Hi all,
The letter below is to Director Anderson from the QIN regarding budget and hatchery cuts / production and while it was written in 2009 not much has changed. I think I will try something and see if it helps folks understand the letter or rather the dance that WDF&W the QIN have had going on since the late 1990's. I will put my comments in RED so they easily distinguished from the letters author's comments. Now the formatting will be rough as in going from a PDF to word to FTC things ...... ah ....... get strange?

So here goes ............................
Phil Anderson Interim Director
Washington Department of Fish and Wildlife 600 Capitol Way N.
Olympia, WA 98501-1091 Dear Ph


Thank you for your letter dating January 27, 2009 providing us with the opportunity to review and comment on the potential impacts of the Washington Department of Fish and Wildlife (Department) budget shortfall and the proposed hatchery program reductions. Our comments pertain primarily to proposed reductions in production for facilities located within Grays Harbor

Factors similar to the four listed in your letter to help identify and rationalize specific program reductions across multiple species and geographic regions are appropriate. However, we believe that two additional considerations should also be taken into account: (1) The extent to which hatchery operations are related to mitigation agreements or requirements to offset damage to habitat or as a condition for obtaining permits or other authorization; Yes & no. The QIN is correct that the hatchery production IS mitigation for the loss of natural production but only to harvest not spawners in a stream. (2) The effect on total allowable harvest mortality of wild and hatchery production from Grays Harbor, for treaty and non-treaty fisheries both within and outside Grays Harbor, under management constraints directed at protection of comingled naturally-produced stocks. 100% correct BUT ( seen that coming didn't you? ) the QIN view is to the court agreed to escapements for Grays Harbor and it's tributaries. The simplest way I know to explain that is if tributary fails to make spawner escapement that is OK as long as the total escapement goal for spawners is acheived. Now the state side is managed down to the tributaries ( larger streams only ) level for Coho & Chinook but not Chum. So what to do? I am clueless as for the last 15 years the co managers have operated a dual management system with each taking care of their share of harvest. Sure the fish and public have suffered but what is new?

Generally, we believe that WDFW and the QIN should work collaboratively as co¬ managers to identify adjustments to hatchery production programs that are focused on improving specific program effectiveness, efficiency, scientific defensibility and reduction of risks to natural salmonid populations. Priority considerations for reducing hatchery production at facilities located within Grays Harbor:

• Programs that do not provide mutual harvest benefits to co-managers within Grays Harbor or pose ecological risks to indigenous populations of naturally produced fish should be eliminated first. For example:

• Out-of-basin transfer programs. I beleive this is directed toward the issue that WDF&W stopped producing salmon ( other than the 300K Skookumchuck Dam mitigatin ) for the Chehalis Basin and rear nearly 1,500,000 Coho for Puget Sound at the Skookumchuck Facility and thank you QIN for objecting.

•Non-local origin summer-run steelhead programs. Non-local origin lake stocking programs. Now this one is just plain BS. The Rec sports fisheries license fees pay a huge portion of WDF&W's bills and to complain about Summerrun Steelhead is rather self serving. Now the non local lake stocking are the Rainbow lake plants for heaven's sake directed primarily at families and children. That the QIN would feel this is inappropriate is a bit of a reach. My goodness the thought that tax payer dollars and citizen license fees only go to things that benefit QIN commercial fisheries defies logic.

• We recommend that WDFW discontinue the Stevens Creek summer run steelhead program in the Humptulips, Lake Aberdeen releases in the Wynoochee, and Eight Creek in the Upper Chehalis. Non-local origin summer run steelhead programs should be eliminated before any reductions for local origin winter run steelhead programs in Grays Harbor are considered. I addressed this previously. Elimination of these programs will potentially reduce fish health risks to other stocks in Grays Harbor and adjacent watersheds because IHN virus is currently being harbored in Lake Aberdeen and Humptulips steelhead. Now this one is a bit stunning as e mails identify objections from another tribe objecting to releases salmon by the QIN of smolt showing signs of IHN. Having some Rainbow we were rearing years back sequestered due to IHN and the fish showed zero signs of the disease but it was detected. I think this one is best left to the Bio's. Rearing capacity that becomes available due to reductions in the summer steelhead program should be utilized to reduce loading densities for on-station winter steelhead production to reduce stress and improve the capacity to manage future IHN virus outbreaks.

• The highest priority for production program goals for the Skookumchuck facility should be directed at providing mitigation for habitat degradation in the Upper Chehalis basin. In-basin mitigation for past and current habitat degradation in the upper Chehalis and future habitat impacts caused by potential flood control projects should receive the highest priority when considering adjustments to enhancement production for Upper Chehalis facilities. This is a bulls eye of the first order. Part of the Governor Dan Evans Salmon Enhancement package the Skookumchuck facility was built and produced salmon for the Chehalis. WDF&W ended the program transferred the 300k mitigation Coho smolt to Bingham Hatchery on the Satsop ( in violation of the mitigation agreement which was ended when Friends of the Chehalis threatened legal action several years back ) Out-of-basin transfers of fish produced in Grays Harbor facilities should have lower priority than in-basin releases. The Skookumchuck hatchery is currently utilized for incubation and rearing of 1.65 million Skykomish origin hatchery coho. Eyed eggs are transferred from Marblemount hatchery to Skookumchuck in January and subsequently transferred to South Sound and Squaxin Island net pens as juveniles in February of their release year. Consequently, the largest release group of hatchery coho raised within Grays Harbor does not contribute to Grays Harbor fisheries. Again thank you QIN as most folks in the Chehalis Basin are unaware that WDF&W continues to utilize one of the most cost effective hatcheries in the state to benefit Puget Sound fisheries. The losses to our community are simply just huge! The proposed reductions to Grays Harbor total 16% whereas a 13% reduction in total production is proposed for South Puget Sound. We note that no reductions are currently proposed for Puget Sound net pen programs that utilize hatchery capacity within Grays Harbor. Right on target folks! No BS here as the QIN pegged this one.

• We support the elimination of Satsop origin coho transfers to Upper Chehalis facilities in favor of the use of Upper Chehalis origin stock as broodstock for the Skookumchuck facility. Now this is interesting. Prior to the present Director being appointed the local communities worked collaboratively on several issues. This was one of the issues and the mitigation Coho were moved back to the upper basin to comply with the mitigation requirements after Freinds of the Chehalis threatened legal action BUT three release sites were to be utilized for this production to disperse harvest opportunity for Rec fishers over a wider area of the upper basin and utilized a LATE ( Dec / Jan ) Satsop Coho stock. Now the rub, bump in the road, a say what moment, WDF&W was supposed to have conversations with the QIN to insure it was not a issue and evidently this DID NOT happen. Bad our side as both the QIN and Chehalis Tribe concerns should ( and were supposed to be ) addressed.

• We request additional information regarding the basis for WDFW's proposal to reduce Chehalis coho production by 40% while proposing a 15% reduction for Humptulips production. The largest release group within Grays Harbor occurs from the Stevens Creek hatchery in the Humptulips River. Hatchery escapements (rack + strays) over the last decade averaged over 25,000 for on-station releases. This program consistently produces the largest hatchery surpluses within Grays Harbor. Adjusting the size of the Stevens Creek coho program was recommended by the HSRG in 2004 as one option for reducing the number of strays and reducing the annual surplus returning at the rack. The Humptulips NOR Coho ( natural origin recruits or Wild ) have not made escapement for 23 years or more and when it did it was only because of the influx of up to 4 hatchery origin Coho for every 1 NOR Coho. Right here things get weird and not just a little but way way out there. Because the Humptulips utilizes pumped river water and does not have a weir a very large percentage of returning adults simply swim right past the hatchery and do what salmon do when they return, they spawn! So for years local advocates from Tom Pentt, Jerry Paveltich, and myself and many others attempted to get a hatchery modification done to utilize Stevens Creek water to reduce straying. In fact the current Fish Program Manager and several Science Division staff tried to get funding for the modification only to have Olympia veto it.

Presently the modification is to be completed this summer ( courtesy the former Governor's job package ) and Rep. Blake's effort must be recognized. That said we have a problem on the Humptulips with NOR Coho as they have been overwhelmed for so many years by the hatchery stock that the QIN appears to accept that it will take hatchery strays to supplement the NOR Coho to make escapement. Take this year as an example. Before harvest the Humptulips NOR Coho will not make escapement. So what to do? Shut down harvest? Recs can selectively fish in river and get the impacts very low by releasing NOR ( unclipped ) Coho. Not so the QIN or NT Nets for that matter. Add to the mix the new Grays Harbor policy that dictates managing for NOR stocks and you have a recipe for something that looks like two trains meeting head on.
Blame the QIN? I think not as WDF&W knew of the problem but just ignored it, as did the QIN. Blame WDF&W? Yes / No but remember as knowledge of hatcheries limitations have grown it culminating with HSRG ( Hatchery Scientific Review Group ) and as with everything the dollars to make changes are scarce and competition for funds fierce and the Humptulips lost out. So now WE ( QIN / WDF&W / citizens ) have a problem and on this issue the blame game will get neither the tribal fisheries or non treaty fishers out of this mess. Only the QIN & WDF&W can map a path out of this mess and mess is a simplistic term to describe what exist with Humptulips NOR Coho. Well I guess another route is available and it would be a judge saying you shall.

• In additional reductions in production are necessary, impacts of adjustments to each program should be evaluated in terms of the distribution of harvest opportunity among treaty and non-treaty commercial and recreational fisheries, particularly within each Grays Harbor management area. Based on information currently available to us regarding program effectiveness and program specific contributions to Grays Harbor fisheries, we recommend the following,:

•No reductions should be made to current levels of Aberdeen net pen releases of 150,000 coho.

Proportional reductions should be larger for off-station Westport net pens and on-station Hurnptulips releases than on-station Satsop releases to help reduce hatchery stray rates and improve "sharing"of reductions in production. This one is really locked in the history of Bingham Hatchery. When Mr. Blum was Director of WDF&W he directed that Simpson Hatchery ( now renamed Bingham ) be closed due to a lower than normal survival rate of out migrating Coho smolt which appeared to take place in the South Monte reach of the river which became known as the "line of death". Well now the meeting at Monte Square with the public was ah .... loud? So a compromise was developed and part of the compromise was to move Bingham Hatchery presmolt to net pens at the Port of Grays Harbor and Westport Marina to get a larger return and provide opportunity in the Westport Marina for tourism. In addition Senator Brad Owen obtained funding for a study of the so called "line of death".

While the net pens do offer up opportunity straying is pretty much a given so it has always been a bit dicey as WDF&W did not really address it in the beginning as it should have. Now that was easy to whack em with but remember at the time the knowledge of hatchery / wild interaction as to genetices was just beginning to emerge. Around Grays Harbor things just seem to run on auto pilot which can come home to bite one's self in the rear, big time.
Lastly, when considering plans for future production from Grays Harbor facilities independently from budget-drive modifications, we suggest that we jointly explore reduction of on-station releases of Humptulips River coho and reallocation of funds to increase production of Chinook within the Chehalis system. This would be nice but I am not going to hold my breath.
We appreciate the opportunity to comment on your proposed hatchery program reductions and look forward to working with you to develop a final package.

1 comment (Add your own)

1. Prince wrote:
We must first learn then stand on our rights prectoted by the Constitution of the United States. The Declaration of Independence states, when a government becomes destructive or corrupt, we must alter or abolish it. One by one, We The People need to drag these corrupt government agents into court and sue them for violating their Oath of office and violating our rights. Don't forget the corrupt judges, they too will be disqualified and convicted of the same. All agents of government need to be held accountable for crimes against the People.

Mon, December 8, 2014 @ 12:35 PM

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