our gross measurements.  It is 


important to establish a better understanding of steelhead life history to 


determine if long-term health of these populations are actually being maintained 


by fish management practices and habitat


management.  For example, the Deschutes River steelhead management program has 


focused on hatchery mitigation for hydro dams, but it has overlooked the selective 


pressures of mainstem Columbia net harvest and the value of small tributary 


production.  Consequently, when the native steelhead decline to very low levels we 


notice a problem that escaped  earlier detection.





It is not good enough to say the hatchery program on the Umatilla is not having an 


effect when our ability to measure effects is on such a gross level. Domestication 


selection in hatcheries is becoming an issue that should be factored into 


assessments of native steelhead health.  Apparently, even if a hatchery brood 


stock is derived from a native stock and constantly refreshed with native stock, 


the hatchery population still diverges from the original wild stock, causing 


lowered fitness of the hatchery fish in nature.  The interbreeding between 


hatchery and wild stock then causes the wild stock productive potential to 


decline.  The status review does not discuss this problem, but it should.  Strict 


gene and life history diversity protocols have to be established for each hatchery 


program, including those in other states that produce potential strays, in order 


to maintain the reproductive fitness of locally adapted native populations.  It is 


equally important for harvest to be managed to make sure the escapement numbers 


support genetic diversity and nutrient loading for native populations.  In 


addition, the habitats that locally adapted native populations rely upon must be 


restored and protected in order to maintain the gene and life history diversity of 


native populations.  All these factors are key to maintaining the long-term 


resilience of native populations so they can respond effectively to a fluctuating 


environment. But our management of steelhead and other salmonids has not been 


effective in this regard because it is production rather than ecologically based.





Your assessment has been able to pick up on gross changes in steelhead health but 


it is not adequate, given the lack of data, to determine risk. All the evaluated 


populations are at risk until there is a better data base on the life history and 


genetic diversity, harvest and hatchery impacts on that diversity, and the habitat 


conditions and trends that maintain that diversity.





While your model is a valuable tool to peek, in a gross way, into the status of 


steelhead in the areas evaluated, it is not adequate to describe the long term 


health of these populations.  We have learned by recent history that the 


combination of prolonged drought, poor ocean productivity, passage mortality on 


the Columbia, harvest, hatchery interactions, and habitat degradation are more 


than steelhead reproductive potential can cope with.  When all these "stars" line-


up, native populations crash.  These factors represent a real problem for native 


populations that are small and less productive.  These populations, however, are 


vital to the long-term health of the metapopulation (ESU) and represent the 


adaptive margins and important genetic and life history diversity within the 


species.  A management program that tries to maintain the larger populations but 


provides no protection for small less productive populations cannot sustain the 


health of the resource, yet that is the management program we have in place.  The 


model you have developed is still not strong and robust enough, primarily because 


of assumptions and poor data, to pick up subtle changes in native steelhead 


productivity that over the long term accumulate into big changes as seen on the 


Deschutes. 








COMMENTS ON LISTING RECOMMENDATIONS:





This steelhead status review will, no doubt, be sent to the National Marine 


Fisheries Service.  As you know the only two categories for listing are threatened 


or endangered.  However, you add the categories sensitive and critical to this 


status review.  Consequently, your status review, from the perspective of federal 


listing, would support a threatened listing for only the Upper Willamette ESU, and 


all other ESUs would be "unwarranted."    This assessment is a mixed bag, aimed 


more at a state process than a federal listing of steelhead.  It would be helpful, 


if the section on listing, at the end of the status review, would evaluate the 


status of steelhead in Oregon for both the federal and state Endangered Species 


Acts.  By doing this, the status review would be made less confusing.





On page 101 you give weight to the model over other indicators of status such as 


hard data.  I believe this is a mistake because the poor data base and assumptions 


in running the model cause it to be a rather weak evaluation of extinction 


probability.  In addition, there seems to be disagreement between what the model 


predicts and what the indicators reveal about status of many populations of these 


ESUs.


 


The status review also assumes an improving ocean production and presumed positive 


effects from fishery and land management changes (page 101).  The status review 


ought to consider the present condition of the populations in question rather than 


factor in  assumed benefits form changing natural climatic cycles and management 


actions. This skews the status review and creates a bias founded upon some future 


condition.  This approach is inappropriate and weakens the status review.  If you 


wanted to explore how assumed positive changes in climate and agency action may 


benefit populations, then the status review should have three scenarios:  Status 


review based on current conditions, a review based on potentially improved 


conditions, and one based on potentially degraded conditions.  This would provide 


a range of potential status levels for each population evaluated along with an 


assessment of population status uncolored by predictions and assumptions.





Not only does the model lack the power to determine the status of  an ESU, there 


is the problem of the ESU itself.  The ESU is, in effect, an aggregation of native 


populations that form it.  Some populations are strong, others are not.  The 


status of the ESU is determined by the status of the populations that compose it.  


A large strong population combined with a few small less productive populations 


into an ESU could lead to an ESU not being listed.  This problem should cause the 


ODFW concern, because populations that should get conservation management 


protection may not get it.  The status review report, however, is more concerned 


with trying to convince NMFS to not list steelhead than it is in making sure that 


native locally adapted populations that need recovery get the protection they 


need.





I evaluated your recommendations for listing and found them more or less 


inconsistent with the following ESUs: Snake, Mid-Columbia, SW Washington, 


Willamette, and potentially the Oregon Coast ESU.





Snake ESU:  





Population:  Upper Grande Ronde





Rated:  Sensitive and unwarranted for minimum population abundance





Comments:





Minimum Populations Abundance rates this ESU as Unwarranted for listing.  However, 


according to text on page 85, the upper Grande Ronde population has been 1/3 of 


estimated equilibrium population size.  This population has declined since 1989 to 


very low levels and shows little if any sign of rebounding.





The rating of unwarranted on page 99 is inconsistent with the assessment of this 


population on page 85, and this inconsistency is not explained.  Consequently, the 


unwarranted rating appears to be a mistake, and may have an effect on the Snake 


ESU status for Oregon (see table 34, page 99).





Mid - Columbia ESU:





Populations:  Deschutes River, lower mainstem John Day, and SF John Day:





Rated:  Sensitive and unwarranted Minimum Population Abundance





Comments:





Deschutes River





On page 75 of the status review, it says: "the native steelhead population will 


remain at very high risk" (until stray steelhead numbers are reduced).





On page 80: The "reproductive ability of this population has failed dramatically 


in the last 3 brood years with an average of only 1 recruit produced for every 10 


spawners. Clearly the probability of extinction will go to a level of 1.0 (meaning 


extinct) if  reproductive performance remains at the current level..."





On page 81: "Deschutes wild steelhead populations are not self-sustaining, at 


least in the last three years."





The status review is not consistent with the rating of unwarranted for this 


population on page 99 under Minimum Population Abundance.  This inconsistency is 


not explained.  





John Day River





	


The lower mainstem and SF John Day River are rated as unwarranted under the 


category Minimum Population Abundance.





On page 78, "the lower mainstem, upper mainstem and the South Fork John Day 


populations have remained in a depressed state for several years.  During the last 


4-years, they have been less than 1/3 of the equilibrium level estimated for these 


populations...  The low levels observed for these populations in the 1990s extends 


over a longer period of time than during the last low population level in the 


1970s."





"...the South Fork and the lower mainstem show the least indication of bouncing 


back to equilibrium abundance levels."


"...the lower mainstem and SF John Day populations are the least healthy of the 


five populations" in the John Day."


"a clear signal that steelhead densities in this basin have bottomed-out and are 


returning to expected levels is not suggested by the data."


"Should this....continue....two or three more years...would be grounds for being 


concerned about the....productivity and health of these populations."





The status report findings are not consistent with the conclusions in the report 


regarding the Deschutes and John Day rivers.  This inconsistency is not explained.  


It appears that this inconsistency has been overlooked in development of 


recommendations because the recommendation of sensitive for this ESU rather than 


threatened or endangered is not supported by the data base.  As stated above, I 


believe the lack power in the extinction model due to poor data and the 


assumptions used is one problem.  Another problem is the model is being used to 


overwhelm the data that is known about populations.  As stated in the text, the 


model concluded for the Deschutes River the population would not go extinct in the 


next 100 years, but, as you noted on page 81, the facts did not agree with the 


model's findings.  I believe the model's findings for the John Day is likewise 


flawed and ignores the data on population status.





S.W. Washington ESU:





Rated:  Minimum Population Abundance: Not Warranted, and recommended Sensitive.





Comments:





On page 43 of the report it says: "The lack of abundance data for the populations 


in Oregon's portion of the ESU makes it difficult to assess their status."  This 


No Data No Problem assessment leads to the conclusion: "that these populations are 


not at risk of extinction."  





While this may be true, how does the ODFW know its true? There is no data support 


for the conclusion.  This section, more than other ESU evaluations, reveals the 


strong bias in the status report to minimize problems and to protect steelhead 


from being listed as a federal protected species.  The status review says this 


about the evaluation used: "Based on a rough averaging...it was inferred that the 


SW Washington ESU populations in Oregon were not at immediate risk, although they 


are likely to decline."  Most populations in the ESU have been exposed to large 


hatchery releases for decades, wild runs have been blocked at hatcheries to 


protect the hatcheries form disease, and they have been exposed to heavy fishing 


pressure as well a the usual habitat degradation.  Consequently, the conclusion 


for this ESU is probably not correct, but the status review doesn't present 


information to refute the conclusion or to support it.


Oregon Coast ESU:





Rated:  Minimum Population Abundance: Not Warranted, and recommended Sensitive.





Comments:





The status review of this ESU samples only a few of the populations that exist.  


For example, the South  Umpqua winter steelhead are not mentioned, yet they are 


one of the most depleted wild steelhead populations in the state. Another  


"extremely depressed" population that was mentioned is the Siletz summer 


steelhead. The rating of this ESU as sensitive may be true, but the data base is 


not strong and some very depleted populations were not evaluated, so the ESU could 


also be threatened.  A lot of emphasis has been placed on promises to reduce 


hatchery fish programs in many basins, but there is no analysis of how these 


hatchery program may have affected the fitness of the locally adapted populations 


in this ESU.  If these locally adapted populations have reduced productive 


capacity due to harvest and interactions with hatchery fish, then the conclusion 


of the report may be incorrect.  However, the report doesn't present enough 


information to actually evaluate the status of wild steelhead in this ESU and 


fails altogether to evaluate some populations that are in trouble.





Klamath Mountains Province ESU





Rating:	Listing not warranted.





Comments:





The middle Rogue summer steelhead are identified as  populations in severe 


decline.  The report says: "There is good reason to be concerned about its 


continued existence" (page 22).





A disturbing aspect in the report is the very different conclusions about the 


status of wild steelhead in this ESU developed by NMFS and ODFW.  The NMFS 


evidence that wild steelhead in this ESU are declining and were unable to 


demonstrate that any steelhead stocks are naturally self-sustaining.  While the 


report seeks to explain the reason why ODFW and NMFS reviews are in contradiction 


of one another, it is apparent there is a dispute that should be resolved by a 


thorough independent scientific review.  





Willamette ESU





Rating:	Threatened





Comments:





The status review for this ESU shows that recruits per spawner are near or below 


replacement, the native steelhead are exposed to interbreeding with exotic, 


domesticated winter and summer steelhead stocks, and most steelhead populations 


have declined to "record low spawner densities."  These data could be used to 


argue for an endangered listing for the ESU.  The evaluation of this ESU should be 


independently evaluated by scientists to make sure the assessment is accurate and 


the rating is justified.





CONCLUSIONS:


 


	The status review helps  identify problems that need immediate solution, but 


it is not adequate for describing the status of steelhead over the next 100 years 


and predicting the risk of extinction for all components of the steelhead 


metapopulation or ESU.  The data base is poor, there are numerous assumptions that 


need to be validated, the sample of steelhead populations is small, hatchery 


introgression and the effect on fitness is discounted, new and future management 


actions are given more weight than decades of poor conservation management in 


terms of impact on population health, the conflict between NMFS assessments and 


ODFW assessments need to be resolved, the model comes to different conclusions 


than the data at hand regarding status of populations and generally, the status 


report appears to be biased toward minimizing problems of steelhead status 


apparently in the attempt to build a case for not listing them as federal 


protected species.  These problems in the status report suggest to me that a more 


thorough independent scientific review of steelhead in Oregon needs to be 


completed so that the best possible assessment of steelhead status can be provided 


NMFS for their decision.  





I would appreciate the opportunity to discuss this status review in more detail in 


person with you.





Sincerely,





Bill M. Bakke, Director 





cc:





NMFS


Governor's Office


Environmental groups


	


Bill M. Bakke


Native Fish Society


June 20, 1997