NATIVE FISH SOCIETY P.O. Box 19570 Portland, Oregon 97280 (503) 


977-0287


March 17, 1997


Mr. Brian Cunninghame Relicensing Coordinator 


Warm Springs Power Enterprises


P.O. Box 960


Warm Springs, Oregon 97761


RE:     Comments on First Stage Consultation Document for license 


of Pelton-Round Butte Hydro 





Project


Dear Mr. Cunninghame: 


These comments are specific to the effect of the Pelton-Round 


Butte Hydro Project on native, wild salmonids with particular 


emphasis on populations downstream form the hydro dam complex.  


These comments are primarily in response to the section in your 


document on genetics at page 96.





The fundamental productive capacity of native fish populations 


within the Deschutes Basin resides within the genetic structure of 


native fish populations. A framework for management of native fish 


populations in the Deschutes River is needed to evaluate the 


effect of the dam on native fish fauna of the river, and this 


framework would protect and rebuild the genetic variation, life 


history attributes, and the evolutionary potential for each 


population affected by dam construction and operation.





The existing answer to this framework has been the operation of 


two fish hatcheries in the Deschutes Basin. The purpose of the 


Round Butte Fish Hatchery is to mitigate for lost salmon and 


steelhead production and the Warm Springs Hatchery is to augment 


spring chinook production in the basin. The management objective 


of these two hatcheries has been to maintain the wild runs and the 


wild run characteristics. This decision probably contributed to 


the maintenance of the productive capacity of native Deschutes 


salmon and steelhead. Evaluation of these hatcheries to determine 


whether the hatchery fish have diverged from the wild seed stock 


and the wild fish still using the river, is necessary. Evaluation 


of the Warm Springs Hatchery spring chinook program shows that 


some divergence has taken place. It may be impossible to keep this 


from happening, but measures can be taken to control it. Each 


hatchery ought to have a gene conservation program as part of its 


operational structure and each hatchery should be evaluated on 


maintaining native genetic resources in the fish populations they 


affect. 





This must be a part of the Hydro license. The hydro dams and other 


dams within the basin once available to anadromous salmonids have 


not only fragmented the habitat for native fish species, they have 


also fragmented the native gene pool for salmonids and other 


fishes.  





It is this latter situation that the Native Fish Society would 


like the Warm Springs Tribes to address in its competitive bid for 


the license to operate the hydro dam complex. It is possible that 


the portion of the anadromous salmonid gene pool historically 


found above these dams is lost. For example, the Round Butte 


Hatchery used Metolius River spring chinook as its egg source, but 


longterm hatchery failures forced the importation of spring 


chinook eggs from the Warm Springs River Hatchery. The Metolius 


River spring chinook is extinct. The same point could be made for 


Squaw Creek steelhead. It can be assumed that the native gene pool 


for anadromous salmonids above the Pelton-Round Butte Hydro Dams 


no longer exists. Therefore, the effect of these dams has been to 


eliminate a portion of the historic gene complex of the Deschutes 


Basin. Where there were at least three native, wild populations of 


spring chinook in the basin, there are now only two. There were 


many more native wild steelhead populations in the basin, but now 


the only ones are found below the dams. 





It is our opinion, then, that because the hydro dams have 


fragmented the original gene pool for native fish, mitigation 


should be focused on maintaining the productive capacity and 


evolutionary potential of native anadromous salmonid populations 


below the dams. In addition, other native fishes should also be 


included. For example, bull trout below the dams should be 


included. Our view of mitigation is not more hatchery fish, but 


making investments into rebuilding and protection of native fish 


populations and their spawning and rearing habitats below the 


dams. By taking this approach what remains of the wild, native 


gene pool can be maintained, contributing to maintenance of the 


biological diversity of the basin that had been fragmented by the 


hydro dams.





It is our concern that if mitigation remains primarily one of 


hatchery releases, the wild portion of the gene pool will be lost 


eventually and the hatchery stock cannot be maintained. 





Your list of references does not include the large and growing 


literature on gene conservation and the problems associated with 


hatchery programs. For example, in 1978, Reginald Reisenbichler 


published a study that showed hatchery and wild steelhead crosses 


did not survive in nature as well as wild - wild crosses. This 


reduced survival, they theorized would result in fewer smolts 


produced from matings of hatchery and wild steelhead and fewer 


returning adults. In short, the hatchery has a significant effect 


upon the productive capacity of native, wild steelhead in the 


basin. This study has since been repeated in a 18 year study 


evaluating hatchery and wild steelhead interactions on the Kalama 


River by the Washington Department of Fish and Wildlife. In their 


work, the hatchery steelhead produced 55% of the juveniles in the 


stream through natural spawning but the adult progeny survival 


back to the stream was zero. So the hatchery system can also be 


part of the hydro effect on the natural ecosystem below the dam, 


because it is producing fish that are less fit for survival in 


nature, and when they interbreed with wild fish of the same 


species, the progeny are less fit. Since the hatchery is an 


artifact of the hydro dam, the hatchery is a hydro dam effect upon 


the natural system. How does one mitigate the effect of the 


hatchery program? 





Several options are possible: First, the hatchery can be operated 


better so that  divergence is controlled better, but probably will 


never be eliminated; second, the hatchery is eliminated; or third, 


the mitigation program is focused on maintaining the biological 


diversity of native fishes below the projects in the mainstem and 


accessible tributaries. 





The Native Fish Society recommends the following to assist in the 


development of 


a framework for the protection and rebuilding of native fish in the 


Deschutes Basin:





1.      Is a framework concept for native wild, salmonids needed for 


the Deschutes Basin? If so, then state the reasoning and the short 


and long-term objectives.


2.      Identify how this framework fits into tribal values and 


traditions and how the framework would advance those values and 


traditions into the future.


3.      Identify in what ways the construction of dams in the basin 


have increased risk to native fish populations and what corrective 


actions are needed.


4.      Develop studies that provide biological information that 


help resolve risks


5.      Determine how biological risks and solutions affect tribal 


cultural values and economic expectations.


Specific biological study recommendations:


1. Inventory existing genetic structure and life history attributes 


of native, wild anadromous salmonids.


2. Compare this information on native fish to existing hatchery 


reared 


anadromous salmonids.


3. Based on this information evaluate risk and the means to control 


risk to 





native salmonids and to maintain a high degree of fitness in 


hatchery salmonids. Determine whether hatchery programs should be 


reduced or eliminated. Determine native salmonid conservation 


strategies to mitigate for the operation of the hatchery and hydro 


system.





The EDT methodology is designed to address the creation of a 


native fish productivity framework for the Deschutes Basin. I 


would recommend that this be a product of that work. 





The Native Fish Society may be submitting additional comments, but 


if you have any questions regarding the above, please give me a 


call.





Sincerely,


Bill M. Bakke,


Director