Attachment 6. Public Correspondence. Public correspondence received as of July 2, 2008

Similar documents
Strategies for mitigating ecological effects of hatchery programs

Okanagan Sockeye Reintroduction

Columbia River Sturgeon in Decline. Recommendation for Harvest Reform

Past, Present and Future Activities Being Conducted in the Klamath River Basin Related to the Protection and Recovery of Fish and Their Habitat

Oregon Administrative Rules Oregon Department of Fish and Wildlife

TESTIMONY OF THE COLUMBIA RIVER TREATY TRIBES BEFORE PACIFIC FISHERIES MANAGEMENT COUNCIL April 12, 2010 Portland, OR

Backgrounder and Frequently Asked Questions

COMMENTS Draft Environmental Impact Statement McCloud Pit Hydroelectric Project (FERC No. 2106) P Applicant: Pacific Gas & Electric Company

California Steelhead: Management, Monitoring and Recovery Efforts

September 4, Update on Columbia basin Salmon and Steelhead Recovery Planning

Attachment 1. Agenda Item Summary BACKGROUND

Fish Passage from the Tidewater to the Sierras Workshop - Fish Passage at High Dams - Part 1

Segregation Weir Placement, Monitoring and Objective

Southern Oregon Coastal Cutthroat Trout

Yakima River Basin Coho Reintroduction Feasibility Study

Staff, Organizations Directly Affected (including but not limited to):

MEMORANDUM Oregon Department of Fish and Wildlife

Addressing Critical Uncertainties in the Reintroduction of Chum Salmon to Oregon Tributaries of the Columbia River. Kris Homel

Summary of HSRG Findings for Chum Populations in the Lower Columbia River and Gorge

Maintaining biodiversity in mixed-stock salmon fisheries in the Skeena watershed


107 FERC 61,282 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

THE CONFEDERATED TRIBES OF THE WARM SPRINGS RESERVATION OF OREGON

Ecosystem Management Model

ESCA. Endangered Species Conservation Act of 1969 Changed in 1973 to ESA Amended several times

Final Bull Trout Genetics Monitoring Plan for the Wallowa Falls Hydroelectric Project. (FERC No. P-308) June 2017

TAY DISTRICT SALMON FISHERIES BOARD POLICY ON SALMON STOCKING

Endangered Species Act and FERC Hydroelectric Projects. Jeff Murphy & Julie Crocker NHA New England Meeting November 16, 2010

APPENDIX D: LEWIS RIVER HATCHERY REVIEW

Upper Columbia Salmon Restoration: Breakout session: Columbia River Treaty Review Conference Castlegar, BC March 22 nd, 2013

Draft Central Valley Salmon and Steelhead Recovery Plan

Cowlitz River Fisheries and Hatchery Management Plan (FHMP)

Agenda Item E.2.g Supplemental Public Comment 2 April 2012

Attachment 2 PETITIONERS

The following language describing the performance standards was taken from the Reasonable and Prudent Alternative Table of Actions in the 2008 BIOP:

May 1, 2018 MEMORANDUM. Council Members. John Harrison, Information Officer

June 3, 2014 MEMORANDUM. Council Members. Stacy Horton, Policy Analyst, Washington. SUBJECT: Final 2012 Hatchery Fin Clip Report

10/29/ :08 AM. Mountain Whitefish, Mussels (freshwater) and Eulachon (candlefish)(smelt) The current Program makes no mention of these species

Volume I: Ecological Attributes of the San Francisco Bay-Delta Watershed

LAKE STOCKING POLICY FOR SPORT FISH DIVISION. Original Policy Authorized in February of 1998 Revised 04/07/2008

Potlatch River Drainage: Salmonid Presence: Largest lower Clearwater River tributary

The. Plain Facts. What s happening on the Deschutes River

January 4, Addresses water quality within the Council program.

Oregon Department of Fish and Wildlife: Inland Fisheries - Hatchery Management

Lewis River Hydroelectric Projects Settlement Agreement Aquatic Coordination Committee (ACC) Meeting Agenda

Burns Paiute Tribe Fisheries Department. Evaluate The Life History Of Native Salmonids Within The Malheur Subbasin Project #

Coho. Oregon Native Fish Status Report 13

California Steelhead: Management, Monitoring and Recovery Efforts

PROTECTING LAND & RESTORING RIVERS FOR SALMON & STEELHEAD

Black Sturgeon Regional Plan

Willamette River Oregon Chub

UNITED STATES OF AMERICA BEFORE THE FEDERAL REGULATORY ENERGY COMMISSION

Management Strategies for Columbia River Recreational and Commercial Fisheries: 2013 and Beyond

UPDATE: Ktunaxa Nation Council efforts to restore anadromous salmon to the Canadian Columbia River basin. Lake Roosevelt Forum April 2018

FISH PASSAGE IMPROVEMENT in California s Watersheds. Assessments & Recommendations by the Fish Passage Forum

RAFTS STOCKING POLICY

Pacific Fishery Management Council NEWS RELEASE WEST COAST SALMON SEASON DATES SET

Oregon Hatchery Research Center January 2014 David L. G. Noakes, Professor & Director

PROJECT OVERVIEW PROJECT AREA. FAHCE Fish Habitat Restoration Plan EIR

UNIT 4E. SALMON SUPPLEMENTAL INFORMATION

April 26, Chairman Rockefeller and members of the Fish and Wildlife Committee. Briefing from Mid-Columbia Regional Fish Enhancement Group (RFEG)

Hatchery Reform and our Pacific Region National Fish Hatcheries. Presented by Doug Olson

***Please Note*** April 3, Dear advisory committee members:

7.0 FISH PASSAGE PLANNING AND EVALUATION

Deschutes River Reintroduction

Case 6:17-cv MC Document 1 Filed 05/22/17 Page 1 of 12

Spring-run Chinook Salmon Reintroduction Experimental Population Designation Elif Fehm-Sullivan National Marine Fisheries Service

Funding Habitat Restoration Projects for Salmon Recovery in the Snake River Region SRFB Grant Round Version: 2/19/16

OREGON AND WASHINGTON DEPARTMENTS OF FISH AND WILDLIFE JOINT STAFF REPORT - WINTER FACT SHEET NO.

October 1, Jim Ruff, Manager, Mainstem Passage and River Operations

For next Thurs: Jackson et al Historical overfishing and the recent collapse of coastal ecosystems. Science 293:

NEVADA DEPARTMENT OF WILDLIFE STATEWIDE FISHERIES MANAGEMENT

Five Counties Salmonid Conservation Program - Fish Passage Design Workshop. February 2013

NASCO Guidelines for the Management of Salmon Fisheries

ESTIMATED RETURNS AND HARVEST OF COLUMBIA RIVER FALL CHINOOK 2000 TO BY JOHN McKERN FISH PASSAGE SOLUTIONS

Annual Report for Fiscal Year and Future Plans for the Tillamook Bay Watershed Council

Little Kern Golden Trout Status:

Perspectives of a State Director Selective fisheries as a tool in fisheries management and salmon recovery

Please be advised that the following participants were in attendance at the special conference call at 2:00pm yesterday:

2012 Bring Back the Natives Awarded Projects

Klamath Lake Bull Trout

middle deschutes progress in restoration

Shasta Dam Fish Passage Evaluation. Public Stakeholder Webinar

A G R E E M E N T. Between. Fisheries Management Authorities. from Republic of BULGARIA, ROMANIA, SERBIA AND MONTENEGRO and UKRAINE

FINAL HATCHERY AND GENETIC MANAGEMENT PLAN (HGMP)

EXHIBIT ARWA-700 TESTIMONY OF PAUL BRATOVICH

Subject: Wells Hydroelectric Project FERC Project No Bull Trout Management Plan and Incidental Take Annual Report

Oregon Coast Coastal Cutthroat Trout

WF4313/6413-Fisheries Management. Class 22

Recreational Sturgeon Commercial Shad MANAGEMENT GUIDELINES

Up Your Creek! The electronic newsletter of the Alameda Creek Alliance

STEELHEAD SURVEYS IN OMAK CREEK

January 9, Chapter Meeting Steve Leonard of Steve s Guided Adventures (

Old Document: Sandy River Coho Final HGMP 78 pages (1.18 MB) 12/10/2013 3:11:23 PM

APPENDIX 2.1 Lake Sturgeon - Mitigation and Enhancement

Eastern Brook Trout. Roadmap to

Catlow Valley Redband Trout

Executive Summary. Map 1. The Santa Clara River watershed with topography.

Salmon Five Point Approach restoring salmon in England

Columbia River Fisheries.A New Vision

Transcription:

Attachment 6 Public Correspondence Public correspondence received as of July 2, 2008

May 8, 2008 Roger Smith Oregon Department of Fish and Wildlife 3406 Cherry Avenue N.E. Salem, OR 97303 Mr. Smith and ODFW, In response to the public release and announcement of the Oregon Department of Fish and Wildlife Plan for Reintroduction of Anadromous Fish in the Upper Klamath Basin (April 17, 2008), we would like to formally register our concerns with ODFW and administrators of the reintroduction plan. While the document, A Plan for the Reintroduction of Anadromous Fish in the Upper Klamath Basin reveals that significant research, planning, and anticipation of additional planning has been done for this effort, a number of noteworthy uncertainties and concerns warrant caution when considering additional reintroduction planning and implementation. Though the Klamath River was once the third greatest salmon fishery in the nation, it currently struggles to maintain fish populations due to poor water quality, water availability, and passage barriers, among other challenges. Some of the results of these difficulties include endangered coho, struggling fall chinook populations, and a nearly non-existent spring chinook population. The plan to reintroduce anadromous fish to the Upper Klamath Basin is directed to address such challenges through alternative (unnatural) means of support. Though this plan might help restore anadromous populations to the Basin in Oregon, the potential threats and concerns may outweigh the benefits. Rivers need native populations in order to maintain healthy fisheries. The Klamath River Basin Fish Management Plan (ODFW 1997) (adopted by the ODFW Commission in 1997) suggests: ODFW generally supports the reestablishment of sustainable populations of indigenous species; however, because of existing habitat problems, loss of the native stocks, risk of disease introductions, and potential competition with remaining native redband trout, it does not appear feasible, or prudent, to attempt re-establishment of anadromous salmon or steelhead to the upper Klamath Basin in Oregon, now or in the near future. However, ODFW will support such reintroductions if and when the biological and physical questions are addressed and show that such actions are feasible and prudent. Further, ODFW would support future studies addressing that feasibility and the habitat restoration that would be conducive to successful reintroductions. The Basin Fish Management Plan reference to ODFW s support of indigenous species and reintroductions if and when the biological and physical questions are addressed suggests that the management priority is to allow native populations to demonstrate their

strength and viability prior to the department s stocking of what were once native-fishonly waters. In addition, it does not appear that the biological and physical questions and concerns have been answered, as is apparent in the lengthy list of uncertainties (p.11) in the department s plan for reintroduction. Given the passage barriers present due to PacifiCorp s Klamath Hydroelectric Project (KHP) dams, we cannot be certain of the viability of the indigenous anadromous population in the upper basin. Under the aforementioned Basin Fish Management Plan, native populations should be given ample opportunity to repopulate this section of the basin through natural passage rather than restocking, once passage barriers are removed or altered. If indigenous populations were unable to self-restore, then restocking by the department might be considered. However, there is no evidence at present to suggest that native populations are absolutely unable to repopulate considering the presence of passage barriers. Alternatives for indigenous population support are possible. Given the limited population of spring chinook and the troubled fall chinook runs in the Klamath River, a listing with the Endangered Species Act of these fish would require the basin, as a whole, to take greater care of the restoration of these fragile populations. While artificial means of reintroduction might secure numbers, it will not secure the health and presence of a native fish population. In accordance with the Basin Fish Management Plan, ODFW should reconsider whether or not their plan for reintroduction adequately meets its own terms for the necessity of hatchery reintroductions. Furthermore, politics should not dictate indigenous fish management. The suggestion that there have been significant social, political and habitat related changes in the basin that make attempting re-introduction of anadromous fish prudent at this time (p.2) in the plan for reintroduction does not provide sufficient evidence of necessity for restocking. That is, political and financial encouragement from the Bush Adminstration and others in light of the Klamath Basin Restoration Agreement (released January 15, 2008) should not dictate ODFW policy. The ODFW plan for reintroduction fits conveniently within the interests of a number of Klamath Basin Restoration Agreement (heretofore referred to as, the Klamath settlement) parties and would clearly facilitate their needs and financial interests, in spite of other stakeholder concerns. Although there are some benefits for fish in the Klamath Settlement, these benefits and their implementation remain uncertain. Such significant uncertainties there may undermine any benefits. Recent Klamath settlement negotiations have produced contentious debate over the Klamath Basin s natural resource management. Linking an ODFW plan for reintroduction to such a controversial, unsettled, and financially burdensome plan does not seem to be in the best interests of ODFW and the populations it is designed to support. In addition, the Klamath settlement does not currently include dam removal. Many Klamath Basin advocates have argued that the settlement not be wedded to dam removal, however, at present they remain linked. As a result, it is unlikely that dam removal will happen in a timely fashion, given the pace of negotiations thus far.

Therefore, ODFW s dependence on dam removal to complete Phase 1 1 of the plan for reintroduction will clearly be stalled until a removal or passage agreement is reached. There are numerous past and present dam removal processes that reinforce our concerns that the timeline for removal of the KHP dams will be convoluted and uncertain. Dam removal can require extensive approval from a number of agencies (state and local governments, etc.) and can take years to complete. Condit Dam on the White Salmon River is an excellent example of dam removal process uncertainties. Stakeholders reached agreement with PacifiCorp, Condit Dam owner, as early as 1999 but are still awaiting dam removal, scheduled for sometime in late 2008. Dam removal has been held up due to necessary agency process and guidelines (see www.whitesalmonriver.org/why_remove.php). Agency prescriptions for fishways on the KHP dams insure that fish will be passing through and eventually reintroduced to the Upper Klamath Basin, prompting ODFW s proposed changes in the policy. Given the uncertain timeline and the aforementioned fishway requirements, ODFW should not rely on the Klamath Settlement for progress in the Upper Klamath Basin or elsewhere. Significant uncertainties regarding management of reintroduction warrant considerable caution. Pages 10 and 11 in the plan for reintroduction identify a number of uncertainties in need of greater investigation. Without confirmation of a number of these uncertainties, the plan for reintroduction should not go forward. The limited availability of a genetically true indigenous spring chinook is a serious uncertainty. The introduction of hatchery races without careful consideration of the native populations may result in a complete dilution of native chinook genetics and likely cause deleterious effects to these existing stocks. Given the precarious state of native populations/numbers at present (see references p.14 of ODFW plan for reintroduction), an influx of hatchery fish will surely deplete any hopes of the ODFW mandate to reestablish sustainable populations of indigenous fish in the Klamath Basin. The list of uncertainties regarding the ODFW reintroduction plan is long and well thought out, as noted by the department. These are valuable uncertainties to consider as the department embarks on this project. Without secure answers to a number of these questions (e.g. How do we monitor interactions between resident fish currently present in Upper Klamath River and tributaries and newly re-introduced anadromous fish? ), the risks for this plan far outweigh the limited benefits (hatchery subsidies, recreational fishing opportunities, etc.). If non-native stocks are used in the ODFW reintroduction plan, and there are inadequate stock identification methods, how will ODFW determine interactions with the native anadromous population? At present, there is insufficient information available to accurately identify the various stocks considered for use by the ODFW in active intervention efforts in the reintroduction of salmonids above Upper Klamath Lake, nor to identify which stock are naturally recolonizing. There exist methods and techniques which can assist managers with the genetic identification of various stocks, life history 1 A major assumption in Phase 1 is that acceptable upstream and downstream fish passage is provided throughout the Klamath River corridor, either through passage facilities at PacifiCorp s hydroelectric dams which meet state and federal standards, or through dam removal (p.6, A Plan for the Reintroduction of Anadromous Fish in the Upper Basin).

assessment tools, and other applications. The ODFW must have adequate stock identification for any species used in reintroduction, prior to implementation. Furthermore, stock identification for the native stocks of concern, either to be used or potentially genetically diluted, should be secured prior to implementation. Use of fish that can not be tracked to determine success and/or failure, as well as their impacts on other existing native populations, reduces the ability to monitor and adapt management to be most successful. There is no security that serious fish disease does not envelop the upper basin fish populations, both native and hatchery. The ODFW plan for reintroduction acknowledges the risk of disease to native species through the introduction of [hatchery] salmon (p. 17-18). Given the potential for more potent and/or resistant pathogens, competition for spawning habitat, and greater predation from competing species, the risks for fish health are significant. Though the department suggests that disease resistant brood stocks are to be used, there are no guarantees that these stocks will remain resistant to yet introduced pathogens or infectious diseases (p.18). Should this reintroduction result in new and more resistant fish disease, it could be detrimental to the entire basin fisheries. To this end, the Assumptions and Rationale (p.20) in the ODFW reintroduction plan speak directly to the aforementioned concerns. As ODFW moves forward with this plan, I hope they will do so with great caution, acknowledging the aforementioned concerns. The risks for disease, native population loss, unnecessary hatchery subsidies, lack of adequate stock identification, and political interference are great. Thank you for your consideration, we look forward to speaking with you about this plan. Sincerely, Steve Pedery, Conservation Director Oregon Wild 5825 N. Greeley Avenue Portland, OR 97217 Scott Greacen, Executive Director epic - the Environmental Protection Information Center #122, 600 F St, Suite 3 Arcata CA 95523 Tom Wolf, Chair Oregon Council Trout Unlimited 22875 NW Chestnut St. Hillsboro, OR 97124