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Promoting Better ESA Management in Puget Sound: WT Provides Input on Hatchery and Harvest Proposals
Washington Trout staff have been monitoring and reviewing state and federal proposals for improving fishing and hatchery management in Puget Sound. The Puget Sound Treaty Tribes and WDFW have prepared three “Resource Management Plans” for protecting Puget Sound chinook salmon, listed as Threatened under the Endangered Species Act since 1999. The three RMPs, one governing harvest activities and two for hatchery operations, have been submitted for approval to NOAA Fisheries, the federal agency in charge of managing listed salmon under the ESA. Both fishing and hatchery activities have been identified as factors in the decline of PS chinook. Under the 4d Rule for PS chinook, NOAA Fisheries must determine whether state/tribal plans to manage hatcheries and fisheries will adequately protect PS chinook populations and contribute to their recovery.
On July 12, a public comment period ended to solicit input on the scope of issues that should be addressed in NOAA’s Environmental Impact Statement on the two hatchery RMPs, one for Puget Sound chinook hatchery programs and the other for non-chinook salmon and steelhead programs in Puget Sound. The plans detail how each of the relevant individual hatchery programs will be operated, what its expected impacts to listed PS chinook will be, how those impacts are being or will be minimized or eliminated, or how the benefits of the hatchery program justify its risks and impacts.
In summer 2003, Washington Trout submitted substantial comments to WDFW regarding the individual hatchery plans associated with the two RMPs (See WT Report, spring 04; “An Overwhelming Body of Evidence: How Hatcheries are Jeopardizing Salmon Recovery”). In general, WT found the hatchery plans inadequate to warrant ESA authorization, and recommended that WDFW withdraw them for significant revision, and/or consider scaling back or discontinuing many of its Puget Sound hatchery programs.
WT used this public-input opportunity to try and influence the pace, direction, and scope of hatchery reform in Puget Sound. We recommended that NOAA evaluate the RMPs and individual hatchery plans to determine how they reconcile with existing and emerging hatchery-reform recommendations, including the recent findings of the Columbia River Power and Conservation Planning Council’s Independent Science Advisory Board and the Hatchery Science Review Group. We suggested that NOAA adopt firm timelines, performance standards, and enforcement mechanisms for hatchery-reform efforts. Our comments promoted several potential alternatives to the proposed RMPs, and other issues that NOAA should consider in the EIS, including: replacing or supplementing hatchery programs with habitat preservation/restoration; full implementation of the HSRG recommendations; full implementation of WDFW’s Wild Salmonid Policy; a decrease in artificial production in selected programs; establishing non-hatchery watersheds as references for analyzing impacts of hatchery production. The full text of Washington Trout’s July 12 comments are available at PSscopingcomments.shtml.
On July 1, Washington Trout submitted to NOAA Fisheries our review of its Puget Sound Chinook Harvest Resource Management Plan; Draft Environmental Impact Statement. The DEIS is required under the National Environmental Policy Act, in this case to evaluate all the potential environmental impacts of NOAA’s approval of the co-managers’ RMP for Puget Sound harvest activities.
WT’s review found the DEIS inadequate in several fundamental respects. NEPA requires a thorough and fair analysis of the potential environmental impacts of the “Proposed Action” (the RMP) as well as reasonable alternatives to the Proposed Action. The dismissals of several proposed alternatives to the RMP appear to be arbitrary, and in the discussion of alternatives that are considered, the analyses are cursory and biased. The analysis of the RMP itself fails to adequately consider or evaluate its full environmental impacts, particularly the impacts on PS chinook. The economic and environmental analyses do not include the full economic, social, and environmental costs of chinook harvest under each of the considered Alternatives. The opportunity costs associated with the RMP are not fully evaluated, and benefits to chinook harvest and chinook conservation that might reasonably be expected under one or another alternative are never considered or even identified. The DEIS fails to make a compelling extra-biological case for accepting potentially unacceptable levels of risk in the RMP.
On May 17, WT submitted to NOAA Fisheries our review of NOAA’s Proposed Evaluation and Pending Determination on a Resource Management Plan (RMP), Pursuant to the Salmon and Steelhead 4(d) Rule (PEPD). The PEPD presents NOAA’s preliminary approval under the ESA 4d Rule of the co-managers harvest RMP. If approval is finalized, the RMP would govern all fishing in Puget Sound until 2010. Fishing carried out under the terms of the RMP would be exempt from ESA enforcement.
Washington Trout does not believe NOAA has adequately justified its decision to grant take authorization to fisheries implemented in accordance with the RMP. The PEPD fails to make a compelling case for accepting the levels of risk and uncertainty associated with the RMP. It uncritically and in many cases inappropriately accepts and endorses several controversial assertions by the co-managers, without any documented support and in many cases without any discussion whatsoever. Most notably, the PEPD explicitly sanctions a “minimum fisheries regime,” a “base level” that fisheries will not drop below, even under conditions when the co-managers expect these populations to be at critically low levels of abundance.
Washington Trout respectfully recommended that NOAA Fisheries substantively revise the both PEPD and the DEIS, and request additional information and appropriate changes in the RMP from the co-managers before final NEPA or ESA determinations are developed. Click on the following links to read the full text of Washington Trout’s reviews of the DEIS and PEPD.