NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


503/ 977-0287





												


Comments on the draft Oregon Plan Supplement on Steelhead





By Bill M. Bakke, Director





November 14, 1997


________________________________








	The following comments are confined to Section 4: Fish Management of the Oregon Plan 


Supplement on Steelhead.  





I.  Harvest Impacts to Spawner Escapement





	This section sets no spawner abundance and escapement goals by ESU or component 


populations.  The only direction provided is that ODFW will "strive for attainment of spawner 


escapement goals."  This objective cannot be evaluated and provides no accountability.


	Spawner abundance goals should be established per ESU reflecting delisting criteria the 


state or federal agencies would use.  Based on the genetics literature, long-term gene 


conservation can be achieved with an escapement of 5,000 adults (Nelson and Soule 1986).  An 


effective breeding population per ESU and by component populations must be established.  The 


WDFW recommendation is for 3,000 adults divided by the generation age of the population.  For 


steelhead the average generation age is four years.  This would provide an effective breeding 


population of 750 per population.  The WDFW based their gene conservation goal on an effective 


population of 50 to 500 adults per year and did not use the recommendation for 5,000.  If the 5,000 


adults per year were used, divided by the average generation age structure of four years for 


steelhead, the effective population size would be 1,250.  The Oregon Wild Fish Management 


Policy calls for a minimum management population of 300 and does not distinguish between a 


census and effective breeding population.  Compared to the work of WDFW and the updated 


recommendations of Nelson and Soule, the ODFW management goal (adopted in 1992) falls far 


short.  However, as stated, the ODFW makes no escapement goal recommendation in the Oregon 


Plan for steelhead.


	Spawner abundance escapement goals should also include nutrient capital enrichment.  


Dr. Bilby's research in Washington State on nutrient enrichment from salmon carcasses 


recommends an optimum carcass goal of 200 per kilometer.  Steelhead carcasses should be 


counted on for contribution to nutrient enrichment of streams, but the bulk of the carcasses will 


come from salmon species.   Since steelhead are less numerous in most watersheds than salmon, 


and because they survive spawning (about 15% spawning survival) the bulk of nutrient enrichment 


must come from increased spawner abundance from salmon species.  Because steelhead and 


cutthroat have the longest freshwater life history, they are dependent upon salmon carcasses to 


improve the productivity of their home streams.  Consequently, salmon management, specifically 


spawner abundance management must address the nutrient enrichment needs for steelhead and 


cutthroat trout.   


	Dr. Bilby's recommendation of an optimum 200 spawners per mile far exceeds the past 


and projected spawner escapement for coho salmon in Oregon streams.  The ODFW, in fact, has 


recommended the reduction of the coho spawner escapement goal through its amendment 13 to 


the Pacific Fishery Management Council.  Coho salmon spawner escapement is particularly 


important because coho salmon tend to migrate into the upper portions of watersheds and into 


small headwater streams where steelhead, cutthroat, and spring chinook are found.  So coho 


salmon carcasses may be more important to steelhead rebuilding than other salmon species.   


Under the Oregon Wild Fish Management Policy the management floor is 300 spawners per 


population.  This compares to a management floor of 200 per kilometer for optimum nutrient 


import.  If a spawning stream is ten miles long, Oregon would require only 300 adult steelhead 


compared to Dr. Bilby's 2,000, and a gene conservation goal of 1,250.


	Unfortunately, the Oregon Steelhead Plan fails to establish a spawner escapement goals 


and it fails to develop a linkage between spawner escapement and important ecological functions 


such as gene conservation and nutrient enrichment.  Consequently, the Oregon Steelhead Plan 


fails to provide the objectives that can be evaluated  for accountability.   Therefore, the NMFS 


should ask ODFW to improve its section on spawner abundance escapement and subject it to 


independent peer review before adoption as sufficient to merit not listing the steelhead as a federal 


protected species.





111A2S: Manage Fisheries To Minimize Impact On Wild Steelhead





	The discussion of harvest impacts on wild native steelhead is merely an account of what 


the state has done to minimize harvest impact on native steelhead.  The Oregon Steelhead Plan 


fails to describe what more needs to be done to stabilize native populations, reverse their decline, 


and rebuild populations.  Past actions by the state have not reversed the decline for most, if not all 


populations, therefore, more actions are called for.  But the Oregon Steelhead Plan fails to do this.  


	The Oregon Steelhead Plan admits that the mortality rate for released wild steelhead is 


unknown, so the actual effect of mixed stock sport fisheries on native steelhead remains unknown.  


Evaluation of this mortality is put off to some unspecified future time.  This only adds to the list of 


critical uncertainties contained in this plan, making it unaccountable and a poor replacement for 


listing steelhead as a federal protected species.


	In this section the Oregon Steelhead Plan proposes to continue with the Columbia River 


Fish Management Plan (CRFMP) harvest impacts on native steelhead.  The Oregon Steelhead 


Plan also fails to mention that the CRFMP is due for re-negotiation in 1998 and that major 


improvements for native steelhead could be accomplished in the Columbia River Basin through 


this re-negotiation.  Why is that crucial fact left out?  Why does the ODFW fail to identify the 


problems this plan has created for native steelhead conservation in the Columbia?  Why does 


ODFW not use the Oregon Steelhead Plan as a place to identify problems and solutions that could 


be used by the state in re-negotiating the CRFMP?


	The 1997 CRFMP All Species Review identifies problems with this plan that ODFW 


could have included in the Oregon Steelhead Plan.  Some of those problems are that native wild 


steelhead escapement goals, even though they remain an issue among the parties to the plan, have 


not been met since adoption of the CRFMP in 1987.  Since that time two Columbia River wild 


steelhead ESUs have been listed as federal protected species.  So the requirements under the 


CRFMP to rebuild wild steelhead populations is a complete and obvious failure.  


	To make no suggestions for revision of the CRFMP in the Oregon Steelhead Plan is 


remarkable in and of itself, but surely it is at least an inappropriate response to the NMFS as 


Oregon's answer to steelhead recovery.  Consequently, the Oregon Steelhead Plan is an 


unacceptable alternative to federal listing of steelhead as a protected species.


	The remainder of this section continues the existing management program for steelhead, it 


preserves the status quo.  





Section 111A3  Trout Fisheries





	In recent years ODFW has been eliminating hatchery trout fisheries in salmon and 


steelhead streams, to end conflicting management missions and to improve salmon and steelhead 


protection.  However, not all salmon and steelhead streams have had hatchery trout fisheries 


removed.  In some streams such as the John Day, hatchery trout stocking continues, even though 


this river is dedicated to wild salmon and steelhead management.  Such conflicts continue in most 


if not all ESUs being considered for steelhead listing.  There is an artful twist on the Grande 


Ronde where spring/summer chinook have been listed since 1992 and steelhead were listed this 


year.  The ODFW uses hatchery steelhead as catchable trout.  The hatchery steelhead residualize 


in great numbers, so Oregon has developed a fishery around them.  This fishery is justified, the 


agency says, because it removes fish that would otherwise compete with wild fish in the rivers 


where they are released.  Rather than reduce the hatchery stocking, solve the residual problem, or 


end the steelhead hatchery program using non-native stock, the state continues a practice that 


does not support the recovery of listed species.


	The "late opener" for trout fishing is used to protect smolts and the size limit is used to 


protect smaller fish, but these measures are not enough to protect rearing juvenile salmon and 


steelhead and cutthroat in rearing streams.  Until nursery waters are closed to all angling, there 


will be insufficient protection for native steelhead.   


	The Oregon Plan fails to provide adequate protection for rearing juvenile steelhead by 


designating nursery waters as sanctuaries for native salmonids.  While Oregon, through the 


Oregon Plan, fails to adequately respond to juvenile steelhead protection in trout fisheries, the state 


is forgoing one of the most necessary and effective means to increase the productivity of native 


steelhead in state rivers.





Harvest Impacts on Spawner Escapement





Snake Basin ESU





	For the Snake Basin ESU the Oregon Plan proposes to continue the escapement goals for 


steelhead adopted under the Columbia River Fish Management Plan (CRFMP) in 1987.  These 


are described as short-term goals, but no timeline is provided to determine just how short term 


these will be.  The CRFMP is to be reviewed and renegotiated in 1998 and short term should be 


defined by this process in the Oregon Plan.  The Oregon Plan states the long-term goal should be 


60,000 wild steelhead over Lower Granite Dam, which would increase the escapement goal from 


the current 30,000 (20,000 A-run and 10,000 B-run steelhead), but no time line is provided for this 


recommendation.  Also, it is unknown if this increased wild steelhead escapement goal is adequate 


for wild steelhead in the Snake Basin and for Oregon tributaries.  The 60,000 is based on earlier 


estimates established under the Lower Snake River Compensation Plan.  The estimates developed 


at that time should be re-evaluated to determine whether they are adequate to natural production 


needs.  By adequate, I mean developing escapement goals that link numerical goals with 


ecological functions important for the protection of wild native steelhead populations.  These 


would include gene conservation criteria and nutrient enrichment criteria by population.  Setting 


escapement goals 


for Grande Ronde and Imnaha rivers by June 30, 1998 must include these ecological goals to be 


derived from spawner escapement.





Two Coastal ESUs





	The priority should be changed to include adult escapement enumeration for Tenmile and 


Cummins creeks where there is now a on-going data base on smolt out- migration and summer 


juvenile abundance estimates.  By adding adult escapement counting for these streams, the data 


base will improve and help relate summer juvenile abundance and smolt yield to adult escapement.  


This is important work for a long term data series that should not be put off to some indefinite 


phase two process.


	The volunteer effort counting redds on the Salmonberry River should be augmented with a 


smolt trap on that river to evaluate the relationship between redd counts and smolt yield.  This data 


is missing for most wild steelhead streams and should be a priority for the Salmonberry rather than 


put off.





S.W. Washington ESU





	Spawning surveys should be expanded so that they run from March 1 to June 15 each 


year to take in the full spawning time for native winter steelhead.  This should be standardized for 


all wild winter steelhead spawning surveys in Oregon.





Lower Columbia ESU





	Hood River:  There should be no passage for hatchery summer or winter steelhead above 


Powerdale dam.  The upper river should be protected from hatchery introgression.  All trout 


stocking in the basin should be terminated.


	Sandy River:  No stocking of hatchery non-native summer steelhead above Marmot Dam 


is required to provide protection for wild winter steelhead from hatchery introgression and 


ecological effects of competition, predation, and potential disease transfer.  There should also be 


no stocking of non-native winter steelhead above Marmot Dam to protect wild winter steelhead in 


the basin above the dam from hatchery introgression and ecological interactions.  A fish trap 


should be installed in Marmot Dam to allow fish sorting and the removal of hatchery fish to 


prevent migration into the upper basin. There should be no release of non-native hatchery summer 


steelhead and winter steelhead below Marmot Dam. The effect of hatchery winter steelhead on 


wild winter steelhead below Marmot Dam should be evaluated and the hatchery program changed 


to dampen any effects.  Conduct a study on the river regarding genetic and life history 


characteristics to create a baseline for the wild population.  A hatchery program for this ESU 


should be converted from using domesticated non-native stock to using local brood stock in 


combination with written hatchery operation plans incorporating gene conservation protocols and 


annual evaluation.





Mid-Columbia ESU





	Deschutes River:   Strays are identified as key factor in decline of native steelhead in the 


system (Chilcote 1997).  The priority action should be the following:


1.	determine the # of strays and how many are breeding in the system, including tributaries.


2.	block all strays at Warm Spring National Fish Hatchery


3.	use trap at Sherars Falls to remove as many strays as possible


4.	stop strays from migrating up Shitike Creek





5.	for all tributaries below dams do the following:


	-  develop restoration plan for habitat and populations


	-  inventory life history attributes and genetic structure


	-  determine abundance and distribution


	-  set spawner escapement goals for each and monitor with spawner and redd counts


	-  establish floating traps to monitor adult and juvenile migrants


6.	Convert RBH to conservation program to maintain genetic and life history traits of native 


steelhead in the system including tributaries.  Eliminate existing mitigation and  production 


agreement through relicensing of hydro projects.


7. Close Deschute sport fishery to all angling when water temperature is 65 F or more


8.  Establish no fishing (sport and commercial) zone at mouth of the river.





ODFW IIA4S - Mark all hatchery steelhead





	The Oregon Plan makes an exception to marking all hatchery fish, saying, "except in 


special circumstances."  These special circumstances need to be defined and limited to specific 


written criteria.





ODFW IIIBIS - Maintain selective harvest on hatchery steelhead





	Hatchery releases to support fisheries should be evaluated in each case to determine the 


effect on wild steelhead.  Some factors to evaluate are:


	-  overharvest of wild population through mixed hatchery/wild fishery


	-  creating potential interbreeding with wild spawners


	-  specific limits on impacts to wild steelhead should be agreed to and monitored


	-  risk analysis for each case





	In all recommended program the ODFW should identify the level of risk associated with 


using local, wild brood stock in hatchery programs.  Some factors to consider are:


	-  the level of risk to locally adapted wild native steelhead that is acceptable


	-  level of acceptable straying and interbreeding


	-  level of acceptable ecological competition


	These factors should be displayed for each program and included in evaluation programs.  


Genetic fitness risk and ecological risk needs to be defined for each hatchery program and 


standards set that are included in the evaluation program.





 Ocean Productivity





	The Oregon Steelhead Plan says it will regulate fisheries in response to poor oceanic 


productivity, but ODFW has no established track record.  For example,  the 1982-1983 El Nino 


event and the ten year drought that followed, caused native, wild steelhead populations to decline.  


The ODFW, however, took no action during this period to protect wild steelhead on the Deschutes 


River, a river with a known wild steelhead production problem.  The Oregon Plan does not 


propose to take specific actions in response to changing oceanic or climate conditions that could 


be unfavorable to wild steelhead production   The Oregon Plan is vague and unresponsive to these 


problems.


 Loss Of Genetic Adaptation Of Wild Populations From Interbreeding With Hatchery 


Fish





Oregon Wild Fish Management Policy requires independent scientific review





	This section and the objectives are based on the Oregon Wild Fish Management Policy 


(WFMP) adopted in 1992.  The WFMP has never been peer reviewed by a body of independent 


scientists.  Therefore, using it as a foundation for controlling interbreeding between wild and 


hatchery steelhead should not be relied upon as being consistent with current scientific knowledge.  


For example, the WFMP calls for a minimum population of 300 to maintain genetic variation in 


wild populations, while in the scientific literature support can be found for 5,000 spawners to 


maintain long-term genetic diversity in the population (Nelson and Soule 1986).  The state of 


Washington, in their Wild Salmonid Policy, recommend 3,000 spawners divided by the average 


generation age for the species.  This means that 750 spawners per year are needed to maintain 


genetic variation in a Washington steelhead population, but only 300 in an Oregon steelhead 


population.  If  the minimum population number were used that is consistent with the scientific 


literature the minimum population in both states would be 1,250 fish.  It is unknown whether the 


numerical standard of 300 under the WFMP in Oregon is the census or the effective breeding 


population.  The Native Fish Society asked ODFW this question in May 1997 but have not 


received the pleasure of their answer.  There are similar problems with the number of hatchery 


steelhead that would be allowed to interbreed with wild steelhead, based on genetic similarity.  


The point is the WFMP used by Oregon is no longer a reliable set of criteria for basing a 


steelhead recovery or management plan on until it is updated to reflect current scientific thinking 


and is subject to independent scientific peer review.





Oregon Hatchery Guidelines have not been completed.





	Another problem with the Oregon Wild Fish Management Policy that would affect the 


state's proposed recovery program is that hatchery guidelines are required by the policy to protect 


genetic resources, but those guidelines have not been developed nor have they been implemented.  


This issue was brought to NMFS's attention regarding coho salmon as well in an earlier review by 


the Native Fish Society.





ODFW lacks institutional support for wild steelhead recovery





	In addition to the scientific problems with the WFMP, there are numerous institutional 


problems that should be taken into account by the NMFS before making a decision.  When the 


policy was first adopted it had program status with five full time staff.  It now has one staff and is 


no longer a program within the fish division.  Through ODFW reorganization job titles were 


changed but the natural production program remains a poor stepchild in a family of harvest 


managers and hatchery personnel.  Also, ODFW, through reorganization did away with the 


statewide steelhead species program manager position.  Now the steelhead program has been 


added to the responsibilities of other staff. The point being that Oregon has not supported the 


technical staff needed to manage wild, native steelhead populations and this lack of administrative 


support has resulted in loss of staff and program emphasis. Consequently, ODFW is not in a 


position to effectively provide the institutional support and management required to take over 


recovery measures for steelhead.  The NMFS should continue to retain authority over steelhead 


listing and recovery.


	


ODFW policy on hatchery and wild interbreeding needs independent scientific review





	Through the Oregon WFMP, the proportion of hatchery fish that would be allowed to 


spawn with wild fish and meet policy guidelines, ranges from 5% to 30%  if the wild and hatchery 


populations are dissimilar genetically, and up to 50% hatchery spawners if the hatchery and wild 


populations are similar.  However, it is uncertain what similar and dissimilar mean.  Without 


hatchery guidelines to conserve genetic resources in place, it would be difficult to know which 


hatchery fish were similar enough to the wild fish to meet the standards of the policy.  Allowing 


the natural spawning population to be composed of 50% hatchery fish needs to be supported by 


reference to the scientific literature.  Likewise, the other values need to be reviewed to determine 


whether they are consistent with gene conservation.  





Adjustments in hatchery stocking proposals need timeline





	While Oregon proposes to adopt changes in the way hatchery fish are used in a 


watershed to support a fishery and to minimize impacts on wild fish, those changes need to be on 


a schedule so that Oregon makes a commitment to change by a specific time and Oregon can be 


evaluated against their own timeline.  These changes would include those recommended for each 


ESU and cover changes such as recycling hatchery fish, acclimation, wild brood stock collection, 


spawning time selection etc.





Continued use of non-native hatchery steelhead should be rejected.





	ODFW proposes to continue the release of non-native steelhead in the Lower Columbia 


ESU (Hood, Clackamas, and Sandy rivers).  In 1997 non-native summer steelhead were passed 


above Powerdale Dam on Hood River.  Precluding hatchery steelhead above Marmot Dam on the 


Sandy River requires the construction of a fish trap to stop non-native steelhead from reaching 


spawning grounds.  Also, the ODFW commission approved a staff proposal in October 1997 to 


continue to release non-native summer steelhead in the Sandy River above Marmot Dam.  


	The NMFS should evaluate ODFW's commitment to their proposal to stop  non-native 


hatchery steelhead from spawning with wild steelhead in each ESU.  For example some coastal 


ESU streams, such as Yachats River  and Tenmile Creek,  are constantly exposed to high stray 


rates from non-native hatchery fish, even though these streams are designated wild steelhead 


management waters.  


  


  Competition With Hatchery Reared Fish





	In this section ODFW proposes to cut hatchery production and to shift production away 


from natural production areas and wild fish populations.  ODFW does not provide information on 


how many hatchery steelhead are released by stream or ESU so that it is possible to evaluate the 


meaning of the proposed cuts and shifts in hatchery production.  This information should be added 


to the plan so the public can better understand what ODFW is proposing.


	In 1992, ODFW released about 8 million steelhead into Oregon streams.  Some of that 


production has been reduced since then.  However, the Oregon Steelhead Plan proposes only to 


reduce steelhead stocking in Nehalem River by 50,000 smolts by 1998.  All the other cuts in 


steelhead stocking have already been done.  So the Oregon Steelhead Plan is not proposing to 


make any major reduction in steelhead hatchery production.  The apparent lack of reduced 


hatchery production should be closely evaluated by NMFS and the public should be provided with 


better information about just how many hatchery steelhead have been produced annually and how 


much ODFW proposes to reduce it to protect wild steelhead.	


	The Oregon Steelhead Plan is full of information about changes that have been made in 


the past, but contains very little information about what changes will be made in 1998 and beyond 


to protect wild steelhead.  Since wild steelhead populations continue to decline, ODFW should be 


making further changes in management and hatchery production to protect wild steelhead.  





Low Density And Reproductive Failure





	This section is about how to preserve the ODFW hatchery program more  than about 


solving problems for native steelhead.  It fails in a number of areas important for steelhead 


rebuilding.   It fails to identify by ESU those component populations that are experiencing negative 


recruitment (less than one adult progeny per adult spawner); it fails to assess reductions or loss of 


genetic characteristics by population including loss of rare alleles, and it fails to assess the loss of 


life history diversity by population.  The Oregon Steelhead Plan not only fails to provide this 


information it does not provide detailed measures to correct these problems.


	This section is based on numerical values, that is, increasing the number of adults (using 


hatchery production) rather than rebuilding healthy native wild populations based on stock 


recruitment values, stabilizing declining trends, and maintaining life history and genetic diversity 


among and within native, wild populations of steelhead.  


	Using hatchery propagation as the primary tool to rebuild native, wild populations is bogus, 


that is, the proposal ignores the experimental nature of using hatchery fish for this purpose, and 


fails to lay out an experimental design, evaluation procedures, and a risk analysis by population to 


be treated.  


	Consequently, the NMFS should reject proposals in this section as incompetent and 


require a rebuilding program that is based on genetic and life history diversity, increasing 


abundance of locally adapted populations and their distribution in their home watersheds.  All 


measures that rely on hatchery propagation must include an experimental design, evaluation plan, 


and independent scientific evaluation of the proposal.





Nutrient Enrichment Of Streams From Salmonid Carcasses





	This section identifies an experiment to evaluate the use of human distributed salmonid 


carcasses to evaluate the value they have for increasing stream productivity.  Like the previous 


section, this one describes yet another purpose for the ODFW hatchery program and tries to 


create a justification for its continued operation as a distribution center for salmon carcasses.


	This research proposal duplicates work already in progress and research that has been 


completed in Washington and British Columbia. Dr. Robert Bilby has already identified an 


optimum number of salmon carcasses to increase stream productivity.  His research shows that 


200 carcasses per kilometer should be the goal of fish managers.  Dr. Bilby says that harvest 


management has not been conducted to provide the necessary nutrient enrichment streams and 


salmon populations need to remain productive (Hunt 1997)


	In British Columbia Larkin and Slaney (1997) indicate from their research that small 


populations of anadromous salmonids are not getting the benefit from nutrient enrichment from 


salmon carcasses because intense commercial and recreational fisheries are preventing the 


needed spawner escapement.  The only streams benefiting are large systems that are being 


enhanced by hatchery propagation.  But the bulk of the streams are not enhanced.


	Oregon should be providing the measures that would increase nutrient enrichment through 


increased salmon and steelhead spawner abundance in all streams rather than merely advancing a 


proposal to test nutrient enrichment through artificial means on a few streams.


	ODFW's proposal should be rejected and the agency required to establish salmon and 


steelhead spawner abundance goals that meet the 200 carcass optimum identified by Bilby and 


evaluate the results.  


	For the coastal ESUs, ODFW is proposing harvest management actions that would limit 


nutrient enrichment.  In November, ODFW proposed to and lobbied  the Pacific Fishery 


Management Council for a coho salmon harvest policy that would reduce coho salmon 


escapement goals and allow fishing to take place before declining coho populations had recovered.  


Nutrient enrichment of steelhead streams will be dependent upon the spawner abundance of coho, 


chinook, chum, and pink salmon.  Coho salmon are of particular importance because they spawn 


high in a watershed, and in small streams, thus they are able to naturally distribute carcasses 


throughout a watershed that is also producing steelhead.


	On the Columbia River tributaries, the Columbia River Fish Management Plan adopted in 


1987 and to be renegotiated in 1998, sets the spawner abundance goals for salmon and steelhead 


based on subbasin spawner escapement needs.  However, spawner escapement goals for spring 


chinook, summer chinook, coho, and summer steelhead have not been achieved through this plan.  


In addition, the plan calls for wild salmonid rebuilding including steelhead, but this has not 


happened in the ten years since plan adoption.  And spawner escapement goals are not linked to 


ecologically important functions like nutrient enrichment or gene conservation.


	Given these two examples of how harvest management is operating against spawner 


abundance to support nutrient enrichment in watershed from salmonid carcasses, the NMFS 


should question ODFW's intentions.  The Oregon Steelhead Plan should provide NMFS with 


measures that will increase spawner abundance and therefore nutrient enrichment naturally and a 


evaluation plan to measure results.  





Predation By Pennipeds And Sea Birds





	This section is a research proposal to evaluate the effect of predation on rebuilding native, 


wild salmon and steelhead.  The problem with this research proposal is it will use hatchery 


releases as a surrogate for wild salmonids.  This is based on an assumption that hatchery fish 


behave like wild fish in terms of predator avoidance as juveniles and adults.  Hatchery fish do not 


mimic wild salmonid migration in timing and abundance.  It may be that the timing and abundance 


of hatchery releases attract predators.  There is some evidence to support this such as cormorant 


staging in anticipation of salmon releases from net pens in Youngs Bay.  Hatchery adult salmon 


tend to have an earlier freshwater entry time than wild salmonids and their migration can be 


delayed by low flows, keeping them in coastal bays where seals are attracted, as opportunistic 


predators, to the salmon abundance. Also, predators attracted to hatchery fish may also have a 


large predation effect on co-mingled wild salmonids. 


	However, the proposed research will not evaluate the role of hatchery fish in 


accumulating predation.  Consequently, the NMFS should subject this research proposal to 


independent scientific review and request a research proposal that specifically address predation 


on wild salmonids and the contribution hatchery programs make toward increasing that predation.


	This research should not be used as an excused to not list steelhead as a federal protected 


species.  This research proposal is operating on the wrong premise and research of this kind 


should be the management responsibility of the involved agencies independent of the question of 


listing steelhead.


Exotic fishes





	This research proposal should be confined to a workshop to determine effective control of 


exotic species.  The Native Fish Society recommended holding this kind of conference to NMFS 


in 1996 but we were rejected by NMFS Portland staff, using the excuse that as conservation 


advocates we were unsuited for organizing this workshop.  Nevertheless, this workshop should be 


held and we have already lost two years in doing it.  


	As a function of management, the ODFW ought to review Oregon policy and 


enforcement programs to determine whether the ODFW is doing all it can to effectively control 


introduction of exotic fishes.  After all, it is ODFW and other state fish agencies that have been 


the primary reason exotic fish have been introduced into western rivers.  For example, ODFW 


spent $130,000 in 1995-1996 for introductions of exotic char and salmon.  The agency also spent 


$51,000 on introducing exotic warm water species into state waters.  


	Research on exotic fish introductions should not be used to prevent a listing of steelhead 


as a federal protected species.  This research is a management function the NMFS should 


encourage the state to conduct.





Comments on Oregon's Steelhead Status Review





	Based on my review and supported by comments from Dr. Richard Williams (ISAB), the 


conclusions of the stock status report by ODFW are at odds with the data and observations.  The 


ODFW assigned steelhead a "sensitive" rather than a threatened status based on a model 


developed to determine steelhead status.  For example, the status report states that in the Mid-


Columbia ESU, the Deschutes wild steelhead have been near complete reproductive failure for 


the last four years, and these fish have to cope with a hatchery steelhead stray rate of 75%.  


According to the Status Report, only one recruit is produced for every ten spawners, and 


concludes "the Deschutes wild steelhead are not self-sustaining..." and, "the status of this ESU is 


more tenuous than presented in this report" if populations do not respond positively to 


improvements in passage, climate cycles, and stray rates.  


	Dr. Williams, in his letter to Director Greer of November 7, 1997, said: "The analytical 


approach and indicators used by ODFW to measure population and metapopulation (ESU) 


vulnerability appear to be less sensitive than they should be.  This leads to an underestimation of 


their vulnerability and an overly optimistic classification status (sensitive rather than threatened).


	Based on these problems, the NMFS should carefully review the ODFW Steelhead Status 


Report and provide it to the Independent Scientific Advisory Board for review and comment.  As 


it stands now, ODFW has provided the NMFS with an overly optimistic status review that 


underestimates the true condition of wild steelhead populations in Oregon.  The recommendations 


of this status review should not be relied upon for making a listing determination on steelhead.  





SUMMARY COMMENTS





	The Oregon Plan Supplement on Steelhead is a collection of on-going measures, many of 


which were put into effect by the agency a few years ago.  Conservation of native, wild steelhead 


is improved by these early shifts in management direction.  However, native steelhead continue to 


decline in Oregon even though these measures have been implemented.  This suggests that 


additional conservation measures are needed to stabilize and rebuild native steelhead.


	The Oregon Plan suggests new measures, but many are vague and lack a timeline for 


completion.  Many research measures are also proposed that will not benefit declining native 


steelhead in the near future.  The Oregon Plan does not identify critical uncertainties related to 


steelhead rebuilding measures, is does not display operating assumptions, a conceptual framework 


is not stated, funding support is not identified by measure, and evaluation and monitoring questions 


remain unanswered.  


	The Oregon Plan also omits obvious measures that should be included such as the to be 


added to a revision of the Columbia River Fish Management Plan.  The Oregon Plan fails to set 


standards and criteria for rebuilding native steelhead populations such as specific spawner 


abundance criteria that are linked to ecological functions like gene conservation and nutrient 


enrichment from spawner carcasses.  Many measures to rebuild native steelhead cannot be 


evaluated and are not accountable.  


	Scientific and public comment on the Oregon Steelhead Status Review support the view 


that its conclusions are at odds with data and observations presented in the report, that the 


vulnerability analysis underestimates the risk of extinction and are overly optimistic.  The 


conclusion that native steelhead are sensitive but do not qualify for listing as threatened or 


endangered species is not supported by the data and review of the methodology.  


	On harvest impacts to spawner abundance the Oregon Plan sets no spawner abundance 


goal by ESU or component populations.  The only direction ODFW supplies is that it will "strive 


for attainment of spawner escapement goals"  The crisis facing steelhead is acute enough that it 


would seem the agency would want to do more than merely strive to achieve spawner goals.  The 


biological objective advanced in this section cannot be evaluated and provides no accountability. 


Gene conservation and nutrient enrichment from salmonid carcasses are not mentioned as a 


function of these goals.


	The Oregon Plan fails to describe what more needs to be done to stabilize and rebuild 


native populations.  Under a federal listing there would be delisting criteria, but under the Oregon 


Plan there are no criteria presented by which efforts to rebuild steelhead populations can be 


evaluated.


	The Oregon Plan fails to develop a coherent juvenile steelhead conservation strategy in 


rearing streams.  Rearing stream sanctuaries are not discussed, and many steelhead streams are 


still being stocked with non-native fish.


	The Oregon Plan is based on the Oregon Wild Fish Management Policy in part, but this 


policy has never been peer reviewed by independent scientists and it contains standards that are 


not adequate for native steelhead conservation management or rebuilding.  Such standards are the 


300 spawner floor, and percent of allowed hatchery fish interbreeding.  


	This review concludes that the Oregon Plan should not be a replacement for listing 


steelhead as a federal protected species.





________________________________________________________________





Literature Cited





Chilcote, Mark. 1997. Conservation Status of Steelhead In Oregon. Oregon Department of Fish 


	and Wildlife.  Peer Review Draft. September 9, 1997.





Larkin, Gillian A. and Pat A. Slaney. 1997. Implications of Trends in Marine-derived Nutrient 


	Influx to South Coastal British Columbia Salmonid Production. Fisheries. Vol 22, No. 11. 


	The American Fisheries Society.





Nelson, Keith, and Michael Soule. 1987. Genetical Conservation of Exploited Fishes. In 


	Population Genetics and Fishery Management. (eds) Nils Ryman and Fred Utter. 


	University of Washington Press. 





Hunt, Ed. 1997. Salmon Survival Rates Triple When Carcasses Are Left. Salmon Trout 


	Steelheader Magazine. October/November Issue. Portland, Oregon.











12


______________________________________


Native Fish Society


Comments on Oregon Plan for Steelhead


November 14, 1997