NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


											


	





February 28, 1998





MEMORANDUM





TO	Oregon Department of Fish and Wildlife Commission


FR	Bill M. Bakke


RE	Testimony on Willamette River spring chinook conservation 


plan


__________________________________________________________________


_______





	I have reviewed the February 17, 1998 staff memo to the 


Commission on proposed Willamette River spring chinook management 


plan.  The following testimony is in response to that staff memo.





1.	There is still no indication that the proposed spring 


chinook management plan has been or will be given independent 


scientific peer review.  This peer review should take place prior 


to the Commission adopting the management plan.  The purpose of 


the peer review is to obtain more information that may assist the 


Commission in its decision, and to make sure the plan is 


scientifically sound.  





2.	There is still no indication that the staff with expertise 


in population dynamics and gene conservation have had input into 


this plan.  I would suggest the Commission adopt a process whereby 


the staff ensures the Commission that there has been a full staff 


review prior to it going to 


the Commission for adoption.  Also, staff with relevant expertise 


in spawner escapement, gene conservation, and compliance with the 


Oregon Wild Fish Policy attend the Commission meeting so that, if 


needed, they are available to answer questions the Commission may 


have.  One last point.  It is the position of the Native Fish 


Society that it is inappropriate for the harvest management staff 


to lead the discussion on adoption of this plan.  The chief of the 


fish division should lead the 


presentation and call upon his staff to provide information 


whenever required.





3.	Page 1, Objective 2:  The staff ensures there will be a 


minimum wild spring chinook escapement for McKenzie River.  But we 


still do not know what that spawner goal is and whether the 


escapement is an adequate effective breeding population size to 


maintain long-term genetic diversity even when the run size is 


low.  Also, since there are three wild spring chinook populations 


identified in the proposed plan, these other wild populations need 


to be addressed and specific 


spawner escapement goals established for each population.  





ASK STAFF:  1) The Commission should ask the staff for a specific 


spawner escapement goal and whether it is designed to maintain 


long-term genetic diversity of each wild spring chinook 


population.  2) Is the spawner escapement goal a constraint upon 


commercial and sport fisheries or is it a target that is only 


periodically achieved?	





4.	Page 4, Actions:  The staff  recommends developing 


guidelines and a monitoring program for Willamette spring chinook 


hatcheries.  





ASK STAFF:      1.) What is the date for completion of this work?


		2.) Are biological diversity and fitness values 


covered ?


		3.)  Is there a parallel action for wild spring 


chinook populations?	


		4.)  How much will this cost annually and can costs be 


met?





5.	Page 4, Assumption 3:  How far short of mitigation have the 


hatcheries been over the years? Again, the staff should be 


specific rather than general when providing important information 


to the Commission and the public.  In 1982 George Staley wrote a 


draft report for the department called: Oregonâs Mitigation 


Experience, the performance of anadromous fish compensation 


programs operated by the Oregon Department of Fish and Wildlife.  


In 1990, I asked Jim Martin for a copy and he said he could not 


find one.  As far as I know the Staley report was never published 


because it has, as Martin said, ãToo many loose threads which 


needed to be pinned down before ODFW put down in writing what the 


mitigation responsibility actually was.ä  The Staley report was 


not encouraging about Oregon having achieved mitigation goals and 


this had something, I 


believe, to do with the department not publishing the report.  It 


reflected badly on the hatchery system at a sensitive time.  


Another run at the mitigation issue was planned by the Northwest 


Region, but it is unclear whether it was ever completed.


	Now, sixteen years later the staff is proposing to do yet 


another evaluation of  hatchery mitigation for Willamette River 


hydro development.  Will this report also disappear if it does not 


reflect well upon the hatchery program at a sensitive time?  How 


long does it take for Oregon to evaluate whether it has achieved 


the hatchery mitigation it asked for?  How much will this new 


study cost?  Will the Commission make sure that this mitigation 


report is distributed to the public?And, if the staff canât find a 


copy of the Staley report, I will be glad to furnish them with 


one.





6.	Page 5, Actions, Number 1:  The agency wants to achieve 


ãfull mitigationä for lost wild Willamette spring chinook.   We 


recommend that full mitigation include funding for the recovery of 


the wild spring chinook populations remaining in the Willamette 


Basin and not just a standard replacement of wild fish with 


hatchery fish.  A question of major importance is if there is full 


mitigation what will be the impact on wild spring chinook in a 


mixed stock fishery?  





7.	Page 7, Cost Accounting:  The chart does not display all 


costs.  This should be corrected.  Also, the chart indicates that 


$910,000 in project funding is, at this time, not funded.  Some of 


this amount is a one time expense but most of it is not.  The 


Commission should ask staff for out year costs including operation 


and maintenance costs and sources of money.  It would also be 


interesting 


to know the cost per adult salmon from the Willamette hatchery 


program.  


	Based on an ODFW cost evaluation study in 1993 the 


Willamette spring chinook cost per recovered adult is:





Willamette/Dexter	$30.36 per adult


McKenzie		$31.90


S. Santiam		$32.00


Marion Fks		$55.15


Clackamas		$137.42


			________


	Average:            $55.36/ adult





	I am sure the cost per adult has not gone down since 1993, 


and one has to eventually ask if the hatchery salmon are costing 


too much and could the money be better spent on programs to 


protect the biological diversity and fitness of the few wild 


populations still remaining.





	In conclusion, the staff proposal is too general, cost 


accounting is not adequately displayed, scientific review is 


lacking, and spawner escapement goals are not stated.  For these 


reasons the Commission should require staff to correct the 


problems in the proposal before submitting it for Commission 


adoption.








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