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On July 22, 2004, a public comment period ended on a Draft Environmental Impact Statement issued by the Washington Department of Fish and Wildlife for a new juvenile steelhead acclimation and rearing facility on the Skagit River. The DEIS evaluated two possible sites: (1) the confluence of Grandy Creek and the Skagit River, and (2) the existing Puget Sound Energy compound on the Baker River. WDFW is proposing to rear and release 334,000 hatchery steelhead at one of the sites, and another 200,000 at existing facilities at Barnaby Slough and the Marblemount Hatchery in the upper river.
WT Board President Bill McMillan volunteered his time to lead the Washington Trout review of the DEIS and submit substantive comments, assisted by Wild Salmon Recovery Initiative staff. The review found the DEIS does not meet the state’s own standards of environmental review. The DEIS misrepresents the nature of the project to avoid evaluating its full impacts on wild fish, arbitrarily dismisses and does not adequately consider reasonable alternatives, and fails to even demonstrate whether the proposed project will improve hatchery-steelhead harvest or increase protection for wild steelhead.
According to WDFW the new facility will not increase hatchery-steelhead releases in the Skagit Basin, but will provide a more rational and conservative distribution of hatchery-release sites in the river. It claims that the total target for steelhead releases in the Skagit is already 534,000; over 300,000 released at Marblemount, the rest distributed between Barnaby, the Baker facility, and various offsite-planting locations, including Grandy Creek. WDFW asserts the new facility will shift the majority of plants to a single site in what it calls the “lower” river, better distributing fishing opportunity and pressure throughout the river, providing more efficient brood collection, and shifting ecological impacts from hatchery releases away from the upper river, where, according to WDFW, the majority of wild steelhead spawn and rear.
Unfortunately, nearly all these assertions are unfounded, unsupported, or simply false. Most importantly, it is misleading and inaccurate to assert that the project is not intended to increase hatchery releases in the Skagit River. According to the DEIS itself, total Skagit River hatchery-steelhead releases over the last eleven years have averaged only 418,000. The target of 534,000 was met only one of those years. This includes years when brood-collection and egg-take targets were significantly exceeded, suggesting that the current program may be unable to meet the smolt target. The DEIS frankly admits that if the project is delayed or deferred, the program will continue to fall short of production goals.
Increasing the actual number of hatchery-steelhead smolts produced by the program is clearly an aim of the new proposal, but the DEIS asserts that releasing 534,000 hatchery fish into the Skagit River does not need to be evaluated, because it is an “existing condition.” But as demonstrated above, the condition does not actually exist, except in the aspirations of WDFW hatchery managers. Additionally, when WDFW increased its Skagit basin steelhead-release goals to the current target (an increase of approximately 300,000), that increase never underwent environmental review. Even if it were true that the new proposal does not represent any significant change from current levels of hatchery production, it does represent an unevaluated level of production. But in fact if the proposed action meets its goal, the increase in actual smolt releases will be real and significant, roughly 28%. It is inaccurate, unreasonable, and arbitrary to assert that no increase will occur and therefore the potential environmental impacts of releasing 534,000 steelhead smolts into the Skagit River do not warrant full review. State law in fact requires such a review.
In view of these and other shortcomings, inconsistencies, and omissions, WT believes that the DEIS does not satisfy state environmental-review standards. The refusals to consider the program’s contribution to cumulative impacts or to consider and evaluate other reasonable alternatives appear to violate state standards. By most accepted measures, Grandy Creek and Baker River are mid-river sites, not “lower” river sites as misleadingly described. Potential alternatives were dismissed based on arbitrary, unsupported determinations that they would not satisfy the purpose and need for the proposed action, but the DEIS does not demonstrate that the new proposal is any more likely to meet the purpose and need than the alternatives not considered. In fact, the DEIS does not satisfactorily demonstrate that the new proposal can achieve either of its stated goals, increasing harvest opportunity in the lower Skagit or providing increased protection for Skagit wild-steelhead stocks. Finally, the refusal to evaluate the impacts of the planned releases leaves unexamined clear indications that increases in hatchery releases since 1992 may in no small part be responsible for the recent decline in both wild and hatchery steelhead populations in the Skagit basin. WT respectfully recommended that WDFW withdraw the DEIS and reconsider its proposal.