Recommendation 52
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ADREC 2000 F&W PLAN/REC/052

May 12, 2000

Northwest Power Planning Council
851 SW Sixth Street, Suite 1100
Portland, OR 97204

Re: Recommendations to restructure the Council's Fish & Wildlife Program

Dear Council Members and staff:

Thank you for this opportunity to submit recommendations in the Council's first phase of the comprehensive revision of the Fish and Wildlife Program. These recommendations are based on the April 11 letter from Chairman Cassidy to interested parties.

PPC submits the attachments to this letter as part of its recommendations to the Council.

1) The Council should take the lead in producing a vision, with specific objectives and strategies, that will provide increasing levels of harvest in the context of the Endangered Species Act.

  Three of the four H's (hydro, habitat and hatcheries) are focused on producing more adult salmon and steelhead. However, this year's spring chinook run above Bonneville Dam provides dramatic evidence that having more salmon or steelhead isn't enough -- it doesn't assure success. Having more returning salmon right now (over 160,000 spring chinook have passed Bonneville Dam as of May 11, three times the 10-year average) has not produced progress toward any of the goals stated in the draft Federal All H paper. If the run is bigger next year, the problems will be worse, not better.   It is very evident that there is no production and harvest plan in place that provides for efficient treaty and non-treaty harvest of non-listed salmon when they return in large numbers. The mixed-stock harvest problem now looms as a major impediment to a successful Program and the Council can no longer assume that some other agency or process will take care of harvest management. The Council's Program will be incomplete unless it outlines the basic elements of success, including production and harvest. PPC therefore urges the Council to take the lead in formulating a vision that describes what success will look like. This should include the five goals from the All H paper. The attached table showing alternative strategies is intended to demonstrate that there may be alternate visions and strategies that lead to success, but the status quo is not one of them.

One important element of the Council's new Program should start with public involvement processes at the watershed level that ensure local input into habitat improvement strategies. PPC is very interested in supporting the Council and federal efforts to encourage constructive, effective habitat programs that benefit priority salmon and steelhead populations while taking into account local economies. One important element of this should be a serious look at lessons learned from model watersheds and other watershed experiences, including the rise and fall of the Yakima Watershed Council. However, there is no point in spending enormous amounts of time, energy and money on improving salmon habitat in order to produce more salmon if the year 2000 spring salmon return is what we get. This year, many of the returning spring salmon weren't eligible for harvest yet they contributed to increased harvest pressure on listed spring chinook populations and then were deemed unsuitable for spawning by state and federal managers. This is not a result worth pursuing.

 2) General scientific and policy standards. There are two basic types of salmon science, and the Council may find it useful to distinguish between conservation biology and animal husbandry. It seems that very well-qualified scientists in these two distinct disciplines have been talking passed each other for years. The Council should take the lead in ensuring that the appropriate science is applied to the appropriate policy visions, strategies and objectives. Growing fish to avoid extinction of ESA-protected populations may involve legitimately different scientific principles than growing fish for human consumption, both for tribal and non-tribal fisheries.   PPC is increasingly aware that success, whether it applies to mitigation for the impact of dams on fish, compliance with the ESA, or fulfillment of treaty and trust responsibilities, must include increasing levels of harvest. This should be considered a fundamental scientific and policy consideration.   3) One important criterion to include in subbasin planning and project selection.   Do habitat, salmon production (natural and artificial) and hydrosystem improvements lead to increased harvest and ESA compliance simultaneously? 4) Improvements in program management, evaluation and coordination. Biologically based performance standards should be considered an important element in all the H's. Setting such standards and holding the appropriate human institutions accountable should be a basis for the Program. PPC looks forward to working with the Council and staff in both phases of the Program revision. Please feel free to contact us if you have any questions or if we can be of any further assistance.

Enclosures:
1. Table of rational and irrational approaches to salmon harvest
2. Vision submitted to the Framework
3. PPC comments on the All H Paper
4. PPC's recent testimony to Senator Gorton Smith's subcommittee
5. PPC's November 12, 1999 letter to NMFS on mixed stock harvest
(not yet answered by NMFS)
 
 

Alternate Fisheries Management Approaches:
PPC April 2000

NMFS, USFWS, WA, OR, ID,
Irrational Status Quo
CRITFC
Manage for 2 kinds of fish: those considered worthy enough to spawn (wild independent viable populations and some locallyadapted hatchery fish) versus those not worthy (hatchery fishnot locally adapted) Dueling fish managers mean no unified plan: NMFS, WA and OR manage for two kinds of fish; CRITFC argues hatchery fish are worthy and opposes marking and selective harvest; both sides win and lose some court fights. 1 kind of fish (if it makes it back to spawn, it's good enough). This would require major change in ESAimplementation by NMFS
Mark fish intended for harvest Mark some hatchery fish, not others on inconsistent basis. No marking or "mass mutilation"
Natural production preferred;conservation hatcheries on test basis; meat hatcheries forterminal or selective harvest. New conservation hatcheries that can't accept many adults plus old style meathatcheries that produce fish unfit to spawn and not available for harvest. State of the art supplementationimplemented widely to boost natural production.
Selective harvest using terminalareas or live-catch-and- sort gear to allow increasing harvest ofmarked (non-listed) fish. Ocean and in-river harvest and productiondecisions made behind closed doors put unreasonable burden on public commissions to say no to harvest evenwhen runs are huge. Gill nets and other traditional gearallowed, since there is no selection to be made: all fish are harvestable.
Theoretical result: increasedharvest on hatchery fish and/or strong stocks; recovery of listed fish. Result: lose-lose since strong runs of hatchery fish can't be harvested, rate goes up on listed populations, pressure increasesto fix the habitat in order to "save the salmon" -for what? Everyone is frustrated. Theoretical result: increasedproduction and increased harvest; ESA-protected fish delisted.

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