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Wild Salmon Recovery Initiative Challenges WDFW Puget Sound Hatcheries

Washington Trout Submits Comments on Puget Sound HGMPs



The full text of WT HGMP comments:

Comments on WDFW Chinook, Coho, and Steelhead Hatchery and Genetic Management Plans for Puget Sound


An Overwhelming Body of Evidence: How Hatcheries are Jeopardizing Salmon Recovery, an article by Washington Trout’s Ramon Vanden Brulle and Nick Gayeski in the Spring 2003 Washington Trout Report.


In 2002 and 2003, Washington Trout and the Native Fish Society filed two lawsuits in Federal Court against the Washington Department of Fish & Wildlife, alleging that WDFW chinook and coho/steelhead hatchery programs in Puget Sound were jeopardizing wild chinook recovery efforts and violating the Endangered Species Act by harming and killing listed Puget Sound chinook. The department’s releases of hatchery-bred chinook, coho and steelhead harm and kill listed wild chinook through competition for food and habitat, displacement, predation, and harmful genetic interactions. Under the specific terms of the ESA, the Puget Sound hatcheries had been unauthorized since January 2001, making each incident of harm to listed chinook illegal.


The National Marine Fisheries Service manages and regulates Puget Sound chinook recovery and conservation efforts under the ESA. NMFS requires take-authorization applications called Hatchery and Genetic Management Plans (HGMPs) for any hatchery program with the potential to impact a listed salmon or steelhead population. Washington State has 13 salmon and steelhead populations with federal ESA protection. Nearly all the HGMPs were overdue a January 2001 deadline. The department submitted HGMPs for its Puget Sound hatcheries in late 2002 and early 2003. Approximately 85 HGMPs are still outstanding.


In spring 2003, WT, NFS, and WDFW reached a negotiated settlement to the two lawsuits. The agreement established a schedule for WDFW to submit the HGMPs that are still overdue, and established a process that provides enhanced opportunity for the public to review the HGMPs and influence improvements in hatchery practices.


Chinook Hatcheries Lawsuit

In fall 2002, WT and the Native Fish Society filed a suit in federal court alleging that

18 WDFW Puget Sound chinook hatcheries violate the ESA by harming and killing federally protected wild chinook salmon, asking the court to shut down the state chinook hatcheries in Puget Sound.


WDFW’s chinook hatcheries harm listed wild chinook in a number of ways:

·        Many wild chinook are captured and killed to use their eggs and sperm for hatchery production. Some wild fish are killed intentionally; others are killed unintentionally because the department’s field staff has no reliable way to tell the difference between wild and hatchery fish.

·        When wild chinook are identified by hatchery staff and released, many subsequently die from stress or injury received during handling.

·        Hatchery chinook released into the wild compete with wild chinook for food and habitat, and in some cases actually prey on wild juveniles.

·        Stray hatchery chinook often breed with wild chinook. The hatchery salmon are genetically inferior, and pass on their faulty genes, harming the wild population as a whole.

·        At least ten of WDFW’s Puget Sound chinook hatcheries have artificial barriers at the facilities that block wild chinook from reaching important spawning and rearing habitats.


Nearly all WDFW hatcheries in Puget Sound produce chinook salmon for harvest by recreational, commercial, and tribal fishers. Only a small number of Puget Sound chinook hatcheries are managed specifically for wild-fish recovery efforts.


Background information:

WDFW Puget Sound Chinook Hatchery Program; Notice of intent to sue for violation of Endangered Species Act (60-Day Notice, submitted 6/27/02)

Complaint for Declaratory and Injunctive Relief

Washington Trout Will Sue State Hatchery Program for Breaking Environmental Law, WT Press Release 6/27/02


Coho/Steelhead Hatcheries Lawsuit

In March 2003, WT and the Native Fish Society filed suit in federal court to stop WDFW from releasing the hatchery coho and steelhead into Puget Sound streams. Hatchery coho and steelhead juveniles are killing and eating federally protected wild chinook juveniles without any special authorization, making the hatchery releases illegal under the Endangered Species Act.


Hatchery coho and steelhead juveniles are preying on wild chinook juveniles during the period when the young fish share the same freshwater, estuary, and near shore habitats. The National Marine Fisheries Service has cited what it calls “substantial” evidence that hatchery fish prey on wild salmon, and WDFW has acknowledged in written documents that predation on listed chinook from hatchery juveniles “undoubtedly occurs.”


The hatchery juveniles are released during the spring, after the young chinook have emerged from the gravel nests where they hatched from eggs laid the previous fall. The young wild salmon spend several weeks to several months in freshwater before migrating to sea. The hatchery coho and steelhead are generally larger and more aggressive than their wild counterparts, and much larger than the young chinook. Hatchery coho juveniles can eat other fish up to 46% their own size and hatchery steelhead eat fish up to 44% their own size, while wild chinook fingerlings are nearly all less than 31% the size of the hatchery fish.


The lawsuit named 30 WDFW steelhead and coho hatchery programs in Puget Sound that produce salmon and steelhead to subsidize commercial and recreational fisheries.


Background information:

WDFW Puget Sound Coho and Steelhead Programs; Notice of intent to sue for violation of Endangered Species Act (60-Day Notice, submitted 1/16/03)

Hatchery Fish Eating Wild Chinook Salmon, Groups File Suit to Stop Hatchery Releases: WT Press Release 3/21/03

Complaint for Declaratory and Injunctive Relief

Motion for Preliminary Injunction

Declaration of Sam Wright supporting Washington Trout's motion for Preliminary Injunction.  Sam Wright is a Certified Fisheries Professional with 42 years experience in Fisheries Management.  During the mid 1980’s he was responsible for game-fish hatchery programs for Washington Department of Game. In 1997, Mr. Wright served as a Special Assistant to the WDFW Director, and was the principal architect of the WDFW Wild Salmonid Policy.



In late 2002 and early 2003, WDFW submitted the Hatchery Genetic Management Plans (HGMPs) to NMFS, applications for ESA authorization for all WDFW Puget Sound hatchery programs. The HGMPs are still under federal review, and a final NMFS determination is not expected for many months. In lengthy and intense negotiations during spring 2003, WT and NFS reached a settlement agreement with WDFW that set a schedule for the submission of the approximately 85 HGMPs still outstanding, and expanded the public review of all the HGMPs.  The agreement will enhance the opportunity for federal analysts, public advocates, and individual citizens to evaluate and improve hatchery management practices in Washington.


Under the terms of the agreement, WDFW published the text of the Puget Sound HGMPs in the State Register and on its website, and solicited public review and input for the following 30 days (eventually granting a two-week extension). The department will draft and publish substantive responses to the public comments, and submit the comments and responses to NMFS for review with the HGMPs. The public-comment period for the 79 Puget Sound HGMPs ended on August 1.


Of the roughly 85 still outstanding salmon and steelhead HGMPs, half will be submitted by late 2004, and the remainder by late 2005. WDFW will also solicit public comment on these additional HGMPs before submitting the applications to NMFS for final approval, and forward comments and department responses to NMFS for review.


Background information:

Settlement Agreement (5/9/03)

Agreement Expands Public Opportunity to Comment on State Hatchery Plans: WT Press Release 5/13/03

Puget Sound Hatchery Plans Available for Review, WT Press Release 6/18/03

An Overwhelming Body of Evidence: How Hatcheries are Jeopardizing Salmon Recovery, an article by Washington Trout’s Ramon Vanden Brulle and Nick Gayeski in the Spring 2003 Washington Trout Report.


Washington Trout Comments on WDFW Puget Sound HGMPs

On August 1, a six-week public comment period ended for 79 salmon and steelhead Hatchery and Genetic Management Plans (HGMPs) developed by Washington Department of Fish and Wildlife for submission to the National Marine Fisheries Service. Washington Trout prepared and submitted comments regarding HGMPs for WDFW’s chinook, coho, and steelhead hatchery programs in Puget Sound. We found the HGMPs inadequate to warrant ESA authorization, and recommended that WDFW withdraw them for significant revision, and/or consider scaling back or discontinuing its Puget Sound hatchery program.


WDFW will consider all the comments it received, prepare responses and/or revise HGMPs accordingly, and submit the comments and responses/revisions to NMFS for review with the HGMPs. This process is intended to ensure that each HGMP is as thorough, accurate, and as biologically and legally credible as possible, make hatchery management more transparent, engage the public, and influence needed improvements in current hatchery practices.


NMFS will ultimately review the HGMPs for compliance with ESA criteria for hatchery operations, and restrictions against harming listed Puget Sound chinook. In order to win NMFS approval, the HGMPs must demonstrate that WDFW hatchery operations in Puget Sound will effectively minimize the risks and harmful impacts they impose on listed Puget Sound chinook, and/or that the benefits of the program justify the identified levels of risk and impacts.


After reviewing all the chinook HGMPs and all the coho and steelhead HGMPs, WT identified several general concerns that run throughout all or many of the documents.  These include our assessment that:

·        In general, the HGMPs fail to adequately describe clear program goals, justifications, performance standards and indicators, or adequately detailed monitoring and evaluation protocols or timetables;

·        A number of erroneous and/or unsupported assumptions run throughout the HGMPs;

·        Many of the HGMPs contain critical deficiencies and omissions;

·        There is a consistent failure to quantify, as required, the estimated take of listed Puget Sound chinook;

·        The overall size of the chinook hatchery program in Puget Sound is far too large with respect to any reasonable “acceptable levels” of competition, predation, and related genetic and ecological impacts upon indigenous wild chinook;

·        The overall size of the coho and steelhead hatchery programs in Puget Sound are far too large with respect to any reasonable “acceptable levels” of competition, predation, and ecological impacts upon indigenous wild chinook;

·        The HGMPs are often in direct conflict with critical elements of WDFW’s own Wild Salmonid Policy.


The intent of the HGMP Template and process would appear to be to evaluate several broad factors -- the justification for or benefits derived from a particular hatchery program, the current state of the affected listed population, the potential for the program to take listed species, and the specific measures proposed by the program proponents to minimize that take (including the ongoing monitoring and evaluation of those measures) -- and to weigh these factors against each other in order to determine if take authorization is warranted. In general, the responses provided by WDFW in the HGMPs that would address these factors are cursory, lacking in sufficient detail, and often inappropriate.


The HGMPs provide no reason to believe that unacceptable levels of take of listed Puget Sound chinook will not occur as a result of hatchery operations described in each. The HGMPs commit to no readily identifiable, measurable performance standards or indicators. No program-specific monitoring plans or timetables are identified or described, and no standards have been specified against which the results of monitoring could be evaluated. Nor do the HGMPs identify alternative management actions that will or might be undertaken in light of the evaluation of the results of a clear quantitative monitoring program.


The HGMPs consistently fail to discuss why it is socially, economically, or biologically necessary, advisable, or even beneficial to rear and release fish at the described programs. Measures to minimize “adverse genetic, demographic or ecological effects on listed fish” are never adequately described. Indeed, the level of these effects that WDFW would consider adequately “minimized” is never identified, nor is any effort to monitor how and when these effects will indeed be minimized described in any detail.


Washington Trout is concerned and skeptical about the size and scope of individual programs and the PS hatchery program in aggregate, about rearing and release strategies and techniques employed by WDFW, and about many of the fundamental assumptions underlying WDFW hatchery practices. Our concerns and skepticism are based on our review of the current scientific literature and a preponderance of the available evidence. The HGMPs fail to adequately address how WDFW hatchery operations are contributing to adverse ecological and genetic impacts to listed chinook through competition, displacement, and predation in juvenile life stages, and through competition and spawning interactions during adult life stages. The HGMPs consistently rely on assertions that various practices will minimize adverse effects, without any explication, citation, or other support. Data and other evidence that challenges or contradicts the assertions are rarely if ever acknowledged or addressed, even though WDFW personnel have collected and/or analyzed much of that data, and all of it is available to the department. Levels of risk are consistently ignored, discounted, or acknowledged as unknown.


WT drafted and submitted general comments that reflect our concern and skepticism, offering recommendations where appropriate, and references that support the comments and recommendations. Several sets of detailed comments on specific, representative HGMPs are included with these general comments. These specific-HGMP comments address in detail and demonstrate the repeated, often redundant failure of the HGMPs to adequately address the critical factors needed to evaluate whether the proposed hatchery programs should qualify for take authorization.


The comments address directly only some fraction of the HGMPs under review. However, with some slight variation to account for the minor idiosyncrasies of each HGMP, the individual reviews submitted demonstrate how virtually the same set of comments applies to the same evaluated sections of each HGMP. Rather than repeat essentially the same set of comments for every HGMP, we recommended to WDFW that the critical, central issues addressed in our comments could and should be applied to all or most of the HGMPs.  


Several fundamental issues must be reconciled in any application for take authorization. What level of take would be authorized? What types of benefits can the level of take be weighed against? What is the difference between current levels and any appropriate standard for those levels? How were those standards determined? How will they be met, when, and how will those efforts be monitored? WDFW fails to provide this important information, creating uncertainty that could provide the potentially inappropriate implication that the level of harm is lower than it actually is, or the level of benefit greater. The overall scope and scale of the Puget Sound hatchery program is simply too large to responsibly accommodate the level of uncertainty presented in the HGMPs.    


Given these significant shortcomings, Washington Trout found the applications apparently inadequate to justify take authorization under the criteria enumerated in the 4d Rule. We suggested that WDFW withdraw many of the applications for significant revision, if it can provide the necessary information. If the necessary information is unavailable at this time, we suggested that WDFW reconsider some of the particular programs, either discontinuing or significantly scaling them back until it can provide pertinent information adequate to warrant take authorization.


WDFW now has 75 days from August 1 to draft and publish substantive responses to all comments received during the public-comment period. The comments and responses will be posted on WDFW’s website for public review, and submitted to NMFS for review with the HGMPs. NMFS will provide another public comment period during its ongoing review of the HGMPs, public comments, and WDFW responses.


The full text of WT HGMP comments:

Comments on WDFW Chinook, Coho, and Steelhead Hatchery and Genetic Management Plans for Puget Sound (submitted 8/1/03)

WT cover letter for HGMP Comments (submitted 8/1/03)