NATIVE FISH SOCIETY
P.O. Box 19570
Portland, Oregon 97280
(503) 977-0287
Email:Ê bmbakke@nativefishsociety.org
http://www.nativefishsociety.org/
________________________________________________________________________________________________
September 20, 2004
Joyce Howard
NOAA Fisheries
525 NE Oregon Street, Suite 500
Portland, OR 97232
RE:Ê Comments on 2004 Draft Biological Opinion
Dear Ms. Howard:
The Native Fish Society appreciates the opportunity to review and comment on the new draft biological opinion.Ê We are submitting these comments for the record.
JUVENILE MORTALITY ASSESSMENT INADEQUATE:
In reviewing the information in the Biop on juvenile mortality we encountered specific numerical estimates of mortality from various predators; however the estimates for dam passage mortality were all in percentages.Ê This is comparing apples and oranges and fails to provide a compete mortality profile for juvenile salmonids in the mainstem Columbia River.Ê
We were forced to use information in the biop to calculate the dam passage mortality and convert it to numerical estimates so that an estimate of total mortality could be constructed using both predation and dam related mortality rates.Ê We used information in the biop stating that the mixed hatchery and wild smolt out migration is 200 million fish.Ê Based on this work we determined that the smolt mortality from predation is 27 million and the mortality caused from dams is 96 million.Ê
This calculation presents some additional information.Ê The dam related mortality is 31% higher than pre-dam conditions. Under pre-dam conditions 170 million smolts reached the ocean compared to current post-dam survival conditions where 104 million smolts reach the ocean.Ê If predation mortality and dam related mortality are added together, only 77 million smolts reach the ocean.Ê If the same predation mortality is added to the pre-dam level of smolt mortality, 143 million smolts reach the ocean.Ê This estimate is likely low since predation has increased as a result of dam construction where predator habitat has been improved and exotic predators have been added to the mainstem.Ê If this is taken into account 160 million smolts would reach the ocean under pre-dam conditions compared to 77million under post-dam conditions.
Pre-dam survival rates, based on these estimates, were 72% compared to 40% under post-dam conditions.ÊÊ If the pre-dam survival rate is corrected for less predator impact the survival rate would increase to 80% which is comparable to the estimated pre-dam survival rate of 85% in the biop (page 5-25).
To be a credible assessment of the pre-dam and post-dam survival rates, the biop should estimate the survival in numerical terms rather than in percentages.Ê The biop should calculate the impact on smolt survival in numerical terms and compare the pre and post dams conditions.Ê By doing this the biop establishes a credible impact estimate of dams on smolt survival.Ê In our opinion the draft biop has failed to provide a credible impact analysis of the dams on smolt survival.
By making improvements in the smolt mortality estimates for pre and post dam conditions, the NOAA Fisheries would more accurately describe the reference conditions in the biop.Ê Given this estimate the difference between the reference condition, pre-dam, and post-dam conditions, the deficit is 80 million smolts and 32% reduction in survival rates caused by the dams and the altered environment they have created. Ê
HATCHERY OFFSET IS INADEQUATE FOR WILD SALMON RECOVERY UNDER THE ESA
In reviewing the proposed NOAA Fisheries draft hatchery policy and the role carved out in the biop for hatcheries the Native Fish SocietyÊ concludes that using hatcheries as an offset to make up for dam related mortality of ESA-listed salmonids is not only mistaken, but takes the takes the draft biop in the wrong direction.
In section four of the biop the hatchery programs are reviewed.Ê According to this review there are 158 distinct populations and 98 hatchery programs operating in the ESUs.Ê In all but one case the NOAA Fisheries did not believe that artificial propagation programs were sufficient to substantially reduce the long-term extinction risk of the ESUs. The only exception was the upper Willamette River winter steelhead only because Oregon eliminated all releases of winter steelhead.Ê For each ESU the NOAA Biological Review Team routinely stated that contribution of hatchery programs to productivity of target populations was uncertain.Ê They did note that in many cases the hatchery programs increased abundance of fish, but could find no evidence that this abundance translated into increased productivity in naturally spawning populations of listed salmonids.ÊÊ This is not a surprising result and anyone with any familiarity with the scientific literature would find the BRTâs conclusions consistent with the best available science.
Since hatchery fish have lower reproductive success than wild salmonids (Kostow 2004; Chilcote 2002, 2003; Ford 2002; Fleming and Peterson 2001; Reisenbichler and McIntyre 1977), they are not a replacement for wild salmonids, but they do increase risk (Waples 1991).Ê When hatchery fish interbreed with wild fish smolt production from this mix is reduced and with it adult spawners are reduced in number the next generation (Nickelson 1986, Chilcote, 2003, Reisenbichler and McIntyre 1977). Ê
Kostow, 2003, was able to show that hatchery steelhead retarded the juvenile abundance and adult returns of wild steelhead through ecological interactions.Ê The hatchery steelhead were a summer-run stock which did not interbreed with the wild winter steelhead, so there was no genetic risk.Ê However, the juveniles produced by the summer steelhead competed with the winter steelhead juveniles in a common rearing environment.Ê The result was that the hatchery summer steelhead produced juveniles, suppressed survival of winter steelhead juveniles, but smolt to adult survival was low for the hatchery fish and few returned.Ê The release of the hatchery steelhead caused a decline in natural production of juveniles and adults in the wild steelhead population through ecological interaction.Ê
Hatchery salmonids effectively reduce the abundance and productivity of wild salmonids through genetic effects from interbreeding, and from ecological interactions.Ê This means that by adding hatchery fish to naturally spawning populations of ESA-listed fish, recovery will be impeded and jeopardy is not avoided. Ê
The claim by NOAA Fisheries that hatchery fish would cause no net reduction in the productivity of the ESUs or that there would be no ãappreciable reduction in the likelihood of both survival and recoveryä cannot be made. The evidence provided in Section Four of the biop by the BRT and NOAA Fisheries states repeatedly that contribution to productivity is uncertain.Ê ÊÊNOAA Fisheries cannot justify a hatchery offset for hydro dam operations, using the best available science, and pass the test that the biop actions do not impede recovery or avoid jeopardy.
In appendix F the hatchery reform projects are listed, however, these measures are required to improve protection of ESA-listed fish independent of the biop.Ê Using these measures as an offset for dam related mortality of salmonids adds nothing new, creating the deception that without the adoption of the biop these measures would not be done.Ê This is not true.Ê Ê
HARVEST ASSESSMENT IS INADEQUATE
The dams harvest the bulk of the smolts leaving the basin above Bonneville Dam and have blocked 55% of the watershed to anadromous fish access, causing a major loss in salmon production.Ê The dams have reduced the productive capacity of the basin and continue to consume the reproductive capacity of the salmon populations that remain. The salmon populations crash during periods of low ocean productivity (mid 1980s to 2000) and drought. Under these conditions the ESA-listed salmonids are unable to replace themselves and decline to very low levels with some going extinct.Ê The combined mortality from hydro dams and poor ocean and freshwater productivity present an obstacle the salmon cannot overcome.Ê Under pre-dam conditions, the salmon productivity was reduced in response to climate changes, but their existence was not imperiled.Ê They could survive the periods of low productivity.Ê This is not the case with the hydro dams in place.ÊÊ
In response to listing most populations of salmonids under the Endangered Species Act, NOAA Fisheries has reduced human harvest to compensate for the altered conditions of the basin from dam construction and operation.Ê Even though harvest rates have been reduced, NOAA Fisheries has not conducted a harvest accounting so that the impact of human harvest on ESUs can be determined.Ê It is uncertain whether the fisheries are impeding recovery of ESA-listed fish or not.Ê
The combined effect of all mortality caused by human use of the basin cannot be determined when evaluation is fragmented.Ê The failure to address the effect of all sources of mortality on ESA-listed salmonids in the basin creates the happy conclusion that no one source is likely to impede recovery or jeopardize the listed species.Ê As a result the hydro biop presents an incomplete assessment of impacts to salmon and makes it easier for NOAA Fisheries to find that the hydro dams do not impede recovery or jeopardize the continued existence of the listed populations and ESUs. We recommend that NOAA Fisheries establish a complete salmonid mortality profile for each listed population and that a harvest accounting evaluation be done to evaluate the effects on each ESU and population.
SHIFTING THE BASELINE
In this draft biop NOAA Fisheries is shifting the baseline on the salmon ecosystem by making the preposterous claim that the hydro dams are now the salmonâs natural habitat.Ê The existence of the dams would be a mere boulder in the stream under this biop.Ê Their effect on salmon mortality, distribution, abundance and productivity would be excused because they are assumed to be a natural part of the ecosystem.Ê ÊOnly some of the damâs operations could be questioned. ÊThere would be no operations that kill salmon if the dams did not exist.Ê This fanciful deception is needed to make the claim that the dams are not jeopardizing listed salmon.Ê On this basis alone, the biop should be rejected and sent back to NOAA Fisheries for Remand Two.Ê
PERFORMANCE STANDARDS
The final draft of updated proposed actions for the biop remand lists performance standards.Ê They do not have quantifiable criteria and therefore accountability is sorely lacking.Ê These standards say what will be done, but provide no way to measure the effectiveness of what is done so that offset survival improvements can be determined.Ê Without quantifiable standards it is impossible to measure and therefore determine whether the offset has prevented hydro dam jeopardy.Ê By not having quantifiable performance standards it is impossible to initiate adaptive management or measure cost effectiveness.Ê The performance standards should be redrafted to include quantifiable criteria that would allow actual evaluation to determine whether the hydro offset is actually providing the benefits needed to avoid jeopardy under the ESA.
CONCLUSION
Based on my review of the draft biop the inescapable conclusion is that it should be rejected because of its attempt to shift the ecological base line by including dams in the natural environment of salmon.Ê In addition, the biop attempts to avoid jeopardy of the federal hydro dams by proposing offsets that would somehow increase the salmon productivity and abundance to compensate for dam mortality. The proposed offsets are not new because they would have to be done independent of the biop to recover the ESA-listed salmonids.Ê This approach is not only deceptive and shameful on the part of NOAA Fisheries, it ruins their credibility in the region.Ê It is also unlikely that these offsets could increase the production of naturally produced salmonid smolts by 80 million or more, the present estimated cost of the federal hydro system in salmonid production.
Sincerely,
Bill M. Bakke, Director
References
Chilcote, Mark, W. 2003. Relationship between natural productivity and the frequency of wild fish in mixed spawning populations of wild and hatchery steelhead. Can. J. Fish. Aquat. Sci. 60: 1057-1067.
Chilcote, Mark, W. 2002. February 1, 2002. Memo to Bob Hooton, Oregon Department of Fish And Wildlife. Portland, Oregon.
Fleming, Ian and Erik Peterson. 2001. Ability of hatchery salmonids to contribute to the natural productivity of wild populations. Nordic J. Freshw. Res. 75: 71-98
Ford, M.J. 2002. Selection in captivity during supportive breeding may reduce fitness in the wild. Conserv. Biol. 16(3): 815-825.
Kostow, Kathryn, E., Anne R. Marshall and Stevan R. Phelps. 2003. Naturally Spawning Hatchery Steelhead Contribute to Smolt Production but Experience Low Reproductive Success. Trans. Amer. Fish. Soc. 132:780-790
Kostow, Kathryn, E. 2004. Differences in juvenile phenotypes and survival between hatchery stocks and a natural population provide evidence for modified selection due to captive breeding. Can. J. Aquat. Sci. 61: 577-589.
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. Can. J. Aquat. Sci. 43:2443-2449
Reisenbichler, R.R. and J.D. McIntyre. 1977. Genetic differences in growth and survival of juvenile hatchery and wild steelhead trout. J. Fish. Res. Board Can. 34:123-128.
Waples, Robin. 1991. Genetic interactions between hatchery and wild salmonids: lesions from the Pacific Northwest.Ê Can. J. Fish. Aquat. Sci., Vol. 48.