From the Native Fish Society: Send a message to ODFW and NMFS that you want to see the Sandy River managed for Wild Salmon and Steelhead.
The deadline for your comments is July 9, 2012. Send the note below by clicking on this link:
I value healthy runs of wild salmon and steelhead and urge NMFS to reject the current Draft Hatchery and Genetic Management Plans (HGMPs) for the Sandy River and require ODFW manage the Sandy based on the best available science for the recovery of its native, wild fish. Over the past decade, dozens of organizations (including the City of Portland, PGE, Western Rivers Conservancy and The Freshwater Trust) have committed over $100 million toward Sandy River dam removal and habitat restoration for the purpose of recovering wild fish. Continuing to plant over 1 million hatchery fish in the Sandy River constitutes the single greatest threat to the recovery of its wild native fish. The ESA listing of Sandy River salmon and steelhead more than a dozen years ago led to sorting of wild and hatchery fish at the former Marmot Dam site. With the dam gone, and 50 miles of spawning habitat again available to wild fish, it is no longer feasible or desirable to trap and sort fish. Since 2007, ODFW’s continued hatchery plantings have jeopardized the tremendous public investment to recover wild fish in the Sandy Basin. The Lower Columbia River Salmon and Steelhead Recovery Plan, which includes the Sandy, sets recovery goals that rewrite abundance levels previously labeled as “likely to become endangered” to be “recovery.” The new targets to achieve recovered status are spring Chinook: 1,230, Fall Chinook: 1,031, Late Fall Chinook: 3,561, Winter Steelhead: 1,519, Coho: 5685, Chum: 1,000. These new targets range from 29% (coho) to as low as 4.5% (spring Chinook) of the modeled historical abundance and three times lower than ODFW’s targets in the Sandy River when Marmot Dam was removed in 2007. The signatories to the Marmot Dam agreement, including NFS, ODFW and NMFS, agreed to the dam removal on the promise of HATCHERY REFORM and recovery targets that now have been abandoned by the agencies. Wild fish in the Sandy River should not be victims of the death by a thousand cuts. Recovery goals should reflect that wild fish abundance is limited by the current condition of habitat and hatchery operations in the Sandy River Basin, not a new and indefensible claim of wild resilience in the face of conditions previously believed to produce extinction.
The spring Chinook draft HGMP allows for the continued release of 300,000 hatchery spring Chinook annually. Data collected by the Forest Service and ODFW in 2010 and 2011 very high stray rates, 78% and 61% respectively, greatly exceeding the 10% stray rate threshold set by ODFW in the Recovery Plan. Despite ODFW efforts to acclimate spring Chinook at the hatchery and in the Bull Run and the operation of weirs on the other tributaries, life history characteristics virtually guarantee that stray rates will remain high and wild fish will experience increased pre-spawn mortality due to handling and holding in traps. Despite Sandy River spring Chinook being derived from wild broodstock, a recent study on the Hood River indicates that domestication of wild broodstock occurs within a single generation. Sustained high stray rates on spring Chinook, currently at a very high risk for extinction, in the Sandy River constitutes a significant and immediate threat to the recovery of ESA listed spring Chinook. NMFS should not allow the continuation of this program under ODFW’s wait and see management. The summer steelhead draft HGMP allows for 75,000 South Santiam stock (Skamania origin) to be released annually in the Sandy River. These fish are out-of-basin stock, and summer steelhead are not native to the Sandy River. With the removal of the artificial barrier at Marmot Dam, these fish stray into the upper spawning tributaries and reproduce naturally. The history of the Sandy, Clackamas, Molalla, and Hood Rivers make it clear that the presence of non-native hatchery summer steelhead in spawning areas harm wild winter steelhead populations. Evidence from extensive research by ODFW scientists on the Clackamas revealed that even if hatchery summer steelhead and wild winter steelhead do not spawn together, increased competition for juveniles can negatively affect the wild run. These risks are increased by the current recycling of summer steelhead, causing an additional threat that the non-native stock will stray and survive spawning. The science is clear that, if hatchery and wild steelhead cannot be separated by time and space, plantings of hatchery fish must cease to avoid impeding recovery of wild stocks. The winter steelhead draft HGMP allows for the continued annual release of 160,000 hatchery winter steelhead in the Sandy River. Despite the hatchery winter steelhead’s wild origin, recent science indicates that these wild derived fish domesticate as soon as a single generation. Additionally, hatchery-bred fish do not have segregated run timing and thus are more likely to arrive on spawning grounds with wild fish, stray, and compete with wild steelhead for spawning gravel. Progeny of wild/hatchery salmon are less fit for survival, further degrading odds of recovery for the wild population. The current practice of recycling hatchery winter steelhead increases the threat of straying and subsequent harm to the wild winter steelhead population. Due to the high water events in the spring when winter steelhead are present spawning in the upper tributaries, the HGMPs do not explain how weirs or other artificial barriers could be used to prevent hatchery fish from harming wild fish.
The coho draft HGMP allows for the continued annual release of 500,000 hatchery coho salmon in the Sandy River. Hatchery coho are extremely voracious and will prey on other juvenile fish, including ESA listed wild steelhead and coho. The high stray rates (24%) found in tributaries downstream of the Sandy hatchery demonstrate the continued risk of operating large hatchery programs where hatchery fish stray into spawning tributaries and compete with wild fish. The draft HGMPs do not respond to the cumulative impacts of the hatchery stocks presented in a scientifically robust fashion. While suggesting that the impacts to wild fish are minor, the draft EA does not specifically quantify this risk nor does the current monitoring and evaluation program exist to determine the entirety of risks posed to wild fish in the Sandy River. Most of the impacts of the proposed HGMPs and the supposed benefits of the mitigation and monitoring programs are “uncertain” or “unknown.” Hatchery programs pose the single greatest impediment to wild fish recovery in the Sandy Basin. In order for the Sandy to fully realize its potential for wild recovery there must be higher escapement goals and a recovery program that allows existing wild stocks to reach their productive potential within the available habitat without hatchery or harvest impediments. Because operation of the hatchery under the HGMPs will continue to threaten the survival and recovery of wild fish in the Sandy River, we request that NMFS not approve the four HGMPs. Thank you for the opportunity to participate in the public comment process.