NOAA Fisheries’ proposed judgment on a Puget Sound Chinook harvest plan has drawn criticism from the Hatchery Scientific Review Group and a coalition of fishing groups who say it allows too much harvest of wild, protected fish and too much straying of hatchery fish onto spawning grounds.
On Dec. 29, NOAA released for public comment its proposed evaluation and determination regarding the Comprehensive Management Plan for Puget Sound Chinook: Harvest Management Component., which was jointly developed by the Washington Department of Fish and Wildlife and Puget Sound Indian tribes. NMFS’ review and approval of the plan is required under the Endangered Species Act to ensure the “take” of protected fish by Puget Sound commercial and recreational fisheries will not undermine the survival and recovery of threatened Chinook salmon, steelhead, rockfish and killer whales, all of which are listed under the ESA.
At the time, the federal agency set Jan. 28 as the deadline for receipt of public comment on its proposed determination, but this week that deadline was extended by 15 days from the date that the notice is published in the Federal Registry. Agency officials said the notice of extension is expected to be today.
The Puget Sound plan is intended to guide fisheries from 2010 through April 2015.
NOAA Fisheries’ evaluation concludes that implementation of the resource plan will result in a range of risks to individual populations, but it will not appreciably reduce the likelihood of survival and recovery of the broader Puget Sound Chinook species.
The Puget Sound Chinook were listed as a threatened species on March 24, 1999, and that status was reaffirmed on June 28, 2005. The “evolutionarily significant unit” includes all naturally spawned populations of Chinook salmon from rivers and streams flowing into northwest Washington’s Puget Sound including the Straits of Juan De Fuca from the Elwha River, eastward, including rivers and streams flowing into Hood Canal, South Sound, North Sound and the Strait of Georgia in Washington, as well as twenty-six artificial propagation programs.
In comments submitted Jan. 25, the HSRG pointed out what its members feel is an error of omission in the NOAA Fisheries evaluation.
“While the HSRG does not intend to comment on NOAA's conclusion that this RMP does not constitute jeopardy for the Puget Sound ESU, we do not believe that this document or the NOAA evaluation is consistent with one of the primary objectives of the Puget Sound Chinook harvest RMP, that is, to ensure that harvest will not impede rebuilding of natural Puget Sound Chinook populations,” the HSRG comments said. “We base this conclusion on the failure of the both documents to adequately address the impact of hatchery fish spawning naturally.
“We understand that this evaluation focused on the Harvest component of the RMP. Perhaps the fitness loss associated with hatchery strays will be addressed elsewhere. We would however like to clarify the HSRG interpretation of the science on this point, since it is one of our most fundamental conclusions.”
The U.S. Congress established the Pacific Northwest Hatchery Reform Project in 2000 with the recognition that hatcheries play a legitimate role in meeting harvest and conservation goals for salmon and steelhead, but that the hatchery system was in need of comprehensive reform. A 14-member independent scientific review panel, the HSRG, was created and it has reviewed all state, tribal and federal hatchery programs in Puget Sound and coastal Washington, and in the Columbia River basin. Those reviews resulted in principles, tools and recommendations about what sort of reforms might be implemented.
“NOAA bases its evaluation of the influence of hatchery fish on the spawning ground in large part on the Hatchery Reform Science report by the Recovery Implementation Science Team (RIST). The Evaluation selectively cites statements in the RIST report and overstates the uncertainty of the science involved,” the HSRG wrote.
“While the 2009 RIST report does state, in part, that ‘the risk [to productivity] may be unsubstantial’and cites the need for further study, in fact the conclusions in the RIST report are considerably different,” according to the HSRG comments. It quotes the RIST report as saying, among other things, that “Adequately addressing threats from hatcheries and harvest is particularly relevant for ESUs that have been historically subject to large scale hatchery production and high harvest rates, such as Lower Columbia Chinook and coho salmon, and Puget Sound Chinook salmon,” and that “…the RIST agrees with the HSRG that the risks of extensive straying by hatchery fish into natural spawning areas are real and need to be considered if the region is to achieve recovery of wild salmon.”
“Even though the HSRG has not specifically looked at Puget Sound in the same detail as we have the Columbia River, we have concluded, based on a fairly rigorous analysis of harvest, habitat and hatcheries there, that failing to control spawning of hatchery origin fish along with failing to implement proper broodstock management, will retard productivity improvement and progress toward rebuilding natural Chinook populations no matter what the current or future condition of habitat,” the HSRG wrote.
“We see no reason that the science of hatcheries, or for that matter, the habitat conditions in Puget Sound, would lead to a different conclusion when evaluating the effect of hatchery programs. Neither the co-managers' RMP, nor NOAA's evaluation of that RMP address this loss of productivity caused by hatchery programs.”
The fishing groups – the Coast Conservation Association, Puget Sound Anglers, Wild Fish Conservancy, Native Fish Society and Northwest Fish – in comments submitted Jan. 27 -- call the proposed determination a “significant step backwards in the National Marine Fisheries Service (NMFS)’s salmon recovery efforts in the Pacific Northwest.”
“The fundamental shortcoming of the plan (and NMFS’ evaluation of it) is the failure to recognize and address the threat to recovery posed by high harvest rates of wild Chinook and the negative effects of permitting excessive numbers of hatchery-produced Chinook to reach the spawning grounds, thereby limiting the productivity of wild Chinook populations,” the fishing groups say.
“Currently, hatchery-produced Chinook spawners are overwhelming natural-origin spawners in all of Hood Canal and Puget Sound south of the Snohomish River. In fact, the proposed management plan would permit harvest rates of 50-65 percent of wild Chinook and hatchery stray rates of 50-71 percent in a majority of Puget Sound rivers,” according to the fishing groups. “Harvest plays a direct role in determining the composition (hatchery vs. wild) of the fish reaching the spawning grounds and provides the primary rationale for hatchery production.”
The groups said NOAA Fisheries should take a step back.
“In light of the magnitude and implications of both documents we believe this is completely inadequate. We ask that you grant the public additional time to review and comment on these proposals. We also believe these deficiencies must be corrected and suggest that the plan be subjected to meaningful scientific scrutiny.”
After the deadline all comments received will be considered and incorporated, if appropriate, NOAA Fisheries’ Brian Gorman said.