Mailboxes at NOAA Fisheries Service’s Northwest headquarters were stuffed full with advice, criticisms and some praise as the Dec. 3 deadline approached for comments on a draft environmental impact statement regarding salmon and steelhead hatchery operations across the Columbia River basin.
The process is intended to develop a policy direction that will 1) guide agency’s distribution of Mitchell Act hatchery funds and 2) inform NOAA Fisheries’ future review of individual Columbia River basin hatchery programs under the Endangered Species Act. NOAA Fisheries is charged with protecting listed wild stocks that many say can be negatively affected by hatchery fish.
About 400 comments were received, though 340 were postmarked from individuals in Washington state and contained the identical one-page message – “restore wild salmon and steelhead populations by scaling down hatchery programs in the Columbia River Basin.” The “citizen” letters say the “broad network of hatcheries” set up to boost fish harvests results in harm when hatchery fish compete for habitat and food and interbreed with protected wild fish.
The federal agency also received hundreds of pages of comments from state and federal agencies and Columbia Basin tribes that are directly involved in the operation of hatcheries as well as salmon recovery efforts. The Hatchery Scientific Review Group also weighed in. The scientists last year completed a review and issued a report detailing how it felt the dual goals of harvest and conserving wild salmon could be achieved. The panel was assembled at the direction of Congress and spent four years developing the report.
A flood of input was also received from fishing organizations and other interest groups, county commissions and others. (See “Hatcheries And Salmon Recovery: Fishing, Conservation, Industry Groups Comment On Draft Hatchery EIS”
NOAA Fisheries will now review the comments and decide, probably by sometime in January, how to proceed.
“We haven’t had those conversations yet,” said project manager Allyson Purcell.
The draft EIS (http://www.nwr.noaa.gov/Salmon-Harvest-Hatcheries/Hatcheries/MA-EIS.cfm) was released for public comment in August. A preferred alternative will eventually be developed and published in the final EIS by NMFS along with responses to the comments. Agency officials have said they anticipate that the preferred alternative will be a blend of more than one of the five alternatives evaluated in the draft EIS and could incorporate suggestions received during the public comment period.
While the final EIS will not make specific determinations on how individual hatchery programs should be operated, it will provide a comprehensive foundation for subsequent decision-making by NMFS under the ESA and Mitchell Act, created by Congress in 1938 “for the conservation of anadromous fishery resources in the Columbia River basin.” Annual appropriations have been used to support research, improve fish passage, install screens on water diversions, and build and operation salmon and steelhead hatcheries.
The draft EIS analyzes and compares the direct, indirect and cumulative effects of operating all 178 hatchery programs in the Columbia River basin over the range of alternatives. The Mitchell Act appropriations fund 62 of the basin’s hatchery programs that annually produce about 71 million juvenile fish.
The draft compares the effects of the five alternatives on natural-origin fish populations, hatchery production levels, harvest, socioeconomics, environmental justice, wildlife, water quality and quantity, and human health.
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 hatchery initiatives.
Another of the alternatives aims at intermediate performance goal 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 HSRG comments praised the DEIS effort but offered some suggestions.
“These actions provide the opportunity for clarity and consistency in Columbia River hatchery management and align well with the conservation of populations, sustainable harvest and treaty-trust responsibilities.” The panel said the final EIS should correct an oversight.
“In our view, the DEIS focused primarily on the number of hatchery fish produced, use of weirs, and integrated broodstock programs, but did not adequately account for the role of selective harvest in reducing the risks posed by hatchery-origin fish to natural populations.
“Currently, the alternatives considered lead to a significant reduction in harvest because of hatchery program reductions. The hatchery reductions proposed in the DEIS are necessary to ameliorate the negative interactions of hatchery fish on wild populations. However, the use of additional selective fisheries targeting hatchery fish, not considered in the current DEIS, could assist in meeting the performance standards while maintaining contemporary harvest.”
Idaho Department of Fish and Game comments say the final EIS needs to properly acknowledge agreements in place to mitigate -- via hatcheries -- for fisheries lost as a result of degraded habitat and the development of the federal Columbia-Snake hydrosystem, and the value of conservation hatcheries.
“Idaho has a sincere interest in fish conservation programs and believes those should be implemented in addition to fish production occurring under existing mitigation agreements, not in replacement of that mitigation production,” the IDFG comments say. “The range of alternatives and implementation scenarios in the final EIS should explicitly include production scenarios where production is increased to support both mitigation and conservation objectives.”
Comments from the Columbia River Inter-Tribal Fish Commission says it “believes the DEIS is fatally flawed.”
“The range of habitat conditions in the Columbia River Basin refutes the efficacy of a one-size-fits-all approach. This myopic view of the effects of hatchery fish on the genetic fitness of the populations ignores the oftentimes determinative demographic risks suffered by those populations and the positive effects that hatchery supplementation can affect on abundance, spatial structure and diversity,” according to comments submitted by CRITFC, which represents the Nez Perce, Umatilla, Warm Springs and Yakama tribes.
“Further, the DEIS applies this analysis to both listed and non-listed ESUs, without explanation. At best, the DEIS approach results in remnant population management. At worst, it may speed up the process of extirpation by limiting options to address demographic risk. The beneficial effect of increasing populations of weak stocks through hatchery supplementation may well outweigh any adverse genetic effects.”
CRITFC said there are defects in the scope and purpose of the DEIS, as well as in its technical details. The commission “further recommends that the DEIS be narrowly focused on Mitchell Act funding with a more fully informed collaborative effort, or withdrawn.”
CRITFC and separate comments submitted by the Nez Perce Tribe say NOAA Fisheries failed to properly consult the tribes during the development of the draft EIS. They also echoed Idaho’s concern about the need to respect existing mitigation agreements requiring production for harvest.
“The Tribe works regularly with NOAA Fisheries, and it is incomprehensible how your agency could have proceeded with releasing such a significant document without notice and consultation with the Nez Perce, as well as other Columbia River Tribes,” the Nez Perce comments say. “As a result, the document is riddled with errors and inaccuracies; it has needlessly caused alarm and misunderstandings and damaged trust.
“NOAA Fisheries should start over; the focus of the DEIS should be narrowed to analyzing the environmental effects of congressional appropriations for the long-standing Mitchell Act program.”
Comments submitted by the Department of Interior likewise question the validity of the draft EIS technical underpinnings, the process and the need to better consider existing mitigation agreements. The department includes the U.S. Fish and Wildlife Service, the Bureau of Reclamation and the Bureau of Indian Affairs.
“While we have substantial policy and technical concerns with the DEIS, the Department supports the development and completion of this Environmental Impact Statement (EIS) as a means to define, focus, and strengthen the Mitchell Act program, and we offer the following comments for that purpose,” the DOI comments say.
“The U.S. Fish and Wildlife Service (Service) operates hatchery programs funded under the Mitchell Act in support of the CRFMA, and the Department believes any modifications to Mitchell Act hatchery programs that reflect the provisions of the CRFMA must be agreed upon by the U.S. v. Oregon parties,” DOI comments said, referencing the 2008 Columbia River Fish Management Agreement forged by the four CRITFC tribes, the states of Idaho, Oregon and Washington and the federal government. “Further, the Department believes that the development of the DEIS would have benefited from the participation of the Federal, Tribal, and State Columbia Basin co-managers.”
The Department of Interior comments say the technical and procedural flaws need to be corrected.
“…the Department recommends that NOAA Fisheries prepare and issue a Supplemental DEIS for further public review prior to issuing the Final EIS.
“Conversely, if NOAA Fisheries no longer considers funding hatchery programs appropriate Federal mitigation, a regional discussion among the Columbia Basin co-managers needs to occur on what type of mitigation would be appropriate, what levels of mitigation would be commensurate with the impacts associated with Federal water resource development, and how to secure the funding necessary to fulfill the Federal mitigation obligation.”
Oregon Department of Fish and Wildlife comments say conversation is just starting.
“… the development of a set of final NOAA Fisheries policies to guide HGMP permitting will require additional discussion and coordination with fisheries managers and the public,” the ODFW comments said of the pursuit of National Environmental Policy Act coverage for ESA Hatchery Genetic Management Plan permitting through broad programmatic EIS. “This effort will and should take more time than that currently allotted by NOAA Fisheries for completion of the DEIS. NOAA Fisheries should pursue the more complicated programmatic EIS only after it completes the necessary dialogue on the development of a regional hatchery policy.”
The Washington Department of Fish and Wildlife also says works remains to be done.
“… we acknowledge NMPS has important work ahead in order to finalize this process and we encourage NMFS to move forward with the DEIS/NEPA process. However, the process has generated confusion about the intent and purpose of the MA DEIS/NEPA and the potential misinterpretation of alternatives 2-5.
“We encourage NMFS to initiate a process to help clarify these for the public and management entities before finalizing the EIS,” the WDFW comments say. “Recognizing how significant the preferred policy direction will be to the region for future Mitchell act funding, we also request that NMFS identify a preferred alternative and seek public comment before the final EIS is completed.”