|March 17, 2016|
Sent via email to: OregonCoastHatcheryEIS.firstname.lastname@example.org
National Marine Fisheries Service
Sustainable Fisheries Division
2900 NW Stewart Parkway
Roseburg, OR 97471
RE: Oregon Coast Hatchery EIS Scoping Comments
To Whom It May Concern:
Trout Unlimited (TU), the nation’s oldest and largest coldwater fisheries conservation organization dedicated to protecting and restoring our nation’s trout and salmon resources and the watersheds that sustain them, appreciates the opportunity to comment regarding the scope of the Oregon Hatchery and Genetic Management Plans Environmental Impact Statement (EIS). TU’s comments primarily address steelhead and consequently focus on the Hatchery Genetic Management Plans (HGMP) for the Siletz, Umpqua and Nehalem Rivers as these rivers contain strong populations of wild steelhead.
Generally speaking, TU believes that the scoping document has captured many of the most important aspects of hatchery operations and effects, particularly for Endangered Species Act (ESA) listed coho salmon. However, it is difficult to adequately evaluate the hatchery programs due to the significantly dated nature of the data being utilized. Additionally, the scoping document’s description and the HGMPs analyses of hatchery effects on non-ESA listed steelhead are quite limited, especially as compared to coho salmon. This analysis should be expanded. Specifically, the EIS should address the potential environmental effects associated with stray hatchery steelhead and the potential for high stray levels in some watersheds. The HGMPs should also include a more detailed monitoring plan to determine whether hatchery programs are achieving their goals and to what extent the programs are influencing the sustainability of wild steelhead and the fisheries they provide. These points are addressed in more detail below.
The DEIS should include a rigorous analysis of the potential significant effect of hatchery programs on wild steelhead
The EIS should evaluate the potentially significant effect of each NEPA alternative on wild steelhead populations. The HGMPs allude to implementing the hatchery steelhead programs in a way that “minimizes harm” to wild steelhead. However, the language describing the hatchery indicators for the HGMPs in the Siletz, Nehalem and Umpqua Rivers only discuss hatchery effects on run timing and the proportion of hatchery fish spawning in nature and such effects and indicators are discussed only briefly. While the effects mentioned in the HGMPs are important, there may be a wide array of other effects, ranging from interbreeding to competition and predator attraction. These effects are evaluated in detail for the ESA-listed coho salmon, but they are not even mentioned for wild steelhead.
The DEIS should address several other potential effects to wild steelhead in addition to effects on run timing and proportion of hatchery fish on the spawning grounds, such as:
- What are the genetic effects of the hatchery steelhead program on the wild steelhead populations?
- Has/does the productivity of the wild steelhead populations declined/decline in relation to the proportion of hatchery steelhead in the system (e.g., Chilcote 2004, Chilcote et al. 2011)?
- Is there a correlation between releases of large-numbers of hatchery smolts and reduced survival (Moore et al. 2015) or productivity (Nehlsen 2003) of wild smolts?
- What is the extent of residual hatchery steelhead that do not migrate to the ocean and remain in freshwater and what is their potential to breed with wild steelhead (e.g., McMillan et al. 2007; Christie et al. 2011)?
Without discussing the aforementioned questions, it is not possible to fully account for the effects of the hatchery programs on wild steelhead. Answers to the questions, and others, are necessary to understand the potential for wild steelhead populations and the fisheries that they provide and complete a thorough NEPA analysis.
The HGMPs and DEIS should ensure they are utilizing the best available scientific information to evaluate the steelhead hatchery programs
The majority of HGMPs, excluding most of the Umpqua steelhead hatchery HGMP, rely heavily on relatively old information to measure current performance standards and indicators. For example, the Siletz River winter steelhead HGMP uses harvest data from 1988-2002, which is over a decade old, and uses data from 1998-2007 to determine the proportion of hatchery fish that do not return to the hatchery and spawn in the wild. Similarly, the Siletz River summer steelhead HGMP relies on harvest data from 1993-2005, and the Nehalem River winter steelhead HGMP uses data from 1990-2000 to evaluate fishery contributions and uses data from 1999-2007 to measure indicators about various features of the hatchery fish. If available, more current scientific information and data should be used. If more recent information is not available, then the HGMPs and DEIS should be careful about drawing definitive conclusions based only on old information. The several concerns we have regarding the use of outdated data is contained below.
- First, although older data is useful for tracking status and trends – if combined with contemporary data – as standalone information it makes it impossible to understand whether the hatchery is meeting production goals and standards.
- Second, a lack of current data hinders our ability to measure performance indicators, such as the extent of hatchery fish spawning in the wild and whether the proportion of hatchery fish spawning in the wild exceeds the 10% threshold adopted by the Department. For example, fish traps in the Siletz River basin found a hatchery stray rate of 34-70%, but the information is from 1998-2007 (Siletz winter steelhead HGMP, pg. 1-6). The hatchery stray levels suggest that the program may be easily exceeding the 10% threshold, and yet, there is little discussion or evaluation of how such high levels of hatchery straying are inconsistent with the hatchery goal of minimizing effects on wild fish (Siletz winter steelhead HGMP, pg. 1-3). TU recommends that the HGMPs describe any steps taken to try to reduce the proportion of hatchery strays and whether there is more current information on hatchery strays.
- Third, we appreciate the inclusion of a potential option for expanding the monitoring of hatchery steelhead spawning in the wild in the Siletz River basin (Siletz summer steelhead HGMP, pg. 7). Nonetheless, given the potential for extensive hatchery straying into the wild, and the associated negative effects on wild steelhead, we believe such a program needs to be expanded into multiple rivers with a rigorous sample design (see more detail below). Without this type of information, it is very difficult to adaptively manage the hatchery programs through the HGMP process.
The DEIS should evaluate the effects of each NEPA alternative on wild steelhead catch-and-release fisheries and should describe the beneficial values of such fisheries.
The HGMPs contain no analysis of the benefits provided by wild steelhead catch-and-release (CnR) fisheries. CnR fisheries for wild steelhead are some of the most popular and sustainable fisheries on the West Coast, and the same is true in Oregon. This is important because as the Hatchery Scientific Review Group (HSRG 2016) recently stated, “It is now clear that the widespread use of traditional hatchery programs has actually contributed to the overall decline of wild populations.” In other words, the hatchery operations described in these HGMPs are likely reducing opportunity for CnR on wild steelhead. The extent of effects likely vary among populations, with the risks of the hatchery depending on the overall value of the CnR wild steelhead fishery. The DEIS and HGMPs should include analysis regarding the economic contributions of different types of wild steelhead fisheries and compare it to the economic costs and contributions of hatchery harvest fisheries. The DEIS should also describe how each NEPA alternative will affect CnR wild steelhead fishing opportunity.
The HGMPs should contain adequate monitoring and evaluation plans that focus on determining the extent of hatchery steelhead that spawn in the wild.
The Siletz River basin HGMP for summer steelhead includes an option for expanding the monitoring of hatchery steelhead spawning in the wild in the Siletz River basin (pg. 7). This is an important part of the scoping process given the high levels of stray hatchery steelhead that were captured in traps in the Siletz River basin. The expansion right now only includes an option for an additional fish trap, however. While the trap would provide additional data, it seems that there is already ample trap data to draw upon. Hence, we suggest that the HGMPs for the Siletz be expanded to include monitoring of genetics (e.g., DNA samples) and behavior (e.g., stray hatchery fish counted via snorkeling) to address the issue of interbreeding and determine which parts of the basin, if any, that hatchery steelhead are more likely to stray to.
Similar monitoring would be beneficial to decision-making if conducted in at least a few other systems with an appropriate sample design. There are examples of some of this in the HGMPs. For instance, information on the distribution of hatchery fish was provided in the Umpqua River basin HGMP, as was a more detailed list of indicators and potential approaches for quantifying the indicators (pgs. 6-9). We agree with the Department that it is not easy or simple to monitor hatchery effects, but, it is being done in other states (e.g., Nielsen et al. 2009, Warheit 2014c) where it has provided valuable information. Of course, genetics are only part of the question, and other methods will be necessary to evaluate all the indicators in the HGMPs. It is unlikely that all questions can be answered immediately, so we suggest that the HGMPs prioritize the questions in order of importance to the fish and the fisheries, and include an appropriate level of detail so that there is a clear path forward for addressing hatchery effects.
Thank you for consideration of these comments. TU looks forward to its continued participation in this process as it moves forward. If you have any questions about this request, please contact me at 916-214-9731 or email@example.com. Thank you.
OR Water Policy Advisor
Chilcote, M.W. 2004. Relationship between natural productivity and the frequency of wild fish in mixed spawning populations of wild and hatchery steelhead (Oncorhynchus mykiss). Canadian Journal of Fisheries and Aquatic Sciences 60: 1057-1067.
Chilcote, M.W., Goodson, K.W., and M.R. Falcy. 2011. Reduced recruitment performance in natural populations of anadromous salmonids associated with hatchery-reared fish. Canadian Journal of Fisheries and Aquatic Sciences 68:511-512.
Christie, M. R., M. L. Marine, and M. S. Blouin. 2011. Who are the missing parents? Grandparentage analysis identifies multiple sources of gene flow into a wild population. Molecular Ecology 20:1263-1276.
Hatchery Scientific Review Group (HSRG). 2015. Annual Report to Congress on the Science of Hatcheries. A. Appleby, H.L. Blankenship, D. Campton, K. Currens, T. Evelyn, D. Fast, T. Flagg, P. Kline, C. Mahnken, B. Missildine, L. Mobrand, G. Nandor, P. Paquet, S. Patterson, L. Seeb, S. Smith, and K. Warheit. www.hatcheryreform.us
McMillan, J. R., S. L. Katz, and G. R. Pess. 2007. Observational evidence of spatial and temporal structure in a sympatric anadromous (winter steelhead) and resident Oncorhynchus mykiss mating system on the Olympic Peninsula, Washington State. Transactions of the American Fisheries Society 136: 736-748.
Moore, M.E., Berejikian, B.A., Goetz, F.A., Berger, A.G., Hodgson, S.S., Connor, E.J., and T.P. Quinn. 2015. Multi-population analysis of Puget Sound steelhead survival and migration behavior. Marine Ecology Progress Series 537:217-232.
Nickelson, T. 2003. The influence of hatchery coho salmon (Oncorhynchus kisutch) on the productivity of wild coho salmon populations in Oregon coastal basins. Canadian Journal of Fisheries and Aquatic Sciences 60:1050–1056.
Nielsen, J.L., Byrne, A., Graziano, S.L., and C.C. Kozfkay. 2009. Steelhead genetic diversity at multiple spatial scales in a managed basin: Snake River, Idaho. North American Journal of Fisheries Management 29:680-701.
Warheit, K. I. 2014c. Summary of hatchery-wild introgressive hybridization for northern Puget Sound steelhead (Oncorhynchus mykiss) populations affected by segregated hatchery programs. March 2014. Washington Department of Fish and Wildlife, Olympia, Washington.