COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION 700 NE Multnomah Street, Suite 1200 Portland, Oregon 97232

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1 COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION 700 NE Multnmah Street, Suite 1200 Prtland, Oregn (503) F (503) April 20, 2016 Dr. Greg Ruggerne, Independent Scientific Advisry Bard Chairman Nrthwest Pwer and Cnservatin Cuncil 851 SW 6 th Avenue, Suite 1100 Prtland, OR RE: Review and analysis f histric run-size estimates frm Density Dependence and its Implicatins fr Fish Management and Restratin in the Clumbia River Basin Dr. Ruggerne and Independent Scientific Advisry Bard members: In July 2015, the Clumbia River Inter-Tribal Fish Cmmissin (CRITFC) prvided cmments n the Independent Scientific Advisry Bard s (ISAB) reprt, Density Dependence and its Implicatins fr Fish Management and Restratin Prgrams in the Clumbia River Basin, hereafter referred t as the Reprt. CRITFC strngly bjected t the ISAB s re-estimate f histrical Clumbia River salmn and steelhead run-sizes (~ 6 millin adults) presented in Chapter III f the Reprt. Serius cncern was expressed by CRITFC staff that the data and assumptins used by the ISAB relied t heavily n wrk by Chapman (1986) and did nt cnsider ther imprtant research. In particular, CRITFC is cncerned with the difference in predevelpment adult run-sizes between the Reprt and thse develped and adpted by the Nrthwest Pwer and Cnservatin Cuncil (NPCC) in 1987 (10-16 millin adults), frmerly knwn as the Nrthwest Pwer Planning Cuncil. The Reprt estimate is substantially lwer than the NPCC 1987 estimate and it is incnsistent with tribal ral histry. A widespread perceptin f a lwer histrical run-size culd ptentially influence restratin gals within the Clumbia River basin. T prvide further insight int the discrepancy between the Reprt s pre-develpment adult runsizes and thse f the NPCC, CRITFC cntracted with Jhn Marsh, f Marsh Cnsulting LLC, t prvide a technical analysis f Chapter III in the Reprt. Mr. Marsh is a plicy analyst, attrney, and scientist, wh spent 14 years with the NPCC as the Prductin and Habitat Manager in the Fish and Wildlife Prgram. During his time with the NPCC, Mr. Marsh was extensively invlved in the develpment f the NPCC s estimate f Clumbia River Basin salmn and steelhead runsizes. In CRITFC s review f Mr. Marsh s memrandum (attached t this letter), it is apparent that imprtant data and infrmatin were nt included in the ISAB s estimate f pre-develpment salmn and steelhead run-sizes. Specifically, seminal wrk by Dr. Allan Schlz did nt appear t be meaningfully cnsidered by the ISAB in its analysis. Further, we agree that the ISAB relied t heavily n Chapman s (1986) wrk and seemingly ignred the NPCC s wrk. As such, Putting fish back in the rivers and prtecting the watersheds where fish live

2 Dr. Greg Ruggerne, ISAB April 20, 2016 Page 2 f 2 CRITFC agrees with Mr. Marsh s verall assessment that the ISAB Reprt des nt cnstitute a sufficiently inclusive reanalysis t warrant mdifying the NPCC pre-develpment run-size estimates. If the NPCC pre-develpment run-size estimates were ever t be recnsidered, CRITFC wuld recmmend that a careful and extensive literature review and data analysis be cnducted within the cntext f a diverse expert panel that wuld include cnsultatin with the tribes that have resided in the Clumbia River basin since time immemrial. While CRITFC appreciates new perspectives n histrical salmnid abundance, the ISAB s estimates in the Reprt are inadmissibly lw and culd ptentially lwer the bar fr restratin f what was nce cnsidered t be the center f abundance fr chink salmn and steelhead trut. Thank yu fr yur cnsideratin. If yu have any questins please cntact me r Dr. Zachary L. Penney, Fishery Science Department Manager (503) Sincerely, Babtist Paul Lumley Executive Directr Enclsure Cc: 15 Tribes, Clumbia Basin Tribes Calitin Michael Frd, Nrthwest Fisheries Science Center Divisin Directr Jim Ruff, Nrthwest Pwer and Cnservatin Cuncil Members, Nrthwest Pwer and Cnservatin Cuncil Erick Merrill, Independent Scientific Review Prgram Manager

3 March 1, 2016 Final Memrandum TO: FROM: SUBJECT: Rb Lthrp, CRITFC Jhn Marsh Review and Analysis f Density Dependence and its Implicatins fr Fish Management and Restratin in the Clumbia River Basin INTRODUCTION This memrandum addresses a review and analysis f Chapter III (Pre-develpment Capacity f the Clumbia River Basin) f the dcument titled Density Dependence and its Implicatins fr Fish Management and Restratin in the Clumbia River Basin (2015) authred by the Independent Science Advisry Bard (ISAB). The purpse f the review was t cmpare the findings and ratinale f the ISAB related t pre-develpment Clumbia Basin salmn run size estimates with thse adpted by the Nrthwest Pwer Planning Cuncil, nw knwn as the Nrthwest Pwer and Cnservatin Cuncil, (Cuncil) in its Clumbia Basin Fish and Wildlife Prgram in BACKGROUND The fcus f this analysis is t lk at assumptins fr differing estimates f ttal run size f all anadrmus Pacific salmn species, including steelhead trut, that returned annually t the Clumbia River Basin t spawn, hereafter referred t as adults, prir t the ccurrence f develpment activities (abut 1850). The ISAB estimates the maximum pre-develpment run size as 6 millin adults based n the primary evidence. The Cuncil prgram lists average pre-develpment run size as 10 t 16 millin adults. The ISAB and Cuncil tk different appraches fr arriving at their respective cnclusins: The Cuncil (1986) estimated run sizes f 10 t 16 millin adults based n lwer river cmmercial catch. It als used an alternative apprach based n lwer river cmmercial catch, upriver Indian and settler catch, and higher catch efficiencies that resulted in an estimate f 12.5 t 13 millin adults. The ISAB extensively reviewed Chapman (1986) which estimated run sizes f 8 t 10 millin adults based n lwer river cmmercial catch. Bth the Cuncil and the ISAB cnsidered the Pacific Fishery Management Cuncil (PMFC) (1979) estimated run sizes f abut 8 millin adults using a habitat-based apprach.

4 The Cuncil, but nt the ISAB, cnsidered the reprt by Schlz, et al. (1985), entitled Cmpilatin f Infrmatin n Salmn and Steelhead Ttal Run Size, Catch and Hydrpwer Related Lsses in the Upper Clumbia Basin, Abve Grand Culee Dam. Schlz fund the Cuncil estimated adult run sizes were apprpriate in the cntext f this study. The Cuncil, but nt the ISAB, cnsidered the Bnneville Pwer Administratin (1984) estimated run sizes f abut 35 millin adults using a fish wheel catch-based apprach. KEY OBSERVATIONS RELATED TO THE NORTHWEST POWER PLANNING COUNCIL S AND ISAB S ESTIMATES OF HISTORIC RUN SIZES The Cuncil s cnclusin was adpted by the Cuncil in a frmal rule making prcess based n infrmatin develped by Cuncil staff, expert cntractrs and interested parties including utilities (Chapman), tribes (Schlz, et al; Walker) BPA, and numerus thers. The Cuncil s three-year effrt was guided by a technical advisry cmmittee cnvened under the Federal Advisry Cmmittee Act [Public Law ]. The Cuncil s prcesses included publicatin and review f draft issue papers and the draft final three vlume reprt. The Cuncil held public hearings in Mntana, Idah, Oregn and Washingtn. By statute, the Cuncil s decisin was required t be based n best available infrmatin. [16 US Cde 839b(h)(6(A)]. In adpting the average annual run size, the Cuncil fund its catch-based apprach t be cnservative because f several factrs and assumptins. Harvest-based estimates frm 1880 t 1928 d nt include habitat degradatin (hydrpwer develpment and peratins, lgging, mining, grazing, agriculture/irrigatin, urbanizatin/pllutin, and ther miscellaneus impacts) that had ccurred as dcumented in NPPC (1986). The ISAB did nt include this cnsideratin in estimating the histric run size. Ocean harvest in cmmercial, subsistence and sprt fisheries were nt included in estimated run size as dcumented in NPPC The ISAB did nt include this cnsideratin in estimating the histric run size. In-river catch by Indians and nn-cmmercial fisherman was nt included in the cmmercial catch estimates. The ISAB did nt include this cnsideratin in estimating the histric run size. The Cuncil s alternative apprach addressed these factrs and resulted in an estimate that fell within the 10 t 16 millin adult estimate. The ISAB relies heavily n Chapman (1986) in develping its estimate. This paper was published in the Transactins f the American Fisheries Sciety. The ther papers listed abve, althugh vluminus, were nt published in technical jurnals. The Chapman paper was cmmissined by the hydrpwer interests as a rebuttal and critique f the Cuncil estimates. Chapman (1986) was cnsidered by the Cuncil in arriving at the decisin that the average histric run size was 10 t 16 millin adults. Chapman cnsidered estimates t be ptential annual run size, nt maximum r average run size. Chapman s assumptins include: The 1915 t 1919 harvest f fall Chink was nt significantly influenced by habitat degradatin. It is pinted ut by the ISAB that Swan Falls Dam blcked 253 km f fall 2

5 Chink habitat starting in As nted abve, habitat degradatin significantly affected run sizes prir t Chapman s estimates d nt include nn-cmmercial harvest. Chapman believed Indian ppulatins had been decimated by disease and, therefre, Indian harvest was t lw t be significant. This assumptin is nt cnfirmed by any references. Chapman speculated reduced Indian fishing frm 1825 t 1850 led t high spawner returns and density dependent effects that resulted in a decline in salmn abundance. Further, after that, the ppulatin vercmpensated s the harvest levels later in the 1800s were higher than they wuld have been therwise. This assumptin needs further investigatin befre it can be relied upn. ISAB findings (paraphrased and italicized) include: Harvest prir t mid-1920s was largely driven by market cnditins in additin t abundance. Respnse: This assumptin wuld lead t a cnclusin that the lwer catch efficiencies cnsidered in the Cuncil estimates (50%, 67%) might be mre accurate in many years. Peak catches were prbably higher than recrded because sme fish were nt sld and prcessed in the lwer Clumbia River as cannery capacity was exceeded at times. This resulted in fish being transprted elsewhere fr prcessing. In additin, it is likely that sme canneries may nt have reprted all f the fish prcessed. Ocean and inland envirnmental cnditins are a big unknwn, but the ISAB states that they were prbably very gd during the late 1800s t early 1900s cmpared t present. This assumptin needs further investigatin. FURTHER OBSERVATIONS RELATED TO THE NORTHWEST POWER PLANNING COUNCIL S AND ISAB S ESTIMATES OF HISTORIC RUN SIZES Tribal cnsumptin estimates fr ISAB and Chapman d nt address the tribal use reprt by Dr. Randall Schalk, cntracted by the Cuncil fr the lsses assessment in The Cuncil apprach assumed that the histrical fishery targeted summer Chink in earlier years and was clsed during fall and spring perids. As summer Chink ppulatins declined, the fishery targeted fall Chink. The Cuncil estimated that the spring Chink run size wuld have been similar t fall-run abundance, althugh the spring runs were nt targeted r included in catch during the time perid analyzed. The ISAB has similar assumptins, except it assumed spring Chink was included in verall reprted catch which results in a lwer estimated adult run size. Figure III.1. The ISAB nly includes Chapman numbers, nt Cuncil numbers, r thse frm Schlz et al. (1985). The ISAB used Chapman s larger average fish size in punds as ppsed t the Cuncil s average. Punds per fish is a significant factr fr determining numbers f fish in the catch. Chapman used the Fraser River Basin (British Clumbia) as a cmparisn t the Clumbia Basin (n dams and much smaller basin). The Cuncil did nt find this cmparisn cmpelling. It is unclear what effect, if any, hatchery prductin had n estimates f pre-develpment run sizes. The ISAB des nt identify the basis f the significant cean harvests fr all Chink races and ch that have ccurred frm 1910 t the present. The ISAB makes this statement, but 3

6 des nt cite a reference. Als, the ISAB asserts that cean harvest was insignificant until 1910 and wuld have had a negligible effect n estimates. Again, there is n citatin fr this assertin. Chapman (1986) prvides a detailed analysis based n fishery science cncepts and apprximates ptential salmn abundance in the Basin prir t significant develpment (ISAB Ch. III). This is a significant ISAB finding. Nte that reginal debate in 1987 resulted in the Cuncil finding Chapman s estimates t lw. Chapman uses 5-year peak harvest averages versus 1-year peak used by the Cuncil. The ISAB lked at anther apprach using single 5-year perid peak harvest by species. The ISAB states, The key pint here is that the five-year perid f peak catch varies amng species, therefre the sum f the peak five-year average catches fr individual species derived frm different five-year perids greatly verestimates the average catch f all salmn that can be expected in any given five-year perid. (ISAB p. 41). The ISAB apprach des nt recgnize that the fishery shifted amng species based n declines in abundance frm verfishing individual species, seasnal races, r discrete ppulatins (NPPC 1986). The mst abundant species, based n the mre prbable harvest rates, were Chink (3.75 millin) and sckeye (2.25 millin), fllwed by ch, chum, and steelhead (apprximately 0.5 millin each). These abundance values were based n the landed weight f each species (derived frm recrds f canned, frzen, and mild-cured salmn, adjusted fr percentage f the fish carcass utilized) and average weight f each species in the late 1800s (Craig and Hacker 1940). (ISAB pgs 42-43) This statement is based n nly ne citatin, which seems inadequate. The ISAB sectin n Tribal Harvests Prir t 1800 is inadequate. A mre thrugh treatment f this tpic wuld require cnsultatin with tribes and a meaningful pprtunity fr the tribes t present their scientific and cultural evidence. The ISAB sectin n Habitat-based Estimates f Abundance needs further review befre acceptance. It shuld be nted that riginal Cuncil catch percentage rates included a 33% catch rate. This estimated rate was cnsidered t lw based n cmments by the Pacific Nrthwest Utilities Cnference Cmmittee (NPPC, Appendix C), and was subsequently eliminated. CONCLUSIONS Significantly, the ISAB did nt meaningfully cnsider wrk dne by Dr. Allan Schlz et al [Cmpilatin f Infrmatin n Salmn and Steelhead Ttal Run Size, Catch and Hydrpwer Related Lsses in the Upper Clumbia River Basin abve Bnneville Dam]. This wrk was cnsidered as ne f the cmpelling factrs by the Cuncil in adpting the 10 t 15 millin adult pre-develpment run size estimate. Dr. Schlz wrk estimated average pre-develpment run size at 12 t 16 millin adults using a lwer river catch-based apprach. The ISAB relies heavily n Chapman s wrk and des nt give much credibility t the Cuncil s wrk. The Cuncil fully cnsidered Chapman s wrk, as well as analyzes by its staff and thers, in adpting the 10 t 16 millin adult run size in the mid-1980s. 4

7 Cnsiderable fundatinal wrk fr the Cuncil s determinatin n pre-develpment run sizes is nt cntained in the 1987 Prgram including issue papers and ther dcuments. A better picture f the basis f the Cuncil s decisin can be fund by reviewing all f this infrmatin. As nted abve, the Cuncil als used an alternative apprach t reaching the decisins that predevelpment run sizes were 10 t 16 millin adults n average. This alternative apprach tk int accunt many f the ISAB cncerns, but was nt addressed by the ISAB in its reprt. Several factrs were very imprtant in estimating pre-develpment run size. These include: Catch number Punds per fish Catch percentage f ttal run size Market effects n catch such as Wrld War I demand Efficiency f the fisheries and harvest methds Number f years and what years are cnsidered in assessing peak harvest in the lwer river r any ther fishery cnsidered in the analysis I d nt believe the ISAB presents an adequate case t mdify the Cuncil s Fish and Wildlife Prgram pre-develpment run size estimates. If it is desired that the Cuncil-adpted predevelpment run size f 10 t 16 millin adults be re-evaluated, I wuld recmmend it be dne cmprehensively ver several years and include all interested svereigns and stakehlders. PRIMARY DOCUMENTS ADDRESSED IN THIS MEMORANDUM Bnneville Pwer Administratin Envirnment and Pwer Issue Backgrunder: Enhancing Our Fish & Wildlife Resurces. Prtland, OR. Chapman, D.W Salmn and Steelhead Abundance in the Clumbia River in the Nineteenth Century. Transactins f the American Fisheries Sciety 115: NPPC (Nrthwest Pwer and Cnservatin Cuncil) Cmpilatin f infrmatin n salmn and steelhead lsses in the Clumbia River Basin. Nrthwest Pwer Planning Cuncil. Prtland, OR. NPPC (Nrthwest Pwer and Cnservatin Cuncil) Clumbia River Basin Fish and Wildlife Prgram. Nrthwest Pwer Planning Cuncil. Prtland, OR. PFMC (Pacific Fishery Management Cuncil) Freshwater habitat, salmn prduced, and escapements fr natural spawning alng the Pacific cast f the U.S. Prepared by the Anadrmus Salmnid Envirnmental Task Frce f the Pacific Fishery Management Cuncil. Prtland, OR. Schlz, A. et al Cmpilatin f Infrmatin n Salmn and Steelhead Ttal Run Size, Catch and Hydrpwer Related Lsses in the Upper Clumbia River Basin abve Bnneville Dam. Upper Clumbia United Tribes Fisheries Center. Cheney, WA. 5