Hi all,

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!


I 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 each year.

This 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.

What 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.

It appears that WDF&W Region 6 staff under both Ron Warren and Kirt Hughes took the following actions.

1.  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.

2.  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.

3. 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.

With the previously mentioned issues in mind we strongly feel that the following need to be incorporated in a revived Wynoochee Mitigation plan.

A. 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 MOA.

C. 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 location.

D. 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.

F. 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. 

It 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 citizen participation.In 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.


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