The following letter is about the failure of ODFW to take 


effectiveconservation action to protect wild, native steelhead on 


the Sandy throughthe approval of the Sandy Basin Fish Management 


Plan last Friday, Sept. 26,1997.


__________________________________________________________________


_______





NATIVE FISH SOCIETYP.O.


 Box 19570Portland,


 Oregon 97280503/ 977-0287


September 29, 1997





Ms. Donna Darm,


 LeaderProtected Species Program


National Marine Fisheries Service


7600 Sand Point Way, NE


Seattle, Washington 98115-0070





Dear Ms. Darm:	





The Oregon Department of Fish and Wildlife staff recommended and 


the ODFW Commission approved a fish management plan for the Sandy 


River (Lower Columbia River ESU) that is not sufficient to protect 


nor to restore native, wild winter steelhead.  The following is my 


account of the problems with this plan.  In my opinion, the ODFW, 


has ignored conservation management of wild steelhead and have 


merely thumbed their nose at cooperative efforts to protect a 


species at risk.   Until the harvest management staff is removed 


from their leadership role at ODFW, there will be no real gains 


made in conservation, and all native populations of salmonids will 


remain at risk of extinction. Unfortunately, the policy body of 


the agency, the ODFW Commission appear to be unwilling to take 


control of the agency. 





Sandy River Fish Management Plan	





In this plan non-native winter steelhead and non-native summer 


steelhead will continue to be stocked in the Sandy River for a 


sport fishery.  The summer fish will continue to be stocked above 


Marmot Dam into streams where wild native winter steelhead spawn 


and rear.  The non-native winter steelhead will be stocked below 


Marmot Dam, but there is nothing to prevent them from passing this 


dam and spawning upstream in the areas where the native winter 


steelhead spawn.  According to the ODFW staff 80% of the spawning 


and rearing habitat is upstream from Marmot Dam, and this is where 


the bulk of the non-native steelhead are either released or where 


they migrate to from release sites further downstream. According 


to Mark Chilcote's analysis 39% of the spawning winter steelhead 


above Marmot Dam are of non-native origin, even though non-native 


hatchery steelhead have been stocked below the dam since 1989.


	In addition, bait fishing for trout and steelhead is allowed 


above Marmot dam using barbed hooks.  Locals have asked ODFW to 


remove bait and barbed hooks in the upper watershed for years to 


protect rearing juvenile native steelhead, but the agency refuses 


to do so.  The reasoning used to keep this regulation going is 


that the non-native summer steelhead have to be harvested and bait 


fishing is needed.  	According to Mark Chilcote's "Conservation 


Status of Steelhead in Oregon", Peer Review Draft 9-09-97, the 


native winter steelhead has been in a steady decline since themid-


1980s,  the Sandy wild native steelhead are described as having 


"low reproductive resiliency", and the report says the native 


population could be improved by removing non-native hatchery fish 


from spawning with wild steelhead.


	The Sandy Basin Fish Management Plan adopted by the 


commission is not consistent with nor is it responsive to the 


Chilcote status report.  A very disappointing show on the part of 


ODFW.	


There is hope that a trap could be placed in Marmot Dam to allow 


for the separation of non-native winter steelhead, preventing them 


from going upriver where the wild fish reproduce.  This, however, 


will not solve the problem of non-native summer steelhead that are 


stocked directly into the basin above the dam. This trap will not 


be in place for many years.  It is a high priority but right now 


there is no money to construct it. 





	Another problem rests with ODFW's administrative 


fragmentation of the wild steelhead habitat in the Sandy Basin and 


other basins.  The river below Marmot Dam is reserved for hatchery 


based fishing, the river above is to be the reserve for native 


fish production once the trap is in place.  But there are winter 


steelhead that spawn below Marmot Dam.  I asked ODFW to evaluate 


this, but they did not.  It is a mistake to assume that all native 


wild winter steelhead are late run fish (late Feb. through June).  


There is plenty of historic evidence of wild fish using this and 


other rivers in Nov. through Feb.   





	I have also heard that at Hood River there are only 60 


unmarked summer steelhead above Powerdale Dam (a few weeks ago) 


and that ODFW was letting Skamania hatchery steelhead above the 


dam.  This comes from an ODFW staff, but I was also told by 


district biologist that they were stopping all hatchery fish at 


the dam.  Apparently this was not true.  The reason for letting 


non-native hatchery fish above the Powerdale trap is to support a 


sport fishery in the canyon.  Well,  this canyon is so remote that 


creel checkers do not find it worth their while to find the few 


people who fish the canyon.  Anyway, non-native hatchery summer 


steelhead are being released above the trap at Powerdale dam.





	Since ODFW staff and commission are unwilling to protect 


native winter and summer run steelhead in the lower Columbia ESU, 


it would be good for them to get awake up call by listing these 


fish as federal protected species.  The fish need the protection 


and ODFW needs to be reminded to follow its conservation mandate.  





Sincerely,


Bill M. Bakke, 


Director