NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


										


		


March 6, 1998





Tom Lichatowich


Protected Resources Division, F/nw03


National Marine Fisheries Service


525 NE Oregon Street, Suite 509


Portland, OR 97232





RE:  	Comments on Section 10 Application #1118





Dear Mr. Lichatowich:





	The permit application #1118 by the U.S. Fish and Wildlife Service is 


deficient and increases the risk of extinction for upper Columbia River steelhead, 


listed as an endangered species by the National Marine Fisheries Service in 1997.  


The Native Fish Society recommends the applicant respond positively to our 


recommendations before the permit is provided.


	This application in addition to others contained in the Federal Register 


(Vol. 63, No. 40) regarding Section 10 ask for a 5-year permit.  The Native Fish 


Society recommends that these permits be renewed annually until a recovery plan 


is established.


	I would like to draw your attention the following problems with permit 


application #1118.





1.  The permit would not further the survival of ESA listed species.  The USFWS 


proposes to propagate and release into the Methow River fish from Wells Hatchery 


with brood stock captured from the Columbia River at Wells Dam.  The applicant 


has stated in the permit that 81% of the steelhead in the Methow River are of 


hatchery origin.  This proposal would continue to release non-native steelhead into 


the Methow River to interbreed with a small population of native steelhead.  The 


applicant did not say whether the Wells Hatchery steelhead were the same as or 


divergent from native Methow River steelhead, therefore, the NMFS must assume 


that the Wells Hatchery fish are different from the Methow River native steelhead 


until proven to be similar in genetic and life history characteristics.


	There is insufficient data to support assumptions made in the application 


claiming the ecological risks of the proposal are low.  For example there is no 


evaluation of residualism of hatchery steelhead and their predation potential on wild 


steelhead and other salmonids.  There is no data to support the claim that hatchery 


fish do not attract predators that may target on smaller wild juveniles as Mullan 


found in his research on chinook.  


	The proposal rests on assumption such as:  ãWe believe that the potential 


risks posed by artificial propagation to the listed population are out-weighed by its 


potential to rapidly increase abundance and avoid extinction,ä  and, ã...hatchery 


propagation...is likely responsible for the existence of the naturally-producing 


populations...ä  The permit provides no data to support these claims, offering only 


suppositions.  If the hatchery program were working as the applicant claims, it 


would seem the steelhead would not be listed as an endangered species.  But to 


continue the hatchery experiment based on such claims and with no supporting 


data, is not supportable and should not be permitted.  


	The proposal does not address the interactions of steelhead based on size 


differential.  The larger hatchery smolt can have a competitive advantage over 


smaller wild juveniles in the same area, especially if the wild population is exposed 


to five to ten thousand residualized steelhead.  However, the number of 


residualized steelhead could be much larger because there is no supporting data.  


Again the applicant says, ãThe rate of steelhead residualism is thought to average 5 


to 10% of the number releasedä (100,000). 


	Disease transfer from hatchery to wild stocks is also discounted by the 


applicant in a rather misleading way, saying, there is ãlittle evidence disease is 


transmitted to wild fish.ä  This is a true statement only because the transmission of 


disease from hatchery to wild populations has been a low study priority and not 


much has been done to determine the rate of transfer.  


	The applicant does not fully address genetic risk nor is there a stated gene 


conservation plan for the hatchery program.  According to NMFS (1998) 


ãInterbreeding of hatchery and natural fish can lead to loss of fitness in local 


populations, and hatchery/ wild interbreeding can also lead to loss of genetic 


diversity among populations.ä  Also, NMFS says, ãSelective changes arising from 


fish culture cannot be avoided even with the best fish culture practices...some 


genetic divergence of a cultured population from a natural population is inevitable 


(Waples 1991, Busack and Currens 1995, Campton 1995).  The changes that do 


occur as a result of fish culture are unlikely to be beneficial to locally adapted 


natural populations.ä  Dr. Reisenbichler warns against domestication selection in 


hatcheries that make the hatchery fish less fit for survival in nature and can cause 


the reduction of fitness in wild populations when survivor hatchery fish interbreed 


with wild fish.


	The application does not set forth a gene conservation plan and its list of 


expertise available to carry out the proposed research project includes no persons 


with requisite genetics expertise on site or available from some other location.


	Genetic risk assessment is not included as part of this proposed research, 


yet NMFS (1998) says, ãConducting a comprehensive risk/benefit analysis for 


salmon (and steelhead) supplementation should be an integral part of adaptive 


management.  In a genetic risk analysis by Dr. Currens (1997 ) for the Yakima 


Hatchery, he pointed out the supplementation program would increase the risk to 


natural populations.  





2.	The proposal is not constructed to be a research proposal and therefore 


does not duplicate other research.  However, it does duplicate other ongoing 


hatchery programs in the Columbia Basin where non-native salmonids are used as 


a replacement for native salmonids for enhancement of fisheries.





3.	An alternative species is proposed to be used, but propagating a non-native 


listed hatchery stock in the Methow River is not treated as a research project to 


determine ecological and genetic effects upon the listed native steelhead of the 


Methow River.





4.	The proposal would use non-native listed steelhead in a hatchery program 


and release them into the Methow River.  This is an improvement over using some 


other stock from some other hatchery, such as Skamania Hatchery steelhead,  but 


the proposal would continue to perpetuate the use of a non-native steelhead the 


Methow River.





5.	The noted expertise in the proposal do not include people with professional 


skills in genetics, gene conservation protocols for hatcheries, population dynamics, 


ecological interactions, life history diversity, conservation management, and 


biological diversity.  Therefore, the expertise available is not sufficient to carry out 


the research that should be required when using artificial propagation to recover an 


endangered population.


	6.	The lack of data to support assumptions made in the application 


and the lack of data collection in the proposal do not constitute an adequate 


sampling design to answer questions of listed fish propagation and their effect upon 


native, locally adapted populations.





	There are a few other problems with the proposal that the Native Fish 


Society would like to bring to your attention.





a)	There is no protocol identified to reduce and control domestication 


selection through hatchery propagation of a listed species.





b)	There are no estimates of smolt to adult survival rates and the relationship 


to hatchery operations and recovery of the listed population.





c)	There is no cost per adult analysis to evaluate the effectiveness of the 


hatchery program.





d)	There is no risk analysis to evaluate the effect of the hatchery program on 


the native population, nor an evaluation plan to develop data to address the 


assumptions made in the proposal.





e)	There is no independent scientific evaluation of the hatchery program to 


determine whether it is sufficient to protect and recover a species listed as 


endangered.





f)	The five year permit should be rejected based on the information and 


problems of this proposal and if a permit is allowed it should be only on an annual 


basis.  However, the Native Fish Society does not support NMFS approval of this 


proposal.





g)	The NMFS should develop a conservation plan prior to approving 


incidental or direct take permits and research proposals, so that efforts to recover 


the species is consistent with the conservation plan.  





h)	The genetic and demographic risk for the Methow River steelhead is high 


and this proposal will only enhance that risk.





I) 	The proposal expands the danger of further homogenizing the native 


Methow River steelhead population with Wells Hatchery fish, losing important 


genetic structure, life history diversity and fitness of the native fish.





	The Native Fish Society is disappointed in application #1118 and view it as 


a continuation of the kind of hatchery program that has contributed to the decline 


of native steelhead populations in the Columbia River Basin.  Consequently, the 


Native Fish Society recommends the proposal be rejected or substantially changed 


to correct the many deficiencies we have identified.


	I appreciate the opportunity to review this proposal and will be pleased to 


review others.





Sincerely,











Bill M. Bakke,


Director	


Literature Cited





Currens, Ken. April 30, 1997. Evolution and risk conservation of Pacific salmon. 


Thesis. Oregon 	State University, Corvallis Oregon





Myers, J.M., R.G. Kope, G.J. Bryant, D. Teel, L.J. Lierheimer, T.C. Wainwright, 


W.S. Grant, 	F.W. Waknitz, K. Neely, S.T. Lindley, and R.S. Waples. 1998. 


Status review of chinook 	salmon from Washington, Idaho, Oregon, and 


California. U.S. Dept. Commer., NOAA 	Tech. Memo. NMFS-NWFSC-35, 443 


p.