What we have here is a letter ( forgive the formatting as C&P is a bear here ) addressing the failure of WDF&W to meet its Wynoochee Mitigation obligations. It is a complex subject but hopefully it is understandable!
am writing on behalf of myself, Mr. Bill Osborn, and Mr. Joe Durham regarding
the Wynoochee Mitigation Funds placed in trust by Tacoma City Light ( TCL ) in
1991 for Mitigation for the dam modifications and power generation. Currently the trust has grown with interest
to approximately $2,400,000 and the WDF&W
Commission directed that a plan to utilize the funds be completed by September
30, 2014 and too date I do not know a plan being put forth by WDF&W staff
for public review or comment for the production of 55,700 Coho smolt and 25,000 Steelhead smolt
being the case I will approach the issue from a historical perspective. WDF&W staff under the direction of former
Deputy Director Larry Peck, and later yourself, in series of problem solving
meetings with Chehalis Basin citizens that became known as the Bristol Process
developed a plan and budget for Wynoochee Mitigation. ( attachment A ) It was agreed that WDF&W would forward the agreed to plan to
the Quinault Indian Nation ( QIN ) representatives and other signatories of the
Wynoochee Mitigation Agreement for comment and input. The final document was to
be submitted to FERC for approval. If
you recall both the local community and agency staff took considerable pride in
jointly resolving the Wynoochee Mitigation and WDF&W's Skookumchuck Mitigation violations by working together.
has become apparent is the fact that WDF&W staff failed to complete any of
the task and when questions were directed to WDF&W staff by citizens
regarding the issue staff assured these citizens that progress was being made.
It was not until myself and Mr. Joe Durham both filed Public Document Request
that documents became available that showed WDF&W staff had been less than
forthright and were likely intentionally misleading citizens.
appears that WDF&W Region 6 staff under both Ron Warren and Kirt Hughes took
the following actions.
Documents provided through the PDR
process show WDF&W revised the plan not
once but twice ( attachment B ) by dropping out both the line item budget and the priority to produce the 55,700 Coho and 25,000 Steelhead smolt. When citizens questioned progress on the TCL Wynoochee
Mitigation information was withheld by Region 6 staff, primarily Mr.
Warren and Mr. Hughes.
Region 6 staff failed to properly
present the Bristol plan for the use of Mitigation funds to the QIN resulting
in the letter of 12/10/2010 from Mr. Ed Johnston representing the QIN ( attachment C ) objecting to the process
WDF&W was utilizing. Again this information was withheld from the
citizens of the Chehalis Basin until obtaining
documents through the PDR process.
It appears WDF&W staff utilized a group of individuals identified as a Technical Committee to attempt to develop
and move the Wynoochee Mitigation issue
forward. Chehalis Basin citizen participation was not sought and it appears Wynoochee Technical Committee purpose was to shield WDF&W from
the local communities scrutiny
regarding the changes made in the planning for the
use Mitigation Funds.
the previously mentioned issues in mind we strongly feel that the following
need to be incorporated in a revived Wynoochee Mitigation plan.
That the plan utilize a revised line item budget from the original Bristol Wynoochee Mitigation plan. That the
budget clearly defined the number of Steelhead
and Coho smolt to be produced, the cost associated with the rearing of the smolt, and the duration
of the production.
B. The Bristol budget had funding directed
toward a pipeline for Aberdeen Lake Hatchery that rears the mitigation
production for the Wynoochee River. There is little
disagreement as to the need for the pipeline as the health of the fish is of prime importance. This expense was originally
in the Bristol prepared budget but due
to recent efforts of Rep. Brian Blake state funds were provided for the pipeline construction. The funds made available by this outside
funding makes available a considerable
amount of funding available to address past failures by WDF&W to produce the additional 55,700 mitigation Coho smolt and 25,000 mitigation Steelhead smolt required for the TCL
Wynoochee Dam power generation
upgrade. It is our view the funds no longer needed for the pipeline should be allocated to producing the approximately
1,856,100 Steelhead and Coho smolt that
WDF&W has failed to produce since the signing of the Memorandum of Agreement ( MOA ) in 1991 as required and
prorated for the years remaining in the
Any remaining funds should be used to recycle adults from the dam to a point downstream
to enhance harvest opportunity and Friends Landing is a viable release
The practice of placing large numbers of adult Wild Coho and Native Steelhead above the dam should end and only
marked adults be placed above the dam.
As very few, if any, smolt survive out migrating through the dam the practice of placing such large numbers of Native Coho
and Native Steelhead adults above the dam has been and is a primary
reason for the Wynoochee River failing to make Wild
Coho and Wild Steelhead escapement
and a terrible waste of Native Coho & Steelhead.
E. Wynoochee Dam mitigation production should
be required, when possible, to utilize 100% native brood to reduce
any possible genetic conflicts now or
in the future.
The final issue we wish to address is what is not a acceptable use of the TCL Wynoochee Dam Mitigation Trust. It is
our understanding that the original mitigation
funds for the Wynoochee Dam have been utilized and that twice WDF&W has proposed eliminating the original
Mitigation Steelhead production. The
shortfall of these funds is the result of the former Washington Department of Game ( WDG ) utilizing a substantial amount of
the Mitigation funds to remodel the
Aberdeen Lake Hatchery. WDG Director
Weyland guaranteed to the Chehalis
Basin, that any future shortfall would be absorbed by the agency.
Simply put no part of the TCL
Wynoochee Trust should be utilized to pay for expense
of rearing the original Wynoochee Dam mitigation Steelhead smolt. That is a WDF&W responsibility outside of the purpose of the
TCL Wynoochee Trust.
is our belief that the steps we have outlined offer the best opportunity to
address the failure of WDF&W to meet the TCL Mitigation requirements that
WDF&W agreed to fulfill in 1991 as a signatory on the MOA. The TCL
Wynoochee Dam Mitigation is a obligation WDF&W has failed to fulfill for 23
years and needs to be addressed promptly and just as importantly properly with
addition as long time citizen activist we would urge WDF&W to reject its
recent policies that shroud this and many other issues in secrecy and embrace
the policies of transparency endorsed by the WDF&W Commission.
Posted on Tue, June 3, 2014
by Dave Hamilton