NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


										


		


March 18, 1998





Mr. Lance Kruzic


National Marine Fisheries Service


525 NE Oregon Street


Portland, OR 97232-2737





RE:  Upper Columbia River Steelhead ESU Biological Opinion





Dear Mr. Kruzic:





Thank you for sending the additional documentation on the use of hatchery 


steelhead to recover wild, native steelhead in the Upper Columbia ESU.  I had not 


seen the Schiewe memo of Oct. 7, 1997 nor the Biological Opinion before.  In 


reading those documents, however, a few additional concerns developed that I 


would like to include for the record on Section !0 Application #1118 sent to Mr. 


Tom Lichatowich on March 6, 1998.  These documents would have contributed to 


my earlier comments if I had them available at the time, so I hope these additional 


comments are not too late to be considered by NMFS in this application process.


	Based on my review I believe the Biop is inadequate to recover the species 


and will increase the risk and cause lower productivity of subbasin wild, native 


steelhead populations covered in by the Biop.  The foundation for this conclusion 


is provided in the following comments:





1.	The historic use of hatchery steelhead in this ESU did not support the 


conservation of locally adapted populations of native, wild steelhead and the 


biological diversity they represent in terms of genetic structure (genetic diversity 


among and within populations) and the fitness of those populations.    The historic 


hatchery program has established a hatchery swarm of a generic, homogenized 


steelhead population in the upper Columbia River and related subbasins.   The 


goals of this historic hatchery program are very different from the purpose of 


recovering locally adapted natural populations in the ESU under the federal 


Endangered Species Act.  However, the Biop, even with the changes described, 


perpetuates hatchery operations that have caused the present problem of a 


homogenized hatchery production steelhead stock.   A similar problem to this was 


also identified for the Willamette spring chinook where the NMFS assessment 


stated the transfer of common hatchery stock among hatcheries and subbasins had 


homogenized the Willamette spring chinook.  However, unlike the Willamette 


spring chinook hatchery program, the steelhead hatchery program in the upper 


Columbia ESU has also included out-of-ESU hatchery transfers such as the 


Skamania summer steelhead stock.  This makes a bad situation even worse in the 


upper Columbia ESU.





2.	Rather than begin with a Biop that perpetuates historic hatchery practices 


and recognized problems along with substantial risks identified in the Schiewe 


memo, the Biop should move immediately to a WxW cross supplementation 


program for each subbasin if a hatchery supplementation program is needed.  I 


think the Schiewe memo is correct when it questions the need for supplementation.  


It may be enough to exclude hatchery production from the subbasins altogether and 


with harvest controls and habitat repair, allow the native wild stock to restore itself.  


But if the hatchery is to be used it, should be based only on WxW crosses.  The 


existing Wells Hatchery program should continue, as a backup, to maintain that 


population, providing it does not jeopardize other listed populations and straying is 


controlled in upper Columbia River subbasins to maintain the locally adapted 


populations.  The Schiewe memo is interesting because it leads the reader to the 


action I mention above, but it then backs away from it in the final conclusion.





3.	The evaluation by NMFS relies upon local WDFW assessment for 


changing hatchery operations, but it does not incorporate the very relevant research 


conducted over the last 20 years by WDFW at the Kalama River Research Station.  


I could find no reference to this research, even though it is uniquely qualified to 


help answer questions asked in the Schiewe memo.  The Kalama Research has 


evaluated the reproductive success of non-native second generation hatchery fish 


and their ability to produce adult progeny.  Because this research addresses the 


questions asked in the Schiewe memo, I would recommend NMFS ask the 


scientists involved in the Kalama research to participate in the development of a 


recovery plan for the upper Columbia steelhead ESU.  At a minimum their review 


and comments would be most helpful in developing a Biop for this steelhead ESU.  


	Based on the findings of the Kalama Research Station results, continuing 


the HxW and HxH crosses in the upper Columbia ESU would continue to 


contribute to the reduction of fitness for natural populations in the subasin and add 


to their risk exposure .  This result is not consistent with the recovery of native, 


wild steelhead under the ESA.





4.	A life history trait of steelhead not recognized in the Schiewe memo or in 


the Biop is the repeat spawner.   This trait has value to natural populations in terms 


of genetic diversity, fitness and productivity of locally adapted populations. Some 


research has shown it to be a relatively large component of native steelhead.  Mark 


Chilcote told me that 22% of a Kamchatka steelhead  population is composed of 


repeat spawners.  The NMFS should evaluate the ecological and genetic value of 


repeat spawners in its steelhead plans and incorporate this life history trait into its 


recovery program.  Since listed kelts are not addressed in the Biop, I am making 


the recommendation that they be included and a conservation plan be developed to 


protect repeat spawners from steelhead ESUs.  Certainly, the lack of consideration 


for the safe passage of steelhead kelts around dams on tributaries and in the 


mainstem is an oversight that could and should be corrected.





5.	There is some discussion of nutrient enrichment of steelhead streams from 


steelhead carcasses.  While steelhead carcasses should be considered for this 


purpose, it may be that stream productivity associated with salmonid carcasses is 


more closely tied to the amount of salmon carcasses than to steelhead. Steelhead, 


cutthroat and salmon are probably all linked together in a nutrient wed primarily 


powered by salmon escapement.  Consequently, salmon recovery in the upper 


Columbia ESU is probably an important factor to successful steelhead recovery 


and delisting.  I would refer you to research conducted in Canada on this topic in 


Fisheries , American Fisheries Society, November 1997, Vol. 22, No. 11, by 


Gillian A Larkin.  


	Nutrient enrichment from salmonid carcasses is an important issue and 


specific standards should be set in a recovery plan for steelhead.





6.	Given the uncertainties and risks identified in the Schiewe memo, it seems 


prudent to call for an independent scientific and public review of the upper 


Columbia River Steelhead ESU Biop.  I am not certain how much external review 


there is of a Biological Opinion.  However, since the Independent Scientific 


Advisory Committee is presently reviewing hatcheries in the Columbia Basin, it 


seems that the ISAB should review and comment on the Biop.  Also, the Biop 


should not be approved for a 5-year period because the ISAB hatchery review may 


identify changes in hatchery operations that could be incorporated in the Upper 


Columbia River Steelhead Biop.  This kind of adaptive management and flexibility 


is needed considering the risks and uncertainties associated with the upper 


Columbia River Steelhead ESU. 





7.	The Biop (p. 12) makes the conclusion: ãBased on available information, 


the proposed actions are likely to provide a net benefit to Upper Columbia ESU 


natural steelhead (Schiewe 1997).ä  However, the Biop does not complete the 


thought contained in the Schiewe memo: ãHowever, this conclusion rests on some 


tenuous assumptions that need to be verified as soon as possible. Most important 


of these is the degree to which naturally spawning Wells stock hatchery fish 


contribute to natural production.  If these fish perform substantially less well in the 


wild than do wild fish or fish that resulted from WxW crosses in the hatchery, then 


the use of Wells Hatchery stock fish in the recovery effort may not provide a net 


benefit to the listed species.  If this is the case, a better strategy may be to 


supplement only with WxW crosses, or possibly not to supplement at all.


	Given this critical uncertainty and risk regarding the use of Wells Hatchery 


stock for supplementing wild steelhead in the subbasins, it would  appear the Biop 


decision is unwarranted and the more conservative approach recommended by the 


NMFS Science Center should be adopted.  





	In conclusion, the NFS society recommends the Biop address steelhead 


kelts and provide for the full expression of this life history trait in Upper Columbia 


River ESU natural steelhead.  In addition, we recommend that the Biop be changed 


to reflect the critical uncertainty and risk identified with using Wells Hatchery 


steelhead for supplementation of natural steelhead in this ESU.  This means using a 


WxW cross, a captive brood program for wild steelhead, or not supplementing the 


wild population.  








Sincerely,











Bill M. Bakke, 


Director





cc:	Tom Lichatowich


	Rollie Schmitten


	Donna Darm