NFS

NATIVE FISH SOCIETY

Conserving biological diversity of native fish and protecting their habitats

 

 

November 19, 2004

 

Ms Allyson Ouzts,

National Marine Fisheries Service

Suite 510

525 NE Oregon Street

Portland, OR 97232

 

RE:Ê EIS scoping comments on Mitchell Act Hatcheries on the Columbia River

 

The Native Fish Society has reviewed the request for comments on the Mitchell Act HatcheryÊ Environmental Impact Statement and we provide our comments for the record with this letter.

 

The Mitchell Act Hatchery program was initially established by Congress in 1938 as mitigation for the construction of main-stem Columbia River federal hydroelectric dams.Ê Since this mitigation program was established most salmon and steelhead populations in the Columbia Basin have been listed as federal protected species under the Endangered Species Act.Ê It is obvious that the purpose of the Mitchell Act Hatchery system and investment has failed to not only mitigate for the wild salmonid losses due to the mainstem federal dams, but it has contributed to the decline of wild salmon and steelhead in the lower Columbia River.Ê For example, when lower Columbia River coho salmon were petitioned for listing under the ESA, the NMFS concluded that no distinct wild coho population could be identified in the tributaries of the lower river.Ê It was determined that all the naturally spawning coho salmon were hatchery strays.Ê

 

The combined hatchery production from Mitchell Act hatcheries and the 80%-90% harvest rate on hatchery fish depleted or eliminated most native, wild coho populations in the lower river.Ê Since then, the ODFW and NMFS have identified three wild coho populations in the lower river and they are now proposed for listing by NMFS as a threatened species.Ê Oregon listed them as endangered under the state ESA in 1999.

 

In addition to direct effects on the health and abundance of distinct wild coho salmon populations in the lower Columbia River, the Mitchell Act hatchery programs have contributed to the decline of wild coho in the northwestern Oregon coast streams.Ê Oregon selected and propagated a strain of lower Columbia River coho that turned south upon reaching the ocean.Ê This was done to benefit Oregon fisheries.Ê The abundance of Mitchell Act coho salmon in the ocean off Oregon and the high harvest rates directed at them along the northwest coast contributed to the over harvest of wild coho in the northwest coast streams.Ê Eventually these coastal coho were listed as a threatened species by NMFS.Ê

 

The Mitchell Act hatcheries have caused enormous ecological damage to native wild salmonids including winter and summer steelhead, chum salmon, coho salmon and fall chinook in the lower Columbia River. All of which are now listed as threatened species in the Columbia River. The hatcheries ãmixedä these salmon populations through stock transfers, imported non-native Rogue chinook for release into the lower river, blocked access to spawning areas above hatcheries, promoted excessive harvest rates and largely eliminated the distinct wild population structure, diversity and abundance of wild salmonids in the lower Columbia River and coastal streams.Ê The challenge is to bring the Mitchell Act hatchery programs into compliance with conservation of native, wild salmonids in the lower river and its tributaries, making it consistent with the purpose of the ESA and state conservation laws such as the Native Fish Conservation Policy in Oregon and the Wild Salmonid Policy in the state of Washington.ÊÊ

 

The Mitchell Act was designed to do more than release hatchery fish for harvest, it was also to conduct biological surveys to promote conservation of fishery resources of the Columbia and its tributaries, screen irrigation diversions, improve fish passage, and to do other duties that promote the conservation of fish in the Columbia River Basin.Ê

 

The most positive and least harmful of Mitchell Act investments have been in the support of research, screening irrigation diversions and other actions for the conservation of fish.Ê However, these aspects of Mitchell Act funding have been minor compared to the development and operation of hatcheries to feed the sport and commercial fisheries with salmon.Ê In fact research investments have been constantly threatened by the hatchery proponents as Mitchell Act funding declines.

 

The Native Fish Society recommends that the Mitchell Act hatchery programs be reviewed by an independent scientific team similar to those appointed to review Washingtonâs Puget Sound hatcheries.Ê This scientific body is called the Hatchery Scientific Review Group and it has provided information to fish managers regarding reform of the hatchery program so that the hatcheries are operated in light of the most current scientific information.Ê The Mitchell Act Hatchery Program would be vastly improved if it were also to get a heavy dose of scientific advice.Ê

 

Scoping Issues

 

Effluent:

-Are all hatcheries in compliance with Clean Water Act standards and following standards for use of toxics?

ÊÊÊÊÊÊÊÊÊÊÊÊÊÊÊ -Are all hatcheries treating effluent released from hatcheries to streams for fish disease?

Fish Marking:

-          Require 100% external mark on all hatchery released fish so they can be identified in fisheries and in tributaries.

-          Require internal tags (CWT or pit tag) so that the hatchery of origin for all released fish can be identified.

Release of Non-native Fish:

-          Eliminate the release of all non-native fish into the Columbia Basin, for example, Rogue River chinook

-          Convert all hatcheries to integrated native brood stock programs and eliminate stock transfers among hatcheries and off-site releases among rivers.

Survival Rates:

-          Determine the survival rate for each release group of fish (egg to smolt and smolt to adult) and display them on a public data base and with Streamnet each year for each facility.

-          Establish a smolt to adult survival rate standard for each facility and release group and display results annually by facility and release group and species.

 

Gene Barriers:

-          To maintain the genetic integrity of hatchery and natural populations establish a passage barrier at each hatchery, allowing only unmarked fish to pass above the barrier. Develop a non-intrusive sorter that rejects fish with a code wire tag.Ê This eliminates the need to handle and short fish while passing wild fish upstream for natural spawning.

Stray Rates:

-          Establish a stray rate standard for each hatchery program by release group of no more than a 5% of the released fish that show up as strays within the watershed were they are released or in other watersheds. Display stray rates by facility, species and release group annually for public use.

-          Actively evaluate stray rates for each facility by species and release group each year and display results.

Wild Fish Management Objectives:

-          Establish management objectives for wild salmonids in each stream where hatchery fish are released or may stray into and determine whether the hatchery program is interfering with these management objectives. Publish results for the public annually.

-          Configure hatchery policy so that the wild salmonid populations drive the hatchery program, that is, the objectives set for the productivity and abundance of the wild population are controlling so that the hatchery operations conform to objectives established for wild populations. A model for this approach would be the operation of the Warm Springs Hatchery.

Replacement:

-          Calculate the replacement rate for hatchery and wild fish for each hatchery program and associated natural population.

Maintenance Backlog:

-          Identify the maintenance backlog for each hatchery program and display it for the public.Ê Identify the entire maintenance backlog for all Mitchell Act hatchery programs for public display and the cost for each hatchery.

-          Develop a funding strategy.

Performance Based Planning and Operations:

-          Establish specific objectives for each species released by hatchery, displaying smolt to adult survival, cost per adult, contribution to fisheries, stray rates, fish losses, CWA compliance, etc.Ê Funding should be based on meeting performance standards.Ê Display results for each hatchery by release group.

Bottom-up Funding Structure:

-          Establish the funding needs for each research program, screening program, inventory program and hatchery program and develop a bottom-up funding structure so that the actual costs and value of various program can be displayed and used to construct a funding package each year.Ê Include the public in development of this planning.

Hatchery Screens:

-          Replace all screens with those that meet NMFSâs screening standards.

Cost per Adult Produced:

-          For each release group and by species determine the cost to produce each adult fish contributing to the fishery or returning to the hatchery or straying.Ê Display the cost per adult by species and release group for the public to review.

Determine Whether the Current Programs are consistent with the Enabling legislation:

-          Review the Mitchell Act Program and determine whether the existing program is consistent with the Mitchell Act legislation and make the necessary adjustments to bring it into compliance.Ê In addition, bring the program into compliance with state fish conservation policy, the ESA, APRE, and HGMPs, and the HSRG reform criteria.Ê

 

Operate Hatchery Programs Consistent with Recommendations of the ISAB and SRT Scientific Panels:

-          Adopt and implement the twenty recommendations developed by the Independent Scientific Advisory Board and the Scientific Review Team in their 1999 report Review of Artificial Production of Anadromous and Resident Fish in the Columbia River Basin (pages 98 to 107).

Secure Funding For Research:

-          Research funding is presently in competition with hatchery funding and attempts to cut research funding for hatchery operations are common.Ê Research funding is an important feature of Mitchell Act but it should be a protected long-term funding source to support important research such as the Kalama River research into native brood stocks and hatchery-wild fish interactions.

Identify Funding for habitat improvement and Research:

-          An important part of the Mitchell Act (see section 2 of the Act) is the funding of projects for the ãimprovement of feeding and spawning conditions for fish, biological surveys and experiments·to facilitate conservation of the fishery resources of the Columbia River and its tributaries·äÊ The implementation of the Mitchell Act funding has been primarily for hatcheries rather than aimed at improving habitat and our understanding of how the natural ecosystem functions.Ê Direct more of the funding to habitat and ecosystem research and secure it from raids by the hatchery advocates.

Require an Independent Scientific Evaluation of the Mitchell Act Funded Programs:

-          Initiate an independent scientific evaluation of the Mitchell Act programs to provide an out-side review free from the interference of state and tribal fish agencies that have an established conflict of interest in the operation of the hatcheries and the direction of program funding. This review should look at all funded programs, unfunded program needs, provide recommendations for changes in hatchery programs, for research and for habitat.Ê This independent review should take place every ten years to make sure that new scientific information is actually included in the application of Mitchell Act funds.

Identify All Wild Salmonid Populations that Interact with Mitchell Act Hatchery Fish and Establish Protection Criteria:

-          Establish a list of all wild and naturalized salmonid populations that interact with Mitchell Act funded hatchery and habitat programs and develop criteria to protect these populations from interactions that reduce their reproductive fitness and survival. Once these criteria are established review each hatchery operation annually to provide accountability for the full implementation of the criteria.

Reduce Hatchery Releases in Streams Where a Conflict Has Been Identified with Wild or Naturalized Salmonids:

-          Size hatchery releases so that hatchery fish straying, interbreeding and ecological interactions and harvest impacts aimed at hatchery fish do not interfere with naturally spawning wild and naturalized populations of salmonids.Ê Examples would be the 700,000 hatchery coho release into Sandy River, the continued release of non-native summer steelhead in Sandy River, the continued release of Rogue River chinook, and the release of Skamania Summer Steelhead into other watersheds than the Washoughal River.

 

 

Moving Mitchell Act Hatchery Releases Upriver:

-          By moving Mitchell Act hatchery production upriver the same problems that these hatchery releases are causing in the lower river will only expand over a larger part of the Columbia River Basin.Ê The proposal to move production upriver cannot be supported until major environmental problems of Mitchell Act hatcheries are resolved.

Establish a Research Program to Determine the Interactions of Mitchell Act Hatchery Releases in the Columbia River Estuary:

-          Evaluation of Mitchell Act Hatchery Releases on predation and other ecological interactions with wild salmonids in the Columbia River estuary is needed to determine whether the releases are causing harm to wild salmonids.

Establish Criteria for Hatchery Review and Closure When Specific Standards are not Accomplished.

ÊÊÊÊÊÊÊÊÊÊÊÊÊÊÊ - Over a decade ago Mitchell Act Hatcheries were reviewed to determine costly facilities that performed poorly.Ê Establish criteria to evaluates both internal and external performance of each hatchery and the cost per adult for each release group.Ê When a hatchery fails to meet the established criteria, develop a process where it is either brought into compliance or shut down.

 

The Native Fish Society is pleased that the Mitchell Act Programs are being evaluated for competence and accountability since the hatchery program has been identified with numerous problems including the extinction of some wild populations of salmonids in the Columbia River.

 

 

Sincerely,

 

 

 

Bill M. Bakke, Director