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Does Washington's Statewide Steelhead Plan Matter?

By Pete Soverel

- Steelhead Committee, Fly Fishers International -

Almost three years ago the Washington Fish & Wildlife Commission adopted a Statewide Steelhead Management Plan (SSMP) and its related Final Environmental Impact Statement. The SSMP explicitly places "the highest priority on the protection of wild steelhead and restoration of these stocks to healthy levels" and established the performance standards against which the SSMP should be measured -- "...steelhead program operations strategies must be carefully monitored to insure that the actions are restoring and maintaining abundance, distribution, diversity and long-term productivity to steelhead and their habitats." The FFI Steelhead Committee had been directly involved in the twenty year process ( 1989-2008) to develop, approved and implement an actual plan to provide strategic guidance for managing steelhead resources. Three years later, it is fair to assess the promise with results. How has the SSMP been or not been applied in three areas:

Wild Steelhead Management Zones

A key feature of the SSMP was the establishment of wild steelhead management zones. The Commission stipulated that the state would establish "...a network of Natural Stock Reserves ... across the state consistent with the applied definition. One natural stock reserve will be established for each major population group with the following characteristics 1) the area of the natural stock reserve must incorporate the spawning area of the stock, 2) the stock must be sufficiently abundant and productive to be self-sustaining into the future, 3) limited direct and indirect influence from hatchery production."

So three years on, the Washington Department of Fish and Wildlife (WDFW) has not identified, proposed or adopted any such natural stock reserves. Nor has it held any public meetings with shareholders to identify potential reserves. Astonishingly, when queried on this subject at a public meeting in Forks in March 2010, the Department acknowledged that no work had been done on this Commission directed initiative but noted that the Puyallup River might be a good candidate, even though the Puyallup clearly failed on criteria 2 and 3 above.

Elwha River Recovery Plan

Soon, workers will start dismantling the two fish blocking dams on the Elwha River which will permit access to about 100 miles of pristine anadromous habitat upstream of the dams in the Olympic National Park -- habitat that will remain pristine and natural forever. This, of course, is a historic opportunity to restore natural, self-sustaining, diverse genetic and life history structures, spatially distributed, and abundant populations of anadromous fish stocks -- key goals of the SSMP.

How do we get from the present to that exciting future? On a matter of such import, it is reasonable to have expected that fish recovery plans would have been subject to the legislatively mandated state and federal environmental assessment processes. Instead, the Elwha River Fish Restoration Plan, (NOAA Technical Memorandum NMFS-NWFSC-90, April, 2008) is a technical memorandum in which there has been no effective public engagement, outside (peer) reviewed science or a discussion of alternatives, risks, benefits and costs. In the case of WDFW, it is certainly reasonable to expect that the recovery plan would have been based upon the SSMP and engaged the public in the process. Instead, the only issue upon which WDFW has sought public input has been a proposed five-year fishing moratorium. The Steelhead Committee, along with a slew of other fish conservation organizations -- Wild Fish Conservancy, The Conservation Angler, Native Fish Society -- and prominent fisheries biologists Dr. Jack Stanford, Director, Flathead Lake Biological Station) and Jim Lichatowich) have objected formally to these procedural and scientific discrepancies summarized below.

The Plan has not undergone any ESA consultation -- it is a technical memorandum that outlines numerous actions. The Final Supplement to the FEIS for Elwha River Ecosystem Restoration Implementation mentions fish recovery, but the Plan is much more detailed, and it implies it is the specific plan required by the Elwha Act (PL 102-495) (p. ix). Unfortunately, the Plan is not an environmental assessment and is neither sufficient nor in compliance with applicable state and federal statutes. Specifically, the Plan does not assess various alternative actions which identify risks and benefits. Thus, prior to implementing this Plan (or any fish recovery plan), state, federal and tribal authorities must conduct the legally-mandated environmental assessments before any action proposed under the plan that may affect any ESA listed salmon, steelhead, or bull trout ESU/DPS is taken.

Any such environmental assessment would force WDFW to reconcile proposed actions with relevant policy guidance such as the SSMP, current and emerging science relative to the impacts of hatchery fish and so on.

Numerous elements in the Plan prima facie pose threats to listed ESUs and DPSs and therefore require that the NMFS and USFWS re-initiate consultation under Section 7 to determine that implementation of the Plan will not jeopardize the Puget Sound Chinook and steelhead ESUs and the bull trout DPS. While we are bringing this matter to the attention of NMFS and USFWS, it is incumbent on the WDFW to ensure that its obligation to avoid "take" of listed species is met through Section 10.

The Plan raises numerous issues that are sufficiently controversial and that prima facie threaten harmful impacts to the affected environment as to require that WDFW comply with SEPA and the federal agencies comply with NEPA and produce an Environmental Impact Statement that specifically addresses plans for the restoration that will be occasioned by the start of dam removal in 2011. Most prominent among these is the proposed use of numerous types and levels of artificial production that the Plan indicates are intended to "jump start" the recolonization of the Elwha River basin by anadromous species and/or preserve extant anadromous fish stocks in the lower Elwha River from suspected short-term adverse effects of the dam removal process. Several aspects of these proposals appear to be at considerable odds with current scientific information and expert opinion regarding the uncertainties and adverse impacts of several kinds of artificial production on indigenous, wild/naturally spawning, salmonids. This alone requires a full alternatives analysis be presented for public review.

As noted above, the dam removals present a rare and invaluable opportunity to evaluate and monitor the natural recolonization by native migratory salmonids of a largely intact major riverine ecosystem in the absence of the confounding and corrupting influence of hatchery programs and hatchery fish. Natural recolonization provides a unique opportunity for the region to evaluate conservation hatcheries as well as management regimes by providing a critically needed natural control free of the confounding influence of fish from large-scale in-basin hatcheries.

Sensibly, the Plan relies on natural colonization for eulachon, lampreys, cutthroat trout, summer-run steelhead, pink salmon, chum salmon, sockeye salmon and coho salmon. Quite incredibly, the Plan will utilize large-scale hatchery programs to "jump start" Chinook salmon and winter steelhead recovery. This reliance on artificial production does not reflect best-available science, ignores numerous recent peer-reviewed publications describing the risks that hatchery fish in general and supplementation programs in particular pose to wild salmon and steelhead, and is at variance with the stated recovery goals associated with dam removal. The SSMP promised WDFW would address each of these issues in managing salmonid resources. Yet, presented with a real case in which to do what was promised, WDFW has, instead, gone back to the bad old days.

WDFW proposes a fishing moratorium even while it continues to rely heavily on various hatchery schemes, especially for winter steelhead and Chinook. Incredibly, the Plan even includes a "maintenance" steelhead hatchery plan based upon continued planting of non-indigenous Chambers Creek hatchery winter steelhead. The features of this "maintenance" program (what is its purpose, how many fish will be released, how do WDFW, the tribe, NOAA and the Olympic National Park propose to prevent the returning adults from interacting with colonizing wild steelhead, and so on) are not addressed in the Plan

The hatchery programs proposed are huge. In 2009 and 2010, 2,700,000 Chinook and 59,500 Chambers Creek steelhead were planted, and the plan for 2011 and 2012 are identical. Clearly, WDFW envisions on-going huge hatchery releases into what has been trumpeted as a wild fish recovery. Not only does the Plan depend upon using non-native Chambers Creek hatchery stock, it is completely at odds with the stated goals of the Plan, especially when coupled with a fishing moratorium and the absence of physical barriers to prevent hatchery steelhead from interacting with all naturally spawning colonizing steelhead. The authors of the Plan are well familiar with the many pernicious, adverse impacts that Chambers Creek stock are known to have on naturally spawning wild stocks. In this case, when the numbers of naturally spawning steelhead colonizing the watershed will initially be low, the impact of Chambers Creek fish on these stocks will be much amplified -- all issues that would have to be evaluated in any environmental assessment against existing science and state/federal policy mandates such the SSMP and ESA 4d rule making. [Editor's Note: The 4(d) rule allows the 'take' of threatened species in some circumstances if doing so does not put the specie's or population's survival at risk.]

To top it all off, one can only be mystified at the proposed continuation of huge hatchery programs that consume public resources to collect, rear and release millions of hatchery fish, which are known to pose grave risks to colonizing wild stocks, for which the state now proposes to ban fishing. It is not only a mystery; it is financially irresponsible.

Snider Creek Wild Brood Stock Program

Twenty-five years ago, WDFW and the Olympic Peninsula Guide Association entered into a 25-year cooperative program the purpose of which was to "enhance" the Solduc River early run timed component of the existing wild steelhead population. The program is based upon the hook and line capture of up to 34 (initially 50) wild adult winter run steelhead in the Solduc, their transportation to a holding facility, spawning, rearing to state smolt standards (6/7 per pound) at the Snider Creek facility in the upper Solduc basin near Forks and release. The brood stock must be captured prior to February 1.

WDFW is now considering whether to renew the agreement in what can only be considered a prime candidate for a natural stock reserve -- the Solduc wild winter run is probably the healthiest stock in the state. Quite sensibly, WDFW proposed several evaluation criteria to guide the decision-making process in this key test of the SSMP:

1. What is the contribution of Snider Creek production to the sport and tribal fisheries? Based upon the 25 year data set, the contribution is very low, especially as represented in the early tribal fishery. Particularly puzzling is the discrepancy between extrapolated run sizes and the extremely low level of Snider Creek adults sampled by either tribal gill nets or the sport fishery. For example, the projected 2008/2009 run size was calculated at 422, yet only 46 fish were captured in the sport and gillnet fisheries -- approximately a 10% exploitation rate, which is far below the typical sport/tribal exploitation rate of about 40%. What accounts for the wild difference? Further, WDFW projects a 2009/2010 Snider Creek run of 882 but provides no supporting data. Additionally, this data appears to be at variance with the earlier experiences regarding the Snider Creek program, which essentially provides few or no returning adults.

2. How does production from the program compare to the production that could be expected had the broodstock fish spawned naturally? Since its inception, this program has operated at a net loss to wild stocks.

3. Is the Snider Creek program producing early timed returns as intended? There is no indication that the program is either producing early timed migrations or contributing to increased numbers of naturally produced wild fish. The tribal fishery (the best indication of entry timing) catches very few Snider Creek fish, which contradicts the premise that Snider Creek fish return early or in any significant numbers. Further, based upon anecdotal information provided by angling colleagues (left ventral fin clipped summer runs captured in the vicinity of Snider Creek) suggest that the Snider Creek brood stock program may be mixing unintentionally wild early returning Solduc winter steelhead with wild Solduc summer-runs.

4. What effect do Snider Creek steelhead mixing on the spawning grounds with naturally produced steelhead have on the genetics and productivity of the natural production? This is, of course, a key question at the heart of the Steelhead Management Plan. Yet, after 25 years of experimenting, the Department is completely unable to answer or even begin to answer this critical question. For the entire 25-year period of the program, there has been no monitoring program in place to assess the impact of the program on wild stocks.

5. What proportion of the early timed Solduc River natural steelhead return is being removed for broodstock? Since WDFW has no monitoring program in place or contemplated to determine the size of the early timed Solduc population, it is clearly not possible to answer this question.

Failing to either answer or even attempt to answer its own sensible questions, one can only wonder what criteria WDFW will use to decide whether or not to renew this misguided program. Let's just skip questions regarding the impact of this program on naturally produced Solduc winter run steelhead. Instead, WDFW might evaluate the Snider Creek program in terms of its own hatchery guidelines. Using any metric they may wish to chose (egg to eyed egg survival; eyed egg to alvin; alvin to smolt; smolts per pound; smolt to returning adult rates), the Snider Creek program falls far below state standards. For example, Snider Creek hatchery fish return at a rate ten times less than the nearby Bogachiel hatchery. Snider Creek smolts never meet the state standard of 6-7 fish per pound at release. Generally there are a few large individual fish (prone to residualize) and a large number of under-sized fish which are not likely to migrate as they are too small. Instead, they are likely to remain in the river competing with wild Solduc juveniles.

Judged only on the basis of hatchery efficiency, the Snider Creek program is not justifiable. However and more importantly, the Snider Creek program is based upon mining naturally produced Solduc steelhead with their unique evolutionary legacy and which reduces the net reproductive potential of these fish compared to letting them test their fate in the wild. In other words, notwithstanding the many outstanding deficiencies in data upon which to base a decision about the future of the Snider Creek program, it is clear that the Snider Creek program is harmful to the wild winter Quileute steelhead population. [Editor's Note: the Solduc and Bogachiel rivers converge to form the Quillayute River] It reduces overall abundance, drags down the evolutionary and reproductive fitness of the precious wild fish that the program removes from its native environment.

Moreover, there is currently no conservation concern for the Quileute system wild winter-run steelhead populations that could motivate even the consideration by responsible managers of a supplementation hatchery program using local wild broodstock. Any consideration of such a hatchery program, on however small or large a scale, in any river in Washington that contains wild steelhead, requires careful scientific evaluation and review. By any reasonable standard of evaluation the Snider Creek program would fail the test.

Evaluated against the promise to accord the "the highest priority on the protection of wild steelhead and restoration of these stocks to healthy levels" WDFW comes up way short in each of the above issues. The state not established the mandated natural stock reserves or even begun the planning process to identify candidate zones. In the case of the Solduc and Elwha rivers, both of which would rank very high on any such candidate list, WDFW has continued to rely on hatchery activities that are known to be harmful to the very stocks the Statewide Steelhead Management Plan promised to accord the "highest priority." Further, in each of those cases, WDFW has not developed or implemented monitoring programs as stipulated in the SSMP "to insure that the actions are restoring and maintaining abundance, distribution, diversity and long-term productivity to steelhead and their habitats."

Hardly encouraging.

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