The wild vs. hatchery public debate was amplified this week with the closing of NOAA Fisheries’ comment period on a draft environmental impact statement on the use of federal funding for artificial propagation to fuel Columbia River basin fisheries.
The "Draft Environmental Impact Statement to Inform Columbia River Basin Hatchery Operations and the Funding of Mitchell Act Hatchery Programs" analyzes and compares the direct, indirect, and cumulative effects of operating all 178 basin hatchery programs -- non-Mitchell Act funded as well as Mitchell Act -- in the Columbia River basin under five alternatives.
The DEIS will be used to develop a policy direction that will 1) guide the agency's distribution of Mitchell Act hatchery funds and 2) inform its future review of individual Columbia River basin hatchery programs for compliance with the Endangered Species Act.
The alternatives analyzed in the draft EIS 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.
The draft produced an avalanche of comments, some of which say that production should be downsized because the hatchery produced fish have a negative effect on efforts to revive wild populations of salmon and steelhead that are ESA listed. Others say that hatchery production to mitigate for hydro system impacts on fish is necessary and can co-exist with wild salmon recovery, and even benefit recovery.
“While we are aware that certain hatchery practices have fallen into disrepute, and need to be reformed, we also believe strongly that the original purposes and original conditions which led to the Mitchell Act are present today, and that these purposes, of providing surrogate environments and production facilities for fisheries mitigation, need to be retained,” according to comments from Salmon for All, a nonprofit trade association of Columbia River commercial fishermen and processors. “The answer, we believe, is not in eliminating the hatchery programs but in reforming them when necessary, based on solid science, new and promising hatchery rearing methods, and in full funding of the Mitchell Act.”
“From our perspective, the mitigation obligation of the Mitchell Act has not ended,” the Salmon for All comments said of a law that calls for the conservation of fishery resources in the Columbia River basin. “Those benefits were promised ‘in perpetuity.’ If NMFS wants to cut hatchery production in the future, the agency needs to first deal with bringing the wild populations to harvestable levels, which means completing the habitat work that is long overdue. We also note that the benefits of removing hatchery fish from natural spawning areas are largely untested and hypothetical. This part of hatchery reform needs to be taken on a case-by-case basis, rather than being an over-arching policy.”
That’s not so, say fish conservation groups.
“We believe that the approach adopted by NMFS in the DEIS squanders a valuable opportunity to acquire a comprehensive understanding of the impact of hatchery programs on Columbia River salmon and steelhead,” according to the Wild Fish Conservancy, a nonprofit group dedicated to the recovery and conservation of the region’s wild-fish ecosystems. “The approach should be entirely abandoned in favor of a more comprehensive approach that is focused on recovery of ESA-listed salmonids and protection of other wild salmonid stocks.
“Hatchery programs are among the significant factors that contributed to the population declines that led to the current listings and that continue to impede the rebuilding of wild populations,” the conservancy says. “Hatchery reform that is intended, in part, to rectify the harmful impacts to wild populations of hatchery programs and practices has been slow to begin, at best. Even so, many elements of proposed hatchery reform follow guidelines that are of questionable validity where the fitness of wild populations is concerned.”
The comments say that before the final DEIS is developed a congressionally mandated review by the National Academy of Science should be called to evaluate whether “hatchery programs are the best way to mitigate for the loss and degradation of salmonid habitat caused by the construction of dams. The evaluation should include analyses whether mitigation in the Columbia River in the form in which it has been practiced a) has been successful, and b) is compatible with preservation and recovery of ESA-listed salmon and steelhead….”
Native Fish Society comments say the DEIS fails to include relevant science in designing its alternatives and therefore could increase genetic risk to wild salmonids.
“The DEIS proposes to use the untested formula developed by the HSRG for integrated hatcheries,” according to comments submitted by the Native Fish Society, which advocates for scientifically sound conservation, protection and recovery actions for native fish and their habitats. The Hatchery Scientific Review Group last year focused on reforms it felt necessary to minimize hatchery impacts on wild fish.
“Given the fact that the purpose of the HSRG stray rate formula is to create a blend of wild and hatchery fish, there is the potential to eliminate existing wild populations in the Columbia River basin, along with their biological integrity and reproductive performance, in the search to improve hatchery operations.”
Northwest Sportfishing Industry Association comments say the HSRG work is the best available science and could provide a solution for sustaining mitigation production while protecting wild fish.
“NMFS should develop a clear view of how HSRG recommendations could better inform and make enhancements to Mitchell Act hatchery programs and present it as a well defined NEPA alternative.
“It is not at all clear in this draft EIS that NMFS is supportive of a strong Mitchell Act program and wants to consider alternatives that could remove the annual funding struggle to adequately fund the federal obligations within the Mitchell Act,” the NSIA comments say. “This perceived ambivalence is deeply concerning to the Board and membership of NSIA, given the thousands of jobs that are dependent on the mitigation hatchery fish funded by the Mitchell Act, let alone the legal obligations of the Act.
“A robust and healthy Mitchell Act program would provide huge social and economic benefits to Northwest citizens and businesses, as well as our precious native salmon. We urge NMFS to look at alternatives that meet the original intentions of Congress of mitigating for federal hydro system development in the basin, and NSIA stands ready to assist NMFS in fighting to secure the resources it will take.”
Northwest RiverPartners “ applauds NMFS’ desire to develop a comprehensive hatchery policy….” However -- “While the DEIS purports to be developing a comprehensive hatchery strategy for the Basin, it is unclear exactly how the new policy will affect existing hatchery reform efforts already under way.” The RiverPartners comments cite prescriptions outlined in NOAA Fisheries’ 2008 Federal Columbia River Power System biological opinion on whether wild, listed stocks are jeopardized by the hydro system.
“Given that the FCRPS hatchery funding reforms have already undergone a programmatic consultation, and are already being implemented, and given that some hatcheries are implementing HGMPs [ESA hatchery genetic management plans] developed on the basis of best available science in coordination with NMFS and are undergoing section 7 ESA consultation, the policy ultimately derived from the Mitchell Act NEPA process must be carefully harmonized with these existing reforms, so as not to conflict with or undermine them,” according to RiverPartners, an alliance of farmers, utilities, ports and businesses that promote the economic and environmental benefits of the Columbia and Snake rivers.
RiverPartners also wonders about potential conflicts with the harvest management agreement reached between states, tribes and the federal government.
“Indeed, hatchery and harvest reforms are inherently intertwined. It is impossible to address or reform one while not impacting the other.
“For all these reasons, NWRP urges NMFS to substantially revise the DEIS and issue a FEIS that is consistent with the comments set forth above.”