NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


503/ 977-0287





May 22, 1997





Mr. Steve Phelps


Washington Department of Fish and Wildlife


600 Capitol Way


North Olympia, WA 98501-1091





RE:  Issues related to the  Draft Wild Salmonid Policy 





Dear Mr. Phelps:  





In reviewing the draft Wild Salmonid Policy of April 1997, the 


Native Fish Society has identified the  following issues in that 


document that we believe should be specifically addressed in the 


final plan.  We are submitting these comments to you for the 


record. 





Sincerely,   


Bill M. Bakke Director  





ISSUES IDENTIFIED IN THE WILD SALMONID POLICY 








 APPENDIX A ISSUES  





Resolving Stock Conflicts 





Issue:  


The WSP ought to mandate a stock by stock management program 


rather than aggregate collections of  stocks into management 


units.  Aggregation increases risk, especially to small less 


productive populations.   These small populations should be the 


bellwether of the WSP.  If the small, less productive populations  


cannot be maintained through this policy then it will fail to 


maintain biological diversity, evolutionary  potential and genetic 


variation of adapted stocks within each species.   





 APPENDIX C ISSUES  





Issue: 


Are water quality and sediment standards adequate in the state 


law? Appealing to state laws that are not  adequate or not enforced 


do nothing for the fish.  How effective is this kind of language in 


making the WSP  work on the ground?  The WSP should state the 


standards it must rely on to sustain native, wild  populations of 


salmonids in the state.  If the standards presently adopted as 


state policy are not adequate to  protect native species they 


should be identified.  The WDFW should recommend in the WSP 


those  standards that should replace inadequate standards 


adopted by the state, or standards the state should  adopt where 


none now exist. 





 APPENDIX D ISSUES  





Issue: 


WDFW argues MSY rather than MSE can be used to rebuild wild 


stocks, protect local adaptations and  genetic diversity, but does 


not explain this assumption.  Certainly it has not been used to 


accomplish these  good goals in the past.  The discussion should 


explain how it has been used to cause the decline in stocks  and 


how it can be used to protect the stocks according to the policy.  In 


addition, the MSY or MSE standard  must address ecological 


functions.  The numerical value of these standards should be 


based on delivering  specific ecological values.  The two I am 


thinking of are: achieving the nutrient capital standard for each  


watershed from fish carcasses, and maximizing natural selection 


by having enough spawning adults to  maintain locally adapted 


and genetically diverse stocks.  The effective breeding population 


is about 1/4 of  the census population.  In other words, if the 


biological goal for adult spawners is 1000, then 4000 actual  


adults must be in the spawning escapement. 





Issue:  


WDFW assumes the management unit at the stock level will 


provide benefits of fine scale (sub-stock  structure management) at 


less cost and allow more harvest.  Yes, maybe this is so, but at 


what risk.  A risk  analysis of this "assumption" must be done.  


This assumption places small less productive stocks, or  sub-


stocks at risk.





Page D7  Issue:  


Fails to describe value of small less productive populations and 


fails to include standards to provide  conservation management of 


these populations.     Issue:  500 spawners (effective breeding 


population) is adequate for maintaining genetic diversity over 


short term, a  few generations according to the literature I looked 


at. But this must be the Nb population not the N population.  If the 


adult escapement (N) is 500 then the  effective breeding 


population (Nb) is 125.  An effective breeding population of 125 is 


not adequate to  maintain the genetic integrity of the wild 


population.   The WSP must state whether the 500 number is Nb or  


N.  Issue:  MSY is a harvest/commodity production model that 


assumes salmon produce a harvestable surplus and it is  


predicated upon a non-fluctuating environment.  This model has 


not been successful in protecting native,  locally adapted stocks 


especially small, less productive ones.  It ignores ecological  


values such as stock  fitness to cope successfully with a 


fluctuating environment, and natural selection and nutrient capital 


by  stock and watershed. Saying MSY can be used to protect 


stocks and maintain biological functions is a  critical uncertainty 


that must be evaluated and treated as an experiment.  It is loaded 


with risk and must be  treated as such.  MSY is harvest friendly 


not conservation biology friendly.  As we have found out, if  


WDFW is not conservation biology friendly the harvesters lose 


opportunity and the resource loses  capacity.





APPENDIX E ISSUES





Issue:


The 500 spawners issue here again.  To get 500 Nb (effective 


breeders) the spawner escapement must be 500  X 4 = 2,000.  I 


hope the WSP is treating the 500 spawners as Nb rather than N or 


it will not prevent the loss  of genetic diversity and locally adapted 


stocks will continue to be lost.  The first to go will be the multitude  


of small, less productive stocks.





APPENDIX F ISSUES





Issue:


There is no discussion on ecological interactions regarding 


disease and transfer of disease to wild stocks.   And there is no 


discussion of disease treatment of hatchery fish and the potential 


for developing  resistant  strains of pathogens that outrun the 


capacity of wild stocks to resist them.  This is a major issue in the  


document.  The hatchery folks are scared of disease issues and 


have shown an aversion to discussing them  publicly.  Disease 


treatment in the form of chemicals such as formalin is potentially a 


very serious EPA water  quality issue since this chemical is a 


carcinogen, and released into public waters.





APPENDIX H ISSUES





Issues:


RASP:  This definition would control the use of supplementation 


but the discussion is limited to this section  (the appendices) and 


should be stated in the policy alternatives.    Gene conservation 


protocols:  This is not mentioned.  Protocols must be identified 


and implemented to  maintain genetic diversity and local 


adaptation of hatchery stocks and to minimize genetic problems 


when  hatchery fish interbreed with wild fish.  Even if one takes the 


hatchery brood from wild fish, the hatchery  environment will 


select for traits that favor survival in the hatchery and select 


against traits that favor  survival in nature.  Consequently, 


hatchery fish will always diverge from their wild ancestors. 


Genetic  protocols are needed to control and slow this divergence, 


but it cannot be stopped.  One must also ask, do  we want the 


hatchery fish to be like wild fish.  Maybe the only reason we have 


wild runs left is that hatchery  fish have been like drones and have 


not been effective breeders.  Taking this route and trying to make 


them  more effective at breeding in the wild may be the single 


most important item causing the extinction of our  remaining wild 


runs.  Yes, this whole issue is a critical uncertainty and should be 


tested.  Uncertainties must  be monitored.  A monitoring plan must 


be developed and all uncertainties must be identified.  I do not see  


this in the WSP  Low similarity and high similarity of hatchery 


stocks to wild stocks must be defined by specific criteria to  guide 


the implementation of the WSP.  It is needed so decisions can be 


made.  They are game rules so one  can successfully play the 


game.    Ignores the fact that hatchery fish diverge from their wild 


source stocks through domestication selection.  A  hatchery stock 


that has high similarity to the parent wild stock in generation one 


may have low similarity in  generation three.  The test for hatchery 


fish is to evaluate the survival of the F3 generation in producing  


adult progeny.  So far the record is rather poor.  Yet the hatchery 


fish spawn, interbreed with wild fish and  compete for food and 


space.  They are, as Jim Karr said, biological pollution.  We 


purposely release drones  to control insect pests now we are 


doing it to salmon.





OTHER ISSUES





Issue:


No discussion of WDFW institutional structure changes needed to 


implement the WSP.





a. Need specific staff expertise (genetics, T&E specialist, 


biometrician, habitat, program director, staff to  write  WSP 


annual report on status of native, wild populations.


b. b.  Need program structure and staff to implement the WSP 


internally as well as externally.  The program  director should 


report directly to the agency director.


c. c.  This staff will in effect, be the ones responsible for 


ensuring the WSP is implemented by the agency  and will be 


the home for conservation management in the agency.   The 


dual mission of WDFW to provide  harvest and conserve the 


resource then will have the organizational structure to do the 


job. The WSP must  add a discussion of the institutional 


structure it will use to implement the policy.





Issue: 


 No discussion regarding how other agencies will be organized to 


assist WDFW in implementation standards  of the WSP especially 


for habitat.  These would include state and federal land and water 


management  agencies.  The governor's office should be 


organized to get the habitat agencies to respond to fish  


conservation issues.


Issue: 


Need to address monitoring and evaluation in a separate 


appendix and incorporate in a discussion of  monitoring and 


evaluation among the alternatives.  The M&E program must 


address adaptive management  and how the WSP proposes to use 


it to inform policy and management of salmonids.


Issue:  Need time series data base on population/habitat by 


ecological region in state to measure the  effect of WSP  as a 


management policy.  Need to develop reference populations by 


ESU, GCMUs and/or Ecological  Regions in state.  Time series 


data base grows in value the longer it is in place.  This is a long -


term  commitment to data collection.


Issue:  Need reference wild, locally adapted native populations 


and habitat throughout the state.


Issue:  Columbia River reservoir drawdown or dam breaching is 


not discussed in the WSP, but for Washington  native salmonids 


in the Snake basin, this may be the only way they will be 


recovered.





GENERAL LIST OF STANDARDS OF THE WSP:


1. Hatchery supplementation will be based on RASP


2.  Harvest based on MSY not MSE


3. Management Units are "Stocks in major basin that empties 


into saltwater" 


4. Assumption that Management Units as defined work for 


substock protection.


5. Spawner counts - should be all wild stocks including wild 


strays.


6. Spawner escapement = 500 (Is this the effective breeding 


population?)


7. Habitat management and protection to address all life history 


stages.


8. Habitat standards for LWD, O2, pH,etc.(state standards).


9. Management priority = TES stocks (the ones in trouble).


10. State template to guide local restoration efforts promised.





ARE ALTERNATIVES COMPARABLE  The main difference among all 


alternatives is in fish management since the habitat criteria has 


the same  potential among all alternatives except alternative no. 1 


(p.21)  





Issue:


It is difficult to compare alternatives because the categories are 


not consistent among them.  For example,  Alternative 2 has 14 


categories from spawner abundance to gene banking.  However, 


Alternative 3 has only  5 of these 14 categories listed, stating 


standards and criteria.  Recommend developing a spread sheet by  


alternative, listing categories and standards and criteria for each 


category.  The spread sheet should include  at least the following 


categories:  Spawner abundance, What counts as a spawner, 


M&E, Gene  conservation, Base spawner number, Ecological 


interactions, Gene flow, Fishing selectivity, Hatchery,  Habitat 


fragmentation, Harvest, Supplementation, Gene banking.    I did a 


spread sheet and found Alternative 2 did a fairly complete job of 


listing categories and standards per  each, but alternatives 3,4,5 


did not.





Issue: 


In the final WSP the agency should identify the priority each 


measure will have for implementation and the  funding required to 


do the work.  Also, the agency should put wild salmonids as a cost 


category in its  budget so the public can identify the amount of 


money that is being invested for protection of native wild  


salmonids in the state.





Bill M. Bakke


Native Fish Society May 22, 1997