At a series of public meetings in recent weeks treaty tribes and other fishing interests expressed concern about a federal process they fear will conclude that Columbia River basin hatchery production of salmon and steelhead needs to be scaled back dramatically.
NOAA Fisheries Service in August released a draft environmental impact statement intended to “inform Columbia River basin hatchery operations and funding of Mitchell Act hatchery programs.” The Mitchell Act, passed by Congress in 1938, calls for the conservation of salmon and steelhead in the basin. Over the past 10 years Congress has appropriated from $11 million to $16 million annually through the act for hatchery operations.
The National Environmental Policy Act requires that an EIS be completed to evaluate the justification for that steady stream of funding and to address NOAA Fisheries actions, such as the distribution of the funding, that results in the “take” of wild stocks that are listed under the Endangered Species Act. There are 13 listed salmon and steelhead stocks in the basin. Hatchery-wild stock interactions are judged to have, in many cases, negative influences on listed wild stock.
A completed EIS will provide policy direction for NOAA Fisheries as it makes decisions regarding the distribution of Mitchell Act funds and inform its future review of individual Columbia River hatchery programs under the ESA.
The document will provide “general policy direction that we can use in the future to support these decisions,” project manager Allyson Purcell stressed during a recent presentation to the Northwest Power and Conservation Council.
The EIS will not determine how individual hatcheries will be operated or assess whether individual hatcheries comply with the ESA, Purcell said.
The draft EIS analyzes the effects of five alternatives on natural-origin fish populations, hatchery production levels, harvest, socioeconomics, environmental justice, wildlife, water quality and quantity, and human health. The draft does not have a preferred alternative.
“We’re not advocating any of these alternatives,” Purcell said. She added that NEPA requires that her agency investigate a wide range of alternatives.
NOAA offered the document for public review and has held three public meetings – in Vancouver and Kennewick, Wash., and Astoria, Ore., so far to explain the process and take public comment. Two public meetings are scheduled in Idaho:
-- Oct. 13, 2010, 5:30-7:30 p.m., Lewiston Community Center, 1424 Main St., Lewiston
-- Oct. 27, 2010, 5:30-7:30 p.m., Red Lion Hotel, 1800 Fairview Ave., Boise
The comment period closes Dec. 3. The draft EIS and other information is on the Web at:
The draft EIS analyzes and compares the direct, indirect, and cumulative effects of operating all 178 hatchery programs in the Columbia River basin under the five alternatives.
The agency anticipates that the preferred alternative will be a blend of more than one of the alternatives evaluated in the draft EIS.
"The alternatives are designed to reduce or minimize adverse effects of hatchery operations on natural-origin salmon and steelhead populations, while hatchery operators continue to pursue not only the conservation or harvest goals that currently apply to each hatchery program, but also different or additional conservation and harvest goals as identified within the alternatives," according to the summary. "NMFS anticipates that the alternative it pursues after completion of this EIS will be applicable for 10 years."
The alternatives range from a baseline or current condition that continues largely status quo to an elimination of Mitchell Act hatchery funding and production with non-Mitchell programs steered toward "intermediate performance goals" regarding hatchery influence on the spawning grounds and the influence of wild fish in hatcheries.
Two of the other alternatives focus either above or below Bonneville Dam and would aim for "stronger performance goals" – a further winnowing of hatcheries strays from the spawning grounds and strengthening of wild, native influence in hatcheries. Both envision new conservation and harvest initiatives.
Another of the alternatives aims at intermediate performance goals that would be applied to all Columbia River basin hatchery programs that affect primary and contributing salmon and steelhead populations. Application of the intermediate performance goal would, in most cases, reduce negative effects of hatchery programs on natural-origin salmon and steelhead populations.
Overall production levels under that alternative – No. 3 -- would be reduced and "conservation hatchery programs would be operated at a level determined by conservation need, with hatchery-origin production diminishing as natural-origin production increases."
The production levels analyzed range from the current level, 143 million juvenile fish, down to as few as 52 million. The number of hatchery fish harvested in all fisheries would range from 602,368 salmon and steelhead harvested in all fisheries under the no action alternative to 309,465 salmon and steelhead under the scenario that assumes no Mitchell Act funding for hatcheries (Alternative 2). The total economic impacts stemming from hatchery fish harvest ranges from $104 million in the no action alternative to $64 million under alternative two.
Purcell said this week that testimony presented thus far has been mostly critical of the range of alternatives.
Columbia River Inter-Tribal Fish Commission member tribes have weighed in at every public meeting, and plan to submit detailed comments and technical analysis by the Dec. 3 deadline. The Nez Perce, Umatilla, Warm Spring and Yakama tribes fish commercially and for ceremonial and subsistence purposes based on long-held treaty rights and other agreements.
“In reviewing the Draft Environmental Impact Statement, the tribes find it disturbing that the analysis of alternatives does not adequately reflect regional collaborative agreements, such as the 2009-2017 U.S. v. Oregon Management Agreement,” Bruce Jim said during the meeting in Astoria. Jim is chairman of the Fish and Wildlife Committee of the Confederated Tribes of the Warm Springs Reservation of Oregon.
“The status quo alternative reflects hatchery release in 2007. The analysis of the remaining alternatives all reflect reductions in hatchery releases, which is contrary to the commitments in the regional agreements,” Jim said. “In this regard, the alternatives also indicate that NOAA Fisheries did not appropriately consult with the Columbia River tribes in development of this DEIS. We are deeply dismayed by that.
“The significant cuts in hatchery programs identified in the analysis of alternatives would be detrimental to important fisheries and recovery efforts.”
“Since the early 1980s, the tribes, states and federal agencies have worked hard to implement numerous salmon restoration and rebuilding projects to improve habitat and move production upriver to assist naturally-spawning runs and help correct the past injustices,” N. Kathryn Brigham, secretary of the Board of Trustees of the Confederated Tribes of the Umatilla Indian Reservation, said during the meeting in Kennewick.
“Now, as we examine the Mitchell Act and Columbia River Basin Hatchery Operations DEIS, we are disappointed to see a series of alternatives and implementation scenarios from NOAA Fisheries that would reverse the progress discussed above, not only in the CTUIR ceded territory, but throughout the Columbia Basin,” Brigham said. “The DEIS identifies a range of alternatives and gives implementation scenarios that call for significant cuts and elimination of hatchery programs throughout the basin; programs that serve to support important treaty fisheries, help fulfill federal trust obligations, and assist in the recovery of natural origin slamoon populations.”
Tribal commenters also say the DEIS is technically flawed.
“Our technical staff is currently reviewing the document and they have noted many errors in the document and its analysis of the proposed alternatives,” Virgil Lewis Sr., chairman of the Fish, Wildlife and Law and Order Committee of the Yakama Tribal Council. “For example, we see significant errors in the harvest modeling which cause errors in both the economic impacts analysis and in the estimates of hatchery and wild fish escaping fisheries. These errors make it exceptionally difficult to judge the level of impacts on efforts to use hatcheries for conservation, mitigation efforts, and fisheries. It is exceptionally difficult to judge the level of adverse impacts that any of these alternative will have on treaty and non-treaty fisheries.”
The Northwest Sportfishing Industry Association has its science and policy team reviewing the document and also plans to submit detailed scientific and economic comments regarding the draft, according to NWSIA Executive Director Liz Hamilton.
She says the said the size of the hatchery production reductions being contemplated would be “devastating” for fishers and her industry. Hamilton used as an example an economic study that showed a revived, after years of no fishing, spring chinook fishery in Idaho reaped a total economic benefit of $90 million. The study focused on a fishery that was implemented in 2001 and targeted what was a record return. It included only 42 miles of stream.
“That was one species, one small area, one state,” Hamilton said.
Hamilton said there is a need for an alternative that focuses more on “making these hatcheries better partners,” i.e. learning to manage hatcheries in ways that reduce impacts on wild population.
Bryan Irwin faulted the document for ignoring selective fishing as an alternative for reducing hatchery-wild fish conflicts. Irwin is regional executive director for the Coastal Conservation Association.
“The feds are going to cut hatchery production to meet ESA requirements” unless the means are found to reduce negative impacts on wild fish caused by straying hatchery salmon, Irwin said. Selective fishing “is a simple solution that’s not being considered.”
Commercial fishers likewise say NOAA Fisheries needs to go back to the drawing board.
“At this point in time, it is quite clear that the Mitchell Act Draft Environmental Impact Statement was not ready for public review,” said Hobe Kytr, the nonprofit administrator for Salmon For All, a nonprofit trade association of Columbia River commercial fishermen and processors, representing the lower river non-Indian gillnet fleet. “We call for the National Marine Fisheries Service to withdraw the DEIS until it actually has engaged in the full consultation process that already should have taken place with the tribes, states, and agencies that co-manage Columbia River fisheries.
“The data and conclusions in the Mitchell Act DEIS are of no use to those constituencies who are most likely to be affected by the draconian cuts proposed for Columbia River salmonid production levels. We reject the listed range of options that call for far fewer fish for the Columbia River Basin, which threaten to leave us all with reduced and failing fisheries,” Kytr said. “Let us instead embrace hope, and work together for increased abundance, leading to genuine recovery for Columbia River salmonids wherever it is possible to achieve that worthy goal.”
“If NMFS is sincere about salmon recovery, hatchery production will be reduced only after natural spawning salmon recovery occurs, not before,” Kent Martin, a commercial fisherman, testified in Astoria. “The Mitchell Act represents congressional recognition of the mitigation obligation owed due to development of the Columbia Basin.
“Mitigation and conservation are not diametrically opposed; rather, they are two sides of the same coin. The DEIS needs to be completely rewritten to ensure that the habitat, hatchery, harvest and hydro components are brought into balance so that genuine salmon recovery can take place.” Martin said.
NOAA will consider and address all substantive comments received by Dec. 3.
All comments should be sent to:
William W. Stelle, Jr.
NMFS Northwest Region
7600 Sand Point Way NE
Seattle, WA 98115
Comments also can be submitted electronically to MitchellActEIS.email@example.com.
For more information
The draft EIS is accessible electronically through the Northwest Region website at www.nwr.noaa.gov
Should you have questions, contact Allyson Purcell at 503-736-4736 or Allyson.Purcell@noaa.gov.