the osprey · eries in a coming series in the osprey journal. thank you for reading. w ashington...

Pete Soverel is a long-time member ofthe Steelhead Committee, andPresident and founder of TheConservation Angler. Co-author DaveMoskowitz is The ConservationAngler’s Executive Director.The Conservation Angler is a non-

profit organization that partnersanglers with scientists to support wildPacific salmon and steelhead conser-vation. You can learn more about TheConservation Angler at:www.theconservationangler.com

A Note from the Authors:

In Part I of this series, we describe aharvest management regime that con-siders wild steelhead stocks as aggre-gates passing a dam with little if anyregard to stock structure, the impactsof direct harvest in commercial fish-eries and indirect mortality fromencounters in the sport fishery. In PartII, we delve into the impact to wildsteelhead, particularly the wild B-runfish, that occurs when fisheries are

authorized to impact an ESA-listedwild run and the fishery is practicallycomplete before the pre-season fore-cast is updated. We also touch on theunaccounted for loss of wild fishbetween the first dam encountered andthen again after passing eight of them.

Finally we argue that the concept ofriver-specific management (first pro-posed by Dr. Willis Rich in the 1930sand re-imagined by Bill Bakke in 2017)must replace the current regime inwhich management is aimed toachieve hatchery broodstock goalswhile free-flowing natal rivers are

without natural escapement and egg-deposition goals. Part III details thedepths of the record-low 2017-2018 wildB-run steelhead return (and the thirdlowest total return of wild steelheadpast Bonneville in the period 1984 thru2017. We also detail a series of conser-vation measures necessary to conservewild steelhead in the Columbia andSnake River region during a new age ofscarcity and warming waters. Weexpect to examine steelhead hatch-eries in a coming series in The OspreyJournal. Thank you for reading.

Washington and Oregonfishery managersreleased the 2018 fore-casts for summer andfall salmon and steel-

head returns in mid-March 2018.Based on this pre-season forecast, wildsteelhead numbers are anticipated tonudge up – indicating that 2017 will bethe new historic low point for wild B-run steelhead in the Columbia and

THE OSPREYA Journal Published by the Steelhead Committee

Fly Fishers International

Dedicated to the Preservation of Wild Steelhead • Issue No. 90 MAY 2018

COLUMBIA B-RUN

— PAGE 1 —

ST HELENS MINING THREAT

— PAGE 15 —

THOMPSON RIVER

— PAGE 8 —

CLEARWATER B-RUN

— PAGE 10 —

STEELHEAD ANDSEA LIONS

— PAGE 12 —

ORCAS ANDSALMON

— PAGE 3 —

INFECTEDATLANTICS

— PAGE 17 —

Continued on Page 4

Managing Columbia River Wild Steelhead for Extinction, Part III

2017 a Historic Low for Wild B-Runs

IN THISISSUE:

by Pete Soverel and David Moskowitz— The Conservation Angler —

Inaccurate abundanceforecasts contribute to the failure to protectwild B-Run steelhead

populations.

http://www.theconservationangler.com

Fly Fishers International is a unique non-profit organization concerned with

sport fishing and fisheriesFly Fishers International (FFI) supports conser-

vation of all fish in all waters. FFI has a longstanding commitment to solving fisheries prob-lems at the grass roots. By charter and inclina-tion, FFI is organized from the bottom up; each ofits 360+ clubs, all over North America and theworld, is a unique and self-directed group. Thegrass roots focusreflects the realitythat most fisheriessolutions must comeat that local level.

Contributing EditorsPete Soverel • Bill Redman Doug Schaad • Ryan Smith

ContributorsPete Soverel • David MoskowitzJoseph Bogaard • Robert Hooton

Linwood Laughy • Conrad GowellJennifer Fairbrother • Matt Little

Patrick Meyers

Design & LayoutJim Yuskavitch

THE OSPREY

Letters To The EditorThe Osprey welcomes letters to theeditor. Submissions are also welcomebut queries in advance are preferred.

The Osprey69278 Lariat

Sisters, OR [email protected](541) 549-8914

The Osprey is a publication of FlyFishers International and is publishedthree times a year in January, May andSeptember. All materials are copyright-ed and require permission prior toreprinting or other use.

The Osprey © 2018ISSN 2334-4075

THE OSPREY IS PRINTED ON RECYCLED PAPERUSING SOY INK

ChairRyan Smith

EditorJim Yuskavitch

FROM THE PERCH — A SPECIAL MESSAGE

2 MAY 2018 THE OSPREY • ISSUE NO. 90

by Pete Soverel, Steelhead Committee

Big News for The Osprey and Its Loyal Supporters

Visit The Osprey on the Web at:www.ospreysteelhead.org

The Osprey Blog:www.ospreysteelheadnews.blogspot.com

Fly Fishers Internationalwww.flyfishersinternational.org

I’mpleased to inform our loyal readership of wild fish advocates that thereare dramatic changes for The Osprey commencing with the September2018 issue. Since its inception in 1986, The Osprey has been produced andpublished by the Steelhead Committee of Fly Fishers International (for-merly the Federation of Fly Fishers). Several prominent conservation

organizations — The Conservation Angler, Steelhead Society of BritishColumbia, World Salmon Forum, Wild Steelhead Coalition, Skeena Wild, WildSteelhead Coalition — have joined in partnership with Fly Fishers Internationalto expand the content, reach and impact of The Osprey on Pacific salmon andsteelhead conservation. In addition to expanded content, the new Osprey will beprinted on higher quality paper. It will remain black and white.The partners have formed an editorial committee that will mold the content of

The Osprey and assist the editor in securing authors. A number of prominentbiologists have agreed to serve as scientific advisors — Jack Stanford, RickWilliams, Jim Lichatowich, Bill Bakke and Bill McMillan. We know where thebodies are buried and we are going to be digging them up. The editorial committee has selected three priority issues –—hatchery-wild

fish interactions; steelhead persistence & climate change and; steelhead manage-ment regimes (harvest models, preserving/expanding angling opportunity,recovery following dam removal). Each of these issues will be explored in eachof the next six to nine issues of The Osprey. Other articles in areas of interest willfill out each issue. I have been involved with The Osprey since its inception as a contributor, chair-

man of the Steelhead Committee for 10 years, and member of the editorial boardfor the past 30 years. I am very excited about The Osprey’s future and its role asthe authoritative source for steelhead conservation. We don’t have much time tosave steelhead from extinction. For example, last year only 350 wild, B-run steel-head made it back to Idaho’s 15,000 miles of habitat. We appreciate sincerely your many years of support for The Osprey and hope

you will continue in the future. The expanded publication needs your financialsupport. Please consider a gift to The Osprey: The International Journal ofSteelhead Conservation. You will find our contribution form on page 19.

http://www.jimyuskavitch.com

mailto:[email protected]

http://www.ospreysteelhead.org/

http://ospreysteelheadnews.blogspot.com/

http://flyfishersinternational.org

This issue’s guest columnist is JosephBogaard, Executive Director of SaveOur Wild Salmon Coalition, which hasbeen advocating for wild Columbia andSnake river wild salmon and steelheadfor decades. Learn more about theirwork at: www.wildsalmon.org

Southern Resident KillerWhales have been plying thecoastal waters of the PacificNorthwest for a very longtime. Genetic research tells

us this salmon-eating community ofwhales diverged from the other localpopulation of orcas — the mammal-eat-ing Transients — a few hundred thou-sand years ago. Until recently, a dietfocused almost exclusively on Chinooksalmon appears to have been a verysuccessful strategy. Abundant, large,and fatty, Chinook have been swim-ming through these same waters for atleast as long.But all that’s changed in the last few

decades. Habitat destruction driven byshort-term thinking and an under-appreciation of the value and benefitsof intact, functional, resilient ecosys-tems has caused our region’s mosticonic native fish to plummet towardextinction. Across the west coast, two-dozen salmon and steelhead popula-tions are listed under the EndangeredSpecies Act, with thirteen in theColumbia River Basin alone.And the Southern Resident orcas that

rely on them are suffering as a result.Today, these beloved whales are at a30-year population low, and just 76individual whales remain today.Without big changes in Northwest nat-ural resource policies, many expertsfear we will lose this unique andbeloved community of whales forever.Research in just the last five years

has both shed new light on their natur-al history and provided insight into anumber of the specific challenges they

face. Fecal sample analyses, for exam-ple, has determined that the SouthernResidents rely on Chinook salmon forroughly 80 percent of their diet.Satellite tracking data confirms that ina typical year they spend about half oftheir time in the Salish Sea, hunting forsalmon bound mainly for the FraserRiver in British Columbia, but otherlesser rivers as well. From fall tospring, these whales are often foundcruising the West Coast, searching forsalmon there. They show a particular

affinity for the Washington coast andmouth of the Columbia River on theOregon-Washington border, not only inwinter and spring, but also opportunis-tically at other times of the yeardepending on what fish are present.Orca reproductive success is strong-

ly tied to Chinook abundance.Hormone analyses by the Universityof Washington’s renowned conserva-tion biologist Sam Wasser has foundthat these whales are often highly“nutritionally stressed” (aka starving)and that more than 60 percent of theirpre-term calves spontaneously abort.They have not produced a calf since2015.

Faced with an already-endangeredpopulation suffering new losses,NOAA in 2015 identified the SouthernResidents as among eight endangeredspecies nationally most likely to go

extinction without significant immedi-ate action.

The National Oceanic andAtmospheric Administration (NOAA),however, has long been part of theproblem. In its 2008 orca recoveryplan, NOAA acknowledges orcas’ his-toric reliance on Columbia BasinChinook and describes its populationdeclines as “[p]erhaps the single great-est change in food availability for resi-dent killer whales since the late1800s...” Despite publicly acknowledg-ing this fact a decade ago, NOAA hasapproved inadequate, illegal salmonplans for the Columbia and Snakerivers dating back to the 1990s. Theirclaim: hatchery production todaymakes up for the depressed wildChinook numbers and no big policychanges — such as lower Snake Riverdam removal — are needed.Unfortunately for NOAA, the law, the

science and the real world all tell avery different story. Leveraging thestring of recent deaths (eight individ-ual whales have died in just the lasttwo years) and accumulating informa-tion, orca and salmon advocates havejoined forces of behalf of both theseiconic and imperiled species to pressNorthwest policymakers to act. At atime of tremendous urgency whenevery individual whale matters, thereare some signs of hope. Many electedofficials now acknowledge the crisis,and signs of leadership are starting toemerge.In March, Washington’s Democratic

Governor Jay Inslee established a newEmergency Orca Task Force. This newbody, made up of diverse experts andstakeholders from across the state,convened for the first time on May 12018 in Olympia. They are tasked withidentifying and recommending nolater than this fall legislative and otheractions that the state can and should

THE OSPREY • ISSUE NO. 90 MAY 2018 3

Endangered Southern Resident OrcasReshape Debate over Salmon Restoration

by Joseph Bogaard

— Save Our Wild Salmon —

GUEST’S CORNER

Continued on page 19

Southern residentorcas rely on Chinookfor 80 percent of theirdiet, and reproductivesuccess is tied to

Chinook abundance.

http://www.wildsalmon.org

Snake Basins.The 2018 forecast calls for 48,200 wildsteelhead to pass Bonneville Dam. Thisexceeds the 32,625 wild steelhead thatpassed Bonneville in 2017; howeverthere is little cause for celebration asthe 2018 forecast is not even 50% ofthe current ten-year average of101,300 wild steelhead.

Wild B-run steelhead crossingBonneville Dam are predicted to total3,400 fish, a forecast three times the2017 forecast of 1,100 wild B-run fish,though it is only 33% of the current

ten-year average for wild B-runs(10,384 fish in the 2007-2016 period).The challenge of predicting the annu-

al return of wild steelhead to theColumbia and Snake Basin is daunting,yet it is the annual abundance of wildsteelhead – particularly wild B-runsteelhead – that remains one of the

principle drivers of harvest manage-ment and regulation in the Columbiaand Snake Rivers. Managers try toestimate wild abundance for a specieswith a wonderfully complex life histo-ry, a broad and diverse historic spawn-ing region, and a spawning timing thatmakes them difficult to track andobserve while in the act of reproduc-ing.The inability to accurately forecast

their abundance (See Table 2, below)

nor make mid-season run updates inthe midst of authorized and on-goingcommercial and sport fishing seasonsthat are based on the pre-season fore-casts, is contributing to the failure to

protect and rebuild wild steelhead pop-ulations in the Columbia and SnakeRiver, and indeed, driving these fish toextinction. The fishery managers know this is

the case, as clearly stated by Idaho in2017: “Abundance and productivitydata are of primary importance in ESA

assessments of Idaho’s steelhead popu-lations. All of Idaho’s populations areconsidered to have a high risk ofextinction within 100 years (probabili-ty >25%) based on the estimated abun-dances and productivities.” Despite the continuing conservation

concerns about wild steelhead theywill not receive the benefit of anyrules reducing the encounter rates inthe sport or tribal fishery. One wouldthink that the low steelhead forecastand a conservation-limited Chinookfishery would translate into some “sav-ings” for wild salmon and steelheadproduced by lower bag limits andfewer encounters – but you would bewrong. One year after an historic low,fishery managers have not proposedany conservation measures like thetime and area closures they relied onto protect the historic low wild B-runin 2017.

In 1962, nearly 43,200 wild B-runsteelhead were counted as theycrossed a small, long gone dam justthree miles upstream from theClearwater River’s confluence withthe Snake River in Lewiston. Yet the2017-2018 run will total fewer than 500fish to the Clearwater and itsundammed tributaries, a decline fromthe early 1960s of 99%. Fishery managers have been count-

ing fish at Bonneville Dam since the1940s, and their official count of wildB-run fish over Bonneville Dam in2017 is 751 from July throughNovember. As of early February, 362of those fish crossed Lower GraniteDam. Past research demonstrates thatapproximately 95% of the total runover Lower Granite Dam is normallycomplete by December 31, meaningthat Idaho can expect a total 2017-18wild B-run steelhead run over LowerGranite of likely fewer than 500 wildfish. The majority of that group of wildB-run steelhead will migrate up theClearwater (about two-thirds) whileabout one-third of the wild B-run fishthat cross Lower Granite will migrateto the Salmon River. As a result, wecan fairly reliably estimate that thetotal 2017-2018 Clearwater River wildB-run steelhead will be in the neigh-borhood of fewer than 300 fish, andpossibly 200 wild B-run steelhead tothe Salmon River.

Pause for a moment to reflect on


B-Run SteelheadContinued from page 1

Continued on next page

Table 1. 2018 Forecast and 2017 Actual Runs of wild A-run and B-run Steelhead toBonneville Dam

Table 2: Pre-season Forecasts of wild B-run steelhead to Bonneville Dam with ActualReturns as percent of forecast

those numbers.These few prized wild B-run steel-

head have been joined by a modestnumber of A-run wild steelhead (steel-head smaller than 30 inches) and amodest number of hatchery fish thatreturned in numbers large enough tocalm the nerves of hatchery managerswho were initially worried that thesteelhead return would not meet hatch-ery broodstock needs. Despite easingthe hatchery manager’s concerns,there do not appear to be any goals forwild steelhead escapement nor wildegg deposition objectives for the indi-vidual rivers to which the wild steel-head will return. Idaho has shown con-cern about this issue in the past,though there is little evidence they areworking to achieve them:“Comparative escapement and resul-

tant juvenile production data for Idahostreams should be presented toColumbia River Compact agencies toinform them of the inadequacy ofSnake River and Columbia Rivergroup-B escapement objectives. Thereis a critical need to modify ColumbiaRiver Compact group-B wild steelheadescapement objectives. The escape-ment objective of 13,300 at BonnevilleDam and 10,000 at Lower Granite Damresults in extremely low seeding levelsfor Idaho’s group-B steelhead produc-tion streams.” The gauntlet wild fish face is wors-

ened by the sport fisheriesWashington, Oregon and Idaho permit-ted and then opened further to a three-hatchery fish daily limit once itbecame clear that the hatchery fishwould return in large enough numbersthat hatchery managers would meettheir egg-take goals. However sportfishing effort results in higher encoun-ters with wild fish even though theyare outnumbered by their hatcherycousins.Data in Oregon and Idaho shows that

steelhead anglers hoping to catch onlyhatchery keepers will typicallyencounter twice as many wild fish ashatchery fish, even though there arefewer wild fish in the rivers. Wildsteelhead are simply more aggressiveand better biters than the hatcheryproduct.What happens when an angler hooks

those wild fish? Approximately 5 to 10

percent will not survive being caughtand released. And when many wildfish will be caught, even though thereare fewer of them, you can assumethat a percentage of the wild B-runsteelhead will not survive theencounter. This means that even fewerwild B-run steelhead will survive tospawn in the Clearwater and SalmonRivers in 2018. And while someangling encounters may not be lethal,research shows that some of the wildsteelhead caught in this fishery may beless successful in their efforts tospawn, further reducing the overallwild fish productivity.

The Conservation Angler believesthat Washington, Oregon and Idaho’swinter and spring steelhead fisheriesshould have been curtailed. There isgood reason for concern.The 2017-2018 B-run index (hatchery

and wild B-runs) will be 50% lowerthan the four lowest previous indexcounts in the 1984-2017 period (1994,1995, 1999 and 2013). The 2017-2018wild B-run return over Lower GraniteDam will very likely be less than 50%of the previous low count (914 wild B-run steelhead in 1999-2000) in the 1984-2017 periods. The return of wild B-runsteelhead to Bonneville Dam will be41% of the previous low (1,847 wild B-run fish) in 1995. These comparisonsare drawn from data in the February20, 2018 Joint Staff Report: StockStatus and Fisheries for SpringChinook, Summer Chinook, Sockeye,Steelhead and Other Species (ODFWand WDFW). The bottom line numbersshow that likely fewer than 500 wild B-run steelhead will return past LowerGranite Dam for the 2017-18 run-year,and anglers will likely reduce the num-ber of wild steelhead on the spawninggrounds since the three states allowedcontinued fishing on steelhead all theway through April 31. Adding urgency to the concern over

the low steelhead return is a mid-2017NOAA finding that ocean survival willremain very poor for at least two moreyears.

Faced with these numbers, statemanagers raised several issues asrational for not taking action. Sinceeach point raises further concerns,The Conservation Angler addressedindividually.1. Angler Effort: State managers stat-ed there was “anecdotal” evidence of

low angler effort. Even if true, thatdoes not necessarily equate to lowencounter rates. Avid and skilled steel-head anglers are likely to fish evenwith low abundance because theyknow how to catch steelhead and theyknow where to find them. The bestanglers will still pursue steelheadwhile the low counts will only deter thecasual angler. It would be helpful ifthere is a formula to calculate anglereffort based on steelhead run-size.2. Encounter Rate: The encounter ratefor wild steelhead is likely higher thanthe encounter rate for the more abun-dant hatchery fish, which means thatanglers encountering steelhead willlikely encounter more wild steelheadthan hatchery steelhead, though theratio of hatchery-to wild steelhead isskewed the other way.3. Habitat Partitioning: State managersnoted evidence that wild and hatcherysteelhead are quite partitioned withinthe available habitat. While this is pos-sible given the attraction of hatcheryfish to hatchery facilities, it is not uni-form across all rivers. Indeed, inNOAA’s 2015 Five Year Review of ESA-listed salmon and steelhead popula-tions, the number of hatchery fishspawning with wild steelhead in Idahois among the major risk factors wildSnake River steelhead face in multiplesub-basins. Why did fishery managersnote this issue as a positive factorwhen partitioning among wild andhatchery steelhead was described as amajor risk factor by NOAA?4. Status of the 2017-2018 run: Statemanagers still expected wild andhatchery steelhead to cross overLower Granite Dam before the runyear ends in June. However, accord-ing to the Fish Passage Center (FPC),ninety-five percent of the wild B-runsteelhead pass Lower Granite Dam byyear-end (December 31, 2017). Giventhe reported visual count to date, theremaining five percent yet to pass intothe rivers above Lower Granite Damwill not measurably increase the finalyear-end count - even reaching 500wild B-run steelhead for the 2017-2018run year would be a pleasant surprise.5. Size, Fitness, Fecundity: Finally,state managers believe that many ofthe wild A-run steelhead passingLower Granite Dam were actually wildB-run steelhead that failed to grow


Continued from previous page


beyond the 78 cm length that wouldvisually identify them as wild B-runfish. This was attributed to poor oceanconditions and disruptions to themarine food web. If this is true, it isactually an even more critical uncer-tainty and risk factor facing the 2017-2018 wild B-run fish. The smaller “B-minus” B-run steelhead will likelyexhibit less fitness and be unable toselect and spawn in the best B-runspawning areas where the depth, cur-rent and cobble size provide conditionsthat contribute to wild B-run life histo-ry diversity. Lastly and significantly,the smaller fish will have fewer eggsso even if they spawn successfully,there will be significantly less eggdeposition per redd than if this year’swild B-run steelhead were products ofbetter marine conditions (a wish) andreturned in greater abundance (a fact).This egg deposition deficit will bemagnified by the loss of even a fewwild B-run steelhead in Idaho’s 2018steelhead fishery.

An additional point TCA raised isequity. Snake River basin anglers areat the end of the line. There is a litanyof fishery encounters that reduce thenumber of steelhead that pass into theSnake River. TCA has consistentlycalled for angling closures and restric-tions in all three states in the Columbiabasin during the 2017 - 2018 fishingseasons to protect wild steelhead.

Proposed Measures to Conserve WildSteelhead Throughout the Columbiaand Snake Basins

First and foremost, federal, state,and tribal management agencies mustprioritize and manage for wild escape-ment – not hatchery needs or harvestgoals. Current management does notvalue wild fish.

Second, the frequently unreliableforecast methodology insures excessmortality for wild stocks. For example,the average forecast for Snake B-runwild steelhead exceeds actual by anaverage of 50%. This egregiously opti-mistic forecast guarantees excessmortality for wild stocks, especially inthe absence of meaningful in-seasonadjustments to fisheries plans.Third, agencies must develop tempo-

ral structure for all wild stocks and

then use those models to moderate in-season fisheries as is done in BristolBay. These models can easily be con-structed with the abundance of pas-sage data at the variousColumbia/Snake dams. Such anapproach last year would have quicklyidentified the dire condition of wildSnake B-run steelhead and forced con-servation measures to protect them.In short, the current methods used to

develop annual fishery plans are bank-rupt and are leading inevitably toextinction of wild stocks, even if theymeet ESA limits. As agencies move toimplement the long over-due changesoutlined above, they must take a num-ber of short-term conservation mea-sures to prevent near-term extinctionsin the Columbian and Snake basin fish-eries:

I. Conservation Measures for 2018Columbia and Snake Basin Fisheries

1. Identify Cold Water Refugia areas(119 areas have been identified, 13 arehigh priorities).2. Create 13 Sanctuaries where fishingis prohibited to protect migratingsteelhead.3. Require that wild fish must bereleased and remain in the water whenlanded for all shore fisheries.4. Barbless hooks in all fisheries tofacilitate safe fish release and mini-mize hook injuries.5. Anglers to rack rods after limiting(rescind “party boat rule) to reduceencounter rates.6. Suspend multi-species bag limits toreduce encounter rates.7. Protect established spawning areasduring spawning seasons in all areas toreduce encounter rate and increaseproductivity of wild fish escaping tospawn in natal streams.8. Eliminate the use of bait in all fish-eries where wild salmon or steelheadare required to be released to reduceC&R mortality and reduce the overallencounter rate.9. Establish statistically valid and real-time observer programs for sport fish-ing so that estimates of e n c o u n t e rrate and mortality rates can be confi-dently used in models.10. Require use of recovery boxes insport fleet boats to reduce release mor-tality for fish requiring release.11. Manage sport fishing seasons so

that real-time catch data can be used toopen or close fishing to allow p a s -sage of wild fish through fisheries andto reach spawning grounds.12. Eliminate the use of side-planersanywhere angling is allowed fromfloating devices to reduce encounterrates and instill the hunting conceptsof “fair chase” into angling.

II. Conservation Measures for 2018Columbia and Snake BasinCommercial and Treaty Fisheries

The following conservation measuresfor use by the non-treaty and treatycommercial fisheries will conservewild salmon and steelhead, includingclosures, if wild fish escapement is atrisk of not being met in upstream trib-utaries.

1. Develop temporal structure for allColumbia/Snake wild stocks to be usedto construct fisheries that will facili-tate recovery of the ESA-listed stocksand prevent disruption of healthy, non-listed stocks.2. All commercial fisheries will occuronly on alternating days so catch datais analyzed.3. All fishing shall be during daylighthours4. Fishing only permitted with a statis-tically valid observer, monitoring andcreel program5. No fishing permitted in any areathat is used as thermal refugia bysteelhead or salmon6. Soak time for drift gill nets shall belimited to 20 minutes7. Use of most selective gear andrecovery boxes will be required.

III. Tribal, State and FederalCoordination Needed for Wild B-RunSteelhead Conservation

In addition, TCA also recommendsdevelopment of a multi-party manage-ment program to recover wild B-runsteelhead. Closing the fisheries thatencounter wild B-run steelhead willnot, by themselves, recover the wild B-run steelhead in the Snake River.Oregon must join with Washington andIdaho and the Treaty Tribes to considerand adopt an interstate recovery planthat addresses biological recoveryactions for B-run steelhead.




IV. Proposed Wild B-run SteelheadConservation and RecoveryAgreement

1. Closure of all Columbia and SnakeRiver thermal refuges to all fisheries.Wild steelhead spend days and weeksin some thermal refugia and should beafforded shelter from angling.2. Establish an inter-state recoveryagreement for B-run steelheadapproved by NOAA. That agreement must be based on the best availablebiological information with the objec-tive to recover the threatened speciesand establish river-specific spawnerescapement criteria and egg deposi-tion criteria for each natal stream. 3. These criteria are to be verified withparr abundance objectives (full seed-ing) by natal stream. 4. The states and NOAA will provide anannual report for the public on meet-ing wild spawner escapement, e g gdeposition and parr abundance criteriaby natal stream. 5. Habitat restoration and protection isto be focused on spawning and rearinghabitat for B-run steelhead. 6 Fishway maintenance closures mustbe coordinated to contribute to themigration of wild B-run s t e e l h e a d .These fish over-winter in the Columbiaand Snake rivers before migrating totheir natal rivers to reproduce.Fishway work should not block migra-tion of steelhead responding to the cueof increasing water temperatures. 7. All three states must commit to eval-uate the effects of fishing on wildsteelhead survival.

A thorough investigation of encounterrates should be conducted to deter-mine risk to wild B-run steelhead insport fisheries for hatchery steelhead.ODFW has identified encounter ratesfor wild steelhead to be 2 -5 timesgreater for wild fish in a river com-pared to hatchery fish (ODFWDeschutes and Alsea rivers data). Acoordinated evaluation of encounterrates, mortality of fish released basedon water temperature, impacts on sur-vival, and their effect on achievingwild spawner criteria are all poorlyunderstood. With the wild populationso low, the precautionary principledemands that the risk be shifted away

from the wild populations. Better rele-vant information could be used to liftany angling and fish-handling limits orto open fisheries that have been closeddue to perceived high encounter andmortality rates.

It is inconceivable that fisheriesrequiring release of wild steelhead arenot contributing to the reduced sur-vival of wild B-run steelhead. Idahorelies on studies examining mortalityin summer and fall resident trout fish-eries to extrapolate impacts to steel-head caught and released in fall, win-ter and spring weather, when anglersare more likely to harm a wild steel-head in freezing air temperatures thanin mild summer-fall trout fisheryweather.

Applicable findings are primarilyfound in the Atlantic salmon scientificliterature. Catch and release fisheriescause direct mortality as well asdepressed reproductive success due tofall back, delayed migration, andreduced length of migration afterrelease. Additional studies haveshown that warmer water tempera-tures increase detrimental effects ofcatch and release and that larger fishhave been found to have particularlyreduced reproductive success aftercatch and release.

8. Failure to mark hatchery steelheadis compromising efforts to monitorsteelhead abundance, diversity andescapement estimates. All hatchery-produced steelhead must be markedbefore release. Fishery researchersfrom Idaho have said it best: “Finally,the issue of non-adipose-clipped hatch-ery fish in window counts of ‘wildsteelhead’ needs resolution. Hatchery-origin fish composed 46% of theunmarked catch in the Lower GraniteDam adult trap. Window counts at thedam included these fish with wildsteelhead, greatly inflating wild steel-head escapement estimates. Obviously,even given that resolution of geneticstock identification is sufficient, themethodology of developing wild steel-head escapement estimates must berefined in order to produce statistical-ly valid and accurate counts.”9. Estimating mortality in commercialnet fisheries must be more rigorouslyevaluated. Oregon and Washingtonincreased their rate of on-board moni-toring of commercial gillnet fisheries

in 2017, yet their joint effort to havethe standard mortality rates changedbased on a single season of observa-tions and data-collection is unwarrant-ed. The Coastal ConservationAssociation has detailed the rationalwhy this rushed effort to approve anew, lower standard is improper, notscientifically valid and must be cate-gorically denied by the US v. OregonTechnical Advisory Committee (TAC). The Columbia River is managed for a

mixed-stock (different species withdifferent population abundance) non-selective (meaning fishers cannotavoid fish they may not or cannot har-vest or release safely) fishery thatrelies on flawed forecasting, poor in-season monitoring and enforcement,no accounting for environmental con-ditions and, ultimately, with no assur-ance that wild fish actually reach theirhome rivers to spawn. This all quiteclear based on NOAA’s FisheryScience Center’s latest review pub-lished in late 2015, before factoring inrecent poor returns: “Four out of thefive MPGs [Major Population Groups]are not meeting the specific objectivesin the draft Recovery Plan based onthe updated status information avail-able for this review, and the status ofmany individual populations remainsuncertain….. A great deal of uncertain-ty still remains regarding the relativeproportion of hatchery fish in naturalspawning areas near major hatcheryrelease sites within individual popula-tions. Overall, the information ana-lyzed for this status review does notindicate a change in biological risk sta-tus.”All wild steelhead, both A-run and B-

run fish, are precious and unique jew-els and need every possible opportuni-ty to spawn successfully. The ongoingand existing Columbia and SnakeRiver sport and commercial fisherywill cause mortalities to the wild steel-head returns now and into the futurewithout significant changes.

It is past time to stop fishing forsteelhead late in the season and instaging and spawning areas when runsare well below historic and even recentabundance levels - until real changesare made in our harvest, hatchery,water withdrawal and hydropowerpractices in the Columbia and Snakerivers.



Robert Hooton retired as supervisor ofthe Fish and Wildlife Section for theBritish Columbia Ministry ofEnvironment’s Vancouver Islandregional office in 2008.

Recent months have seen avirtual tidal wave of infor-mation trading back andforth over the status ofone of British Columbia’s

treasures, Thompson River steelhead.Never in almost six decades of associ-ation with steelhead in this provincehave I seen anywhere near the level ofconcern over a steelhead stock. That isa very good thing and one can onlyhope the eleventh hour pressure nowdeveloping will make a difference tothe future of these magnificent fish.That said, let’s examine the guts of theissue.

First stop — it isn’t just thoseThompson fish. From a pure scienceperspective they are but one of a groupknown as the Interior Fraser Steelhead(IFS). The distant and long forgottenChilcotin stock is among them as aremuch smaller and even more forgottenstocks from the Nahatlatch, Stein,Bridge and Seton rivers. All the atten-tion is focused on the Thompson, most-ly because it is within a day’s drive ofVancouver and it is, or was, the largeststock among all the IFS. The Chilcotinonce enjoyed an equal reputation butone would be hard pressed to find ahalf dozen anglers of the modern erawho know anything of that. Shed a tear.Keeping in mind that most of what

follows with respect to Thompsonsteelhead applies equally to thoseother IFS stocks, let’s look more care-fully at where we stand.The downward trend in abundance of

Thompson fish is well understood. Theforces contributing to that trend haveall been acknowledged but I’ll offertheir relative influence is nowherenear appreciated. The ocean is alwaysthe great unknown. All we can say with

certainty is it hasn’t been a happyplace for salmon and steelhead inrecent years. Blame “the blob”, north-ern extension of the range of voraciouspredators such as mackerel and pom-pano, competition for food from matur-ing hatchery salmon originating fromthe far western Pacific and commer-cial fisheries that intercept steelheadafter they spin off from their annualcycle through the Gulf of Alaska andhead for the Fraser River approaches.All are factors, to be sure. Some con-

tend the ocean is less important thanwater starved juvenile rearing habitatin Thompson tributaries. To those Isay, the highly productive steelheadrearing habitat of the Chilcotin is any-thing but short on water and that stockis even worse off than is theThompson. For as long as I can remember as a

member of the government agencyresponsible for steelhead management(in fresh water at least), the commer-cial fishing industry was held to be thesingle greatest factor controlling theabundance of Thompson steelhead. I’llagree the case in support of that wasstrong at one time. Whereas the com-mercial fishery doesn’t get a passtoday, it has been eclipsed by the FirstNations fisheries prosecuted within theFraser River. Call it the elephant in theroom. Here’s the reality.

The First Nations population ofBritish Columbia is roughly 4% (5% ifInuit and Metis are included) of theprovincial total but, by far, theyoungest and fastest growing segmentof that total. Coincidentally, we have

governments pushing harder than everto build voting capital by being seen asatoning for the injustices of our forefa-thers. Pile on the United NationsDeclaration on the Rights ofIndigenous Peoples to add momentumto what was already growing exponen-tially. Almost everyone on the streetsof Vancouver hears about indigenousrights on a daily basis. Almost no onehas ever heard of steelhead.

In the political arena the forcemajeure is reconciliation. For coastalFirst Nations, fish are clearly becom-ing currency in that respect. In thecourt of public opinion one dares notsuggest this is not a good thing. Mypoint is the supply of fish is diminish-ing and the demand increasing. Thetwo lines crossed years ago withrespect to Fraser River bound steel-head, regardless of who has the legalor political nod to catch them. Today isnot about allocation, it’s about sustain-ability and conservation.Ah, but we have all the conservation

oriented process and law to saveendangered species like Thompsonand Chilcotin steelhead. Enter theCommittee on the Status ofEndangered Wildlife in Canada(COSEWIC). These highly respectedscientists performed an emergencyassessment of the status of those steel-head and recommended to Canada’sMinister of Environment and ClimateChange an endangered listing.Subsequent steps are described adnauseam in a couple of blog pieces I’veprepared so I won’t confuse things bytrying to summarize them again here(www.steelheadvoices.com). Suffice tosay due process is highly unlikely tosecure the endangered species listingthat would obligate the federal govern-ment to introduce the sorts of protec-tion measures that could save whatremains of IFS. Even if the endangeredlisting was brought forward according


The downward trendin the abundance ofThompson River fish iswell understood.


The Thompson River’s Last Stand asWild Steelhead Numbers Plummet

By Robert Hooton

— Nanaimo, British Columbia —

to the timetable one can tease out ofthe plethora of background material onsuch matters, we would endure at leastanother two or three seasons of the sta-tus quo.

The Department of Fisheries andOceans (DFO) would have us believethey are doing everything possible toprotect IFS. They are pursuing newcomputer models that assess the“exposure” of IFS to commercial fish-ing nets along their migration pathfrom Johnstone Strait through thelower Fraser River. What that means isthey are reviewing past data on whereand when catches of IFS occurred andcalculating the time over which theywould be present in the conventionalcommercial seine and gill net fishingareas. Then they are talking about“rolling 3 or 4 week closure windows”to protect 80% of the run from harvest“with a high degree of certainty”. Noone I know who is familiar with the IFSmigration routes and timing is theleast bit comfortable with such deskdriven exercises. First, IFS are pre-sent for 10 or more weeks, not 3 or 4.Second, protecting 80% of the run is abit of a different story when there areonly 200 fish present as opposed to sev-eral thousand that occupied thosesame migration corridors and timesnot long ago. Third, what does a highdegree of certainty mean? Fourth,what about those in-river First Nationsfisheries? Fifth, the provincial govern-ment voice representing steelhead inthese private discussions is theMinistry of Agriculture, not the steel-head management agency known asthe Ministry of Forests, Lands, NaturalResource Operations and RuralDevelopment or FLNRORD (does thatsound like emasculation of any steel-head management capability?). ThoseAgriculture people are co-conspiratorswith DFO in the issue that drives thecommercial fishery and, by extension,the First Nations fisheries. That issueis the certification of the Fraser Riverchum fisheries as sustainable underthe Marine Stewardship Council (MSC)guidelines and process. Add on the factthose Agriculture people are alsoresponsible for licensing the shorebased fish processors, as well as mar-keting British Columbia seafood prod-ucts, and there is just a bit of a conflict

of interest within the provincial gov-ernment itself.Anyone not familiar with the green

washing marketing tool that MSC cer-tification is all about might want toconsider a quote from an excellentreview article published in BiologicalConservation 161 (2013) 10-17.“During its 15 years, the MSC, whichhas an annual budget of close to US$20million, has attached its logo to morethan 170 fisheries. These certificationshave not occurred without protest.Despite high costs and difficult proce-dures, conservation organizations andother groups have filed and paid for 19formal objections to MSC fisheries cer-tifications. Only one objection has beenupheld such that the fishery was notcertified. … An analysis of the formalobjections indicates that the MSC’sprinciples for sustainable fishing aretoo lenient and discretionary, andallow for overly generous interpreta-tion by third-party certifiers and adju-dicators, which means that the MSClabel may be misleading both con-sumers and conservation funders”.I don’t use the term co-conspirators

without reason. The chum fisheries,both commercial and First Nations,dominate what remains of the BC’ssalmon fisheries. DFO and the provin-cial Agriculture people would have alot less to manage and market withoutthem. DFO performs token enforce-ment patrols in both tidal and non-tidalwaters to police commercial vessellicense requirements that specifyrecovery boxes and circulating pumpsmust be operational at all times whenfishing and all non-target species,which generally includes sockeye,Chinook and wild coho salmon, andsteelhead, must be resuscitated andreleased unharmed. They brag thatthese are selective fishing methodsthat have been in place since 2002.Look at the above figure for evidenceof how that’s been working forThompson steelhead. A recent presen-tation by a top official in DFO’senforcement division revealed theenforcement effort in 2017 was thelowest in the past four years. Our manalso stated plainly that the enforce-ment patrols in the Johnstone Straitarea were intended to satisfy all com-ers that the commercial fisheries were“clean” and thus the MSC conditionsfor certification upheld. Predictably,

no significant transgressions weredetected so the MSC beat goes on.The last point I’ll make around the

chum fishery is it is focused onenhanced stocks that return to lowerFraser tributaries at the worst possibletime in terms of the overlap with IFSrun timing. The chum fishery is allabout roe, the value of which is enor-mous in offshore markets. The carcas-es are little more than pet food andprawn bait. Any reference to FNs tar-geting chums for “Food, Social andCeremonial” purposes acknowledgedunder Canada’s Constitution is smokeand mirrors. The Firt Nations fisheriesimpacting IFS are now formallyreferred to by DFO as “EconomicOpportunity” fisheries. What makesmatters even worse is DFO is quick toimpose restrictions and even closureson harvesting the two species longknown as the only significant food tar-get of the FNs — Chinook and sockeye.Foregone opportunity on those tradi-tional species whose run timing pre-cedes steelhead pushes the FN fish-eries later into the year so they cancapitalize on dollars from chum roe,rather than protein from sockeye andchinook, while wreaking havoc on whatlittle remains of IFS.More on process. DFO now prepares

massive documents titled InterimFisheries Management Plans (IFMPs).These are circulated in draft form to“stakeholders” that they consider torepresent the full spectrum of fish-eries interests. The 2018 document ofinterest to IFS is 587 pages. I submitthere are damned few of us volunteersout here with the time and dollars toprocess that material and attend all themeetings in far away places to ask pen-etrating questions. Nonetheless thatIFMP and the so called consultationaround it is all the federal governmentneeds to have its way. Steelhead havenever and will never be given their duein any IFMP. The abundance trend forIFS shouts volumes in that regard.And, if that isn’t depressing enough,consider that any conditions aroundFirst Nations fisheries are negotiatedindependent of IFMP processes.Instead, the First Nations along the IFSmigration corridor — upwards of 40 ofthem between Vancouver and theThompson steelhead spawning desti-nations — deal separately with DFO in




Author Linwood Laughy is an Idaho-based wild salmon and steelhead advo-cate.

In the mid-1950s, I oftenwatched Clearwater River B-run steelhead leap from pool topool ascending the fish ladderon the north end of the

Washington Water Power Dam threemiles upstream from the river’smouth. According to the IdahoDepartment of Fish and Game (IDFG),in the 1950s and early ‘60s, 40,000 wildB-run steelhead crossed that dam eachyear. Now 2018, 98% of the oncefamous Clearwater B-run steelheadare gone.

The destruction of this magnificentsteelhead run began officially onMarch 14, 1947, as noted in the U.S.Army Corps of Engineers’ SpecialReport on Selection of Sites, LowerSnake River, Oregon, Washington andIdaho.“The problem of passing migratory

fish over dams on lower Snake Riverwas discussed with representatives ofthe U.S. Fish and Wildlife Service,State of Washington Department ofFisheries, Fish Commission of Oregon,Oregon State Game Commission, andthe State of Idaho Department of Fishand Game. The consensus of opinion ofthese agencies was that any series ofdams on lower Snake River would behazardous and might entirely elimi-nate the runs of migratory fish in thatstream. [Emphasis added.] In view of

the experience at Bonneville Dam, thisoffice does not concur with thisunfounded opinion.”

The actual destruction of theClearwater’s B-run steelhead began in1956. The U.S. Corps of Engineers con-structed Ice Harbor Dam 1956-1961;Lower Monumental Dam, 1961-1969;Little Goose Dam, 1963-1970; LowerGranite Dam, 1965-1973. In 1973 thecompletion of Dworshak Dam on theClearwater’s North Fork struck anoth-er blow.

The early 1960s saw more than100,000 wild A-run and B-run steelheadenter the Snake River each year. Bythe 1974-75 season that number haddropped to 12,200, with only 3,000 fishreturning to Idaho rivers and streams.In 1997, the U.S. Fish and WildlifeService listed all Snake River steel-head as threatened with extinctionunder the Endangered Species Act. A-run steelhead generally passBonneville Dam between July 1 andAugust 25. These are primarily one-year-in-ocean fish less than 78 cen-timeters (about 31 inches) in length. B-run steelhead pass Bonneville mostlyafter August 25 and before November1. These fish typically spend two yearsin the ocean and are headed for Idaho’sClearwater and Salmon rivers.Fast-forward 20 years. In 2017 fish

managers predicted as few as 770 wildB-run steelhead would cross LowerGranite dam during the 2017-2018 sea-son, later raising this figure to 1,100.Pinning down accurate fish numbers iscomplicated. Not all B-run steelheadare over 78 centimeters in length,cross Bonneville between August 25and November 1, or spend two years inthe ocean. Further, up to a third of theB-run over Lower Granite Dam arebound for the Middle Fork and SouthFork of the Salmon River rather thanthe Clearwater. Yet slice the figuresany way you wish, since the late 1950saround 98% of the Clearwater River

forums where there has never been asteelhead management voice present.An agency with a sad history ofaddressing steelhead concerns part-nered with a large number of indepen-dent First Nations who do not holdsteelhead and steelhead angling in highregard does not breed optimism. What can we do? Cancelling the MSC

certification would be entirely benefi-cial but the best sources I can tap intoon that subject tell me the armouraround the MSC certification process isall but bullet proof. That paper refer-enced above is evidence enough ofthat. The alternative is to go after themajor buyers of fish from MSC certi-fied fisheries in BC. That holdspromise. The other avenue of hope islegal action to force the federal gov-ernment to live by its own rulesregarding endangered species status,and protective measures that statuscommands. People are angry overDFO’s intransigence and the province’scomplicity. Canada has never been bigon the courtroom over the boardroombut this one deserves a differentapproach. The other seemingly obvious conser-

vation measure is to get the FirstNation’s chum seeking nets out of themigration corridor when IFS are pre-sent. What could be simpler? The largemajority of those enhanced chumsoriginate from lower Fraser tribu-taries where they could be harvestedwithout collateral damage. However,that would require sharing agreementsbetween First Nations that have a longhistory of conflict over salmon and lit-tle concern for steelhead. The 2018 IFS return will be the test.

There can be no doubt the worst ever,most black and white conservation cri-sis ever known among BritishColumbia’s revered steelhead stockswill never reverse itself in the absenceof major changes in how all three gov-ernments manage fisheries. All theplatitudes about conservation, sustain-ability, the precautionary principle,biodiversity, etc. will be tested asnever before. As go Thompson steel-head, so go wild steelhead in the nextand the next and the next once greatrivers.



Continued from previous page On the Edge: Wild Clearwater

River B-Run SteelheadBy Linwood Laughy

— Moscow, Idaho —

Now, in 2018, 98% of the once famousClearwater River B-Run steelhead are gone

wild B-run steelhead have disap-peared.Citing present ocean conditions as a

major contributor to the extremely low2017 Snake River steelhead returns,IDFG fish biologist Joe Dupont recent-ly wrote: “If we had better spawning,rearing and migratory conditions, itwould buffer the poor ocean conditionsto the point that we could still provideharvest fisheries in Idaho, and wildfish would not be threatened of goingextinct.” [Emphasis added] This maybe as bold a statement as an IDFG staffmember dare make with its referenceto “migratory conditions.” In 1999 theIdaho legislature whisked manage-ment of ESA-listed fish species awayfrom IDFG with the creation of theOffice of Species Conservation in theGovernor’s office. The State of Idaho, adefendant in the current Bi-Op casebefore Judge Michael H. Simon, isaligned with the federal agencies andspecial interest groups trying to main-tain the status quo on the lower SnakeRiver—fish be damned as well asdammed.

In its 2002 Lower Snake RiverJuvenile Salmon Migration FeasibilityStudy, the Corps of Engineers identi-fied three action alternatives toaddress the issue of threatened andendangered Snake River salmon andsteelhead: the maximum transport(barging) of juvenile fish around thedams, major dam passage systemimprovements, and dam breaching.The biological analysis concluded thethird alternative, breaching, presentedthe highest probability of recoveringendangered and threatened SnakeRiver salmon and steelhead.

The Corps and Bonneville PowerAdministration have since spent bil-lions of taxpayer and ratepayer dollarsimplementing the first two alterna-tives. These least-likely-to-succeedalternatives have failed. No SnakeRiver threatened or endangered fishspecies is on its way to recovery. InNovember 2017 National Oceanic andAtmospheric Administration Fisheriesreleased its new “Recovery Plan” forthreatened Snake River steelhead.The plan includes an extensive list ofactions continuing over the next 50 to100 years and is projected to cost hun-dreds of millions of dollars. Two points

of particular note in the report: first,the plan keeps the lower Snake Riverdams in place, and second, astonishing-ly, NOAA Fisheries acknowledges that“the actions will not get us to recov-ery.”

The public is thus now asked to investmore millions of dollars in a fishrecovery plan designed to fail whileignoring the one action fish scientistshave consistently identified as having

the greatest potential for successfulrecovery: dam breaching. And all thiswhile the four lower Snake River damscontinue to produce electricity we nolonger need, while we subsidize theSnake River shipment of wheat to Asia,

and watch our once plentiful and thriv-ing wild salmon and steelhead disap-pear.By NOAA’s own admission, the feder-

al government’s recovery plan forthreatened Snake River steelhead is asham deserving of public outrage. Thespecial interest groups that supportthe status quo on the lower SnakeRiver —including government agen-cies like the Corps of Engineers andNOAA Fisheries — deserve the pub-lic’s disdain. Politicians who do thebidding of these organizations and whowillfully deceive the public with misin-formation and false statementsregarding Snake River steelhead andsalmon must be held accountable.

Based on Jared Diamond’s awardwinning book Collapse, the onlyremaining hope for avoiding theextinction of Snake River wild salmonand steelhead rests with an aggressive

mass movement of individuals whorefuse to see these iconic species dis-appear. Individual anger without col-lective action is a sure path to speciesextinction.


The four lower Snake River dams remain the primary impediment to restoring notonly Clearwater River B-Run steelhead, but steelhead and Pacific salmon populationsthroughout the upper Columbia River Basin. Photo by Jim Yuskavitch


Breaching the fourSnake River damsoffers the best

chance of recoveringESA listed fish

Conrad Gowell is Fellowship ProgramDirector and Jennifer Fairbrother isCampaign & Columbia RegionalDirector for the Native Fish Society.The Native Fish Society uses the best

available science to advocate for therecovery of wild native fish and goodstewardship of their habitats. Learnmore about the organization’s work at:nativefishsociety.org

Since the Oregon Departmentof Fish and Wildlife (ODFW)released a press statement atWillamette Falls in 2017,there has been a sustained

public outcry about the conflictbetween wild winter steelhead and sealions. Dr. Shaun Clements, SeniorPolicy Analyst with ODFW, said in astatement, “We know what the problemis and have seen this coming for abouta decade, we just couldn’t take actionto prevent it.” Dr. Clements is refer-ring to an effort by many groups tomodify the Marine Mammal ProtectionAct (MMPA), which would allow theDepartment to lethally removeCalifornia sea lions from the area sur-rounding Willamette Falls. Federal leg-islation has been introduced in both theHouse and Senate (H.R. 2083 and S.1702, respectively) to modify theMMPA for this purpose. While the actdoes allow for the lethal removal ofproblem sea lions under crisis situa-tions, state agencies want more lati-tude to address predation problemsthroughout the Columbia. ODFW’s sci-ence team released a PopulationViability Analysis (PVA) in 2017assessing the effect of sea lion associ-ated mortality on wild winter steel-head at Willamette Falls. The reportindicates: “Sea lions have a large nega-tive effect on the viability of wintersteelhead.” Sea lion presence at Willamette Falls

has been increasing over the pastdecade. As predators of Endangered

Species Act-listed winter steelhead,spring Chinook, lamprey, sturgeon,and other fishes native and non-nativeto the Willamette, sea lion predation isimpacting the already low populationsof wild fish in the basin. ODFW hasdeclared that, because of the increasedsea-lion population, wild winter steel-head are on the verge of extinction inthe Willamette. But the Department’sown analysis also shows one populationof wild Willamette River winter steel-head, the Calapooia, is destined forextinction regardless of what is donewith sea lions.

For Native Fish Society (NFS) RiverStewards working on the recovery andprotection of these fish, ODFW’s state-ments and PVA only provide part ofthe story. Winter steelhead have beendeclining for at least four and a halfdecades, falling from over 25,000 fishin 1971-1972 run year to just 822 in the2016-2017 run year. Of those 822 fish,only 512 were estimated to return tothe four core populations included inthe analysis. The shifting baseline ofwild steelhead decline in theWillamette began well before thesedata were taken. It started with intensesplash dam logging, gravel mining, andindustrial development that has beenoccurring since the 1860s. Willamettewinter steelhead and spring Chinookwere listed as threatened species in1999 due to the continued degradationof habitat below, and lack of passageover federally owned dams, the nega-

tive impacts of mitigation hatcheries,and recreational and commercial har-vest concerns. In response, severalmanagement plans have been put inplace in the Willamette including theFisheries Evaluation and ManagementPlan (2001), the Willamette BiologicalOpinion (2008), and the NationalMarine Fisheries Services’ RecoveryPlan (2011). Because of recommenda-tions made in these plans, direct har-vest has been reduced, incidental har-vest through commercial fisheries hasdecreased, and hatchery operationshave been limited to non-native sum-mer steelhead, resident rainbows, andspring Chinook production. But even as River Stewards through-

out the basin carefully followed theabysmal returns of wild winter steel-head over Willamette Falls early in the2016-2017 run year, no action wastaken by fisheries managers. This lackof action led NFS River Steward DaveCarpenter to reach out to the gover-nor's office, district fisheries biolo-gists, Fish and WildlifeCommissioners, and state senators andrepresentatives, urging them toaddress the multitude of threats facingthese fish. In many of the Willamette’stributaries, it is legal to fish for wildwinter steelhead during their spawn-ing period, and the use of bait isallowed while juveniles are rearing infreshwater. Simple actions, like shut-ting down the catch and release fisherycan take place on an emergency basis.But there is a problem: no one hasdetermined an escapement number, orthe number of fish that need to returnto the spawning grounds. This figure isabsolutely necessary to take in-seasonaction and sustain the population intothe future. The research, monitoring,and evaluation has not been developedto say if and when we need to adaptive-ly reduce our various impacts to thesefish.



Winter steelhead havebeen declining for thepast 45 years, longbefore the sea lions

showed up.

Wild Winter Steelhead, Sea Lions and Crisis Management

By Conrad Gowell and Jennifer Fairbrother

— Native Fish Society —

http://nativefishsociety.org

Winter steelhead have been decliningfor the past 45 years, long before sealions showed up. While it is easy toarticulate the effect of a single factor,such as sea lion predation, the solution

to wild steelhead recovery is more elu-sive. During the in-season period ofthis year’s steelhead run, ODFWoffered the following statement: “Partof the reason for this year's declinemay be the horrific water conditionsthat existed during outmigration formany steelhead smolts during the win-ter and spring of 2015. As you recallwe endured one of the worst droughtson record, exacerbated by a heat wavethat elevated stream temperaturesmarkedly in spring and early summer.Sea lion predation could also be a fac-tor, given the ever-growing numbers inboth the Willamette and the Columbiarivers. They feed both on upstreammigrating winter steelhead adults andout-migrating juveniles below thefalls, taking an estimated minimum of15% of the Willamette bound adults in2016. Understand that additional mor-tality is occurring in the river belowthe falls as well.”Indeed, these fish did experience a

triple whammy of environmental con-ditions which contributed to their poorsurvival. A drought in 2015 causedmany streams throughout the upperWillamette basin to dewater, includingCourtney Creek, a high priority tribu-tary in the Calapooia watershed.Oregon has been found ill-equipped tosolve water quantity challenges, andpublic and private efforts to addresswater quality concerns have stalled.The juvenile steelhead that survived

the poor freshwater conditions were

also subjected to some of the worstocean conditions since the late 1990s.Poor upwelling along the NorthwestPacific Coast in the 2014-2016 yearslikely led to very low juvenile survivalfor Willamette steelhead. When winter

steelhead were foraging through theNorth Pacific, these fish encountered“the blob", a deadly patch of warmwater that developed and persistedduring the summer of 2015 and into2016, leading to poor survival of sub-adult steelhead in the ocean. Once this cohort of fish returned to

freshwater they were caught in recre-ational and commercial gillnet fish-eries throughout the lower ColumbiaRiver, not purposely, but as bycatch—the unintended consequence of tryingto keep fisheries open when small pop-ulations of ESA-listed fish are passingthrough. The effect of this harvest isassumed to be low, but poor data callsinto question whether or not this factoris important. It’s at this point in their migration

that adult wild winter steelhead wouldbe subjected to sea lion mortality.With an increasing number ofCalifornia sea lions showing up in theWillamette River, scientists estimatedthat 25% of the steelhead that returnedto Willamette Falls in 2016 were con-sumed by these marine mammals. Ifwe extrapolate the 25% predation esti-mate out to the 2017 return year andadd that number back into the totalnumber of fish that returned, thecounts of winter steelhead atWillamette Falls would still be the low-est on record. And the trend is notimproving. This year’s run of wildWillamette winter steelhead looks tobe the second lowest on record.

In 2017, NFS River Steward NickRowell provided anecdotal observa-tions on the Clackamas River of sealions moving up into the river to preyon spawning winter steelhead.It is no question that sea lions movingthis far into freshwater, feeding attimes on spawning fish, is having anegative effect. In WashingtonState, sea lions drove a population ofsteelhead that moved through theBallard Locks in Seattle to nearextirpation. Indicators within thelarger ecosystem, however, point toa larger collapse of prey species,with lamprey, forage fish and otherfood sources for sea lions such assardines, sand lance, anchovies,and herring also struggling in thepoor ocean conditions.So where do we draw the line in

our efforts to control predators?In one study, avian predators in

central California wiped out 100% ofendangered steelhead and cohosalmon. Do we also start selectivelykilling problem water oozles, blueherons, hooded mergansers, kingfish-ers, salmon sharks, and orca whales?

But those fish that successfullymaneuver around the sea lions andanglers parked at the base ofWillamette Falls still face numeroushurdles before they are able to spawn.Native fish often find that they can’treach their historical spawning habitatdue to incomplete or partial fish pas-sage at dams. For example, the MintoFish Passage facility on the N. ForkSantiam River, which was built by theArmy Corps of Engineers in 2013, hasnot been able to pass wild winter steel-head or spring Chinook upstream intotheir historical habitat because theiroffspring will have no way to migratedownstream through the reservoirsafter they hatch. The $27.4 million dol-lar facility opened in 2013, but plans toprovide downstream passage atDetroit reservoir have stalled and thetimeline remains uncertain to startconstruction on downstream passage.The earliest that juvenile wild steel-head could naturally pass throughDetroit Reservoir on their way to theocean is now 2023, the deadline forproviding full fish passage in theWillamette Biological Opinion. Another factor weighing on the pop-

ulation of winter steelhead is ODFW’s




Table 1. Percentages of quasi-extinction over a 100 year period in four populations ofWillamette River winter steelhead under four different scenarios. Scenarios with sea lionsassume that the predation mortality estimated during that year will continue indefinitely. Thelowest predation rate was observed in 2015 and the highest predation rate was observed in2017.

stocking of non-nativehatchery summer steel-head and hatchery rain-bow trout. ODFW releas-es hundreds of thousandsof these fish every year,which pose ecological andgenetic risks to nativewinter steelhead.Hatchery summer steel-head smolts are plantedat a much larger size thanjuvenile winter steelheadand often residualize, orstay in the river, insteadof going to the ocean.These holdover summersteelhead then competewith native winter steel-head for food and otherresources. Wild winterand hatchery summersteelhead can also spawntogether, yielding unfithybrids of the two dis-tinct life histories.Stocked rainbow trout,like sea lions, can alsodirectly prey upon juvenile ESA-listedwinter steelhead and spring Chinook.Last year, a lawsuit was filed by twoconservation groups, WillametteRiverkeeper and The ConservationAngler, alleging that hatchery summerrun steelhead programs are puttingESA-listed wild winter steelhead injeopardy.

While the effect of sea lion preda-tion shown by ODFW researchers doescontribute to the probability of one ormore Willamette steelhead populationsgoing extinct over the next century,other factors like those discussedabove were not analyzed to weigh theirindividual contribution to the prob-lems facing these fish. Pinniped preda-tion may be a serious threat movingforward, but it was not the sole factorresponsible for the critically low run in2017 and again this year.

In 2021, wild winter steelhead arelikely to be uplisted from threatened toendangered under the EndangeredSpecies Act. We take very seriouslyDr. Clements’ statement that, “We areat a point where any more delays in theWillamette may condemn this run toextinction.”But it will take more than just amend-

ing the Marine Mammal Protection Actto save these fish. In March, NFS fileda lawsuit, in conjunction with our part-ners at WildEarth Guardians andNorthwest Environmental DefenseCenter and represented by Advocatesfor the West, to address the failure bythe U.S. Army Corps of Engineers (theCorps) to implement the managementchanges necessary to recover UpperWillamette River winter steelhead andspring Chinook. The Corps initiatedreconsultation under the EndangeredSpecies Act in April, the first step toaddressing significant factors such asfish passage at key dams.Native Fish Society River Stewards

in the upper Willamette Basins havebeen calling on fisheries managers toshut down harvest on these ESA-listedfish, reform hatchery practices,restore access to historical habitat,and invest in solutions to the immedi-ate and systemic problems of wild fishdecline. Paramount to that goal is thatwe establish an escapement, or thresh-old for each population, at which welimit the array of threats we haveimmediate control over. We can’t oper-ate under crisis management to recov-er any listed species.

Ultimately, the solution to the

Willamette’s wild fish crisis dependsupon our collective voices creating thepublic will necessary to motivate stateand federal resource managers toimplement meaningful solutions. Ourcurrent crisis has drawn a diversearray of stakeholders to the table toform a coalition to help guide recoveryefforts and engage the public inaddressing the many causes of wildfish decline. The root threats to the survival of

threatened Willamette winter steel-head and spring Chinook are complex.While the effect of sea lion predation isimportant, it isn’t the reason wild win-ter steelhead face extinction. Savingthese fish, much less recovering themto populations that can sustain fullyexecutable fisheries, will requireresource managers to address the mul-tiplicity of factors impacting thesepopulations. We must move forwardnow on implementing solutions thatdon’t require congressional approval ifwe are to ensure the persistence of thisunique run of fish.





Matt Little is Executive Director of theCascade Forest Conservancy, an orga-nization that is dedicated to protectingforests, streams, wildlife and commu-nities in the Cascade Mountains. Learnmore about their work at: cascadeforest.org

Just north of Mount St. Helenslies the beautiful and pristineGreen River valley, which is atreasured wild steelheadrefuge and a destination for

backcountry recreationists. It is alsothe site of a proposed gold and coppermine, and a battle that has been ragingfor over a decade.The headwaters of the Green River

lie in a steep and verdant valley in theremote northeastern portion of theMount St. Helens National VolcanicMonument and contain one of theworld’s unique ecosystems. FollowingMount St. Helens’ 1980 eruption, thisvalley had areas that were scorched bythe blast and other areas that weresheltered and where old growthforests survived the volcaniccatalysm. This resulting mix of nativeflora and fauna at various levels ofsuccession created a mosaic of diversi-ty that today supports a diversity ofspecies from wildflowers to herds ofelk, and enjoyed by recreationistsfrom bird-watchers to anglers.The Green River flows in and out of

the Monument’s borders, snaking itsway west through the glacial-carvedlandscape of Green River valley.Further downstream, it flows into thefamous Toutle/Cowlitz River system.From the Cowlitz Trout Hatchery andNorth Toutle Hatchery down to theColumbia River, this popular stretchprovides anglers with abundant oppor-tunities to catch salmon and steelhead.What many anglers don’t know, howev-er, is that above this system flowwaters so clean, clear, and productivefor wild steelhead that the Washington

Department of Fish and Wildlife desig-nated it in 2014 as one of the state’sfirst “Wild Stock Gene Banks”, to pro-tect the integrity of the genetic stock.The Lower Columbia Fish RecoveryBoard also identified the Green andNorth Fork Toutle Rivers as “Primary”waters — their highest designation —for the recovery of fall Chinook andcoho salmon, and winter steelhead, inthe lower Columbia River Basin. Theclean water and habitat values of theGreen River, and proximity to thescenic Mount St. Helens NationalVolcanic Monument, also led the USForest Service to determine that theGreen River is eligible for Wild andScenic River designation.

The valley is a treasure trove forother backcountry pursuits as well. Itis a valuable wildlife corridor for theseasonal migration of a large elk herd,long recognized by the state wildlifeagency for its habitat values. It alsocontains the Norway Pass special per-mit area for elk, highly coveted byhunters. Outdoor enthusiasts oftenstart their adventures at the GreenRiver Horse Camp to hike, bike, orride horses along the 22-mile GoatMountain and Green River loop trailsthrough blast zone and old growthforests, and past beautiful alpine lakesand mountain views.

Enter Ascot Resources Ltd. ThisCanadian-based mining company hasplans to explore for an industrial-scalemine in this valley. However, they arenot the first prospectors to the area. In1891, two German immigrant farmerswere on a fishing and hunting expedi-tion and found evidence of preciousmetals. This set off a mining rush inthe area and led to the establishmentof the Green River mining district in1892 (later named the St. Helens min-ing district) to manage the numerousclaims. However, these mining ven-tures proved to be unprofitable, and by1926, the three companies that had

explored the Green River valleydeposits (called Mount Margaret) hadfailed. The gold rush had ended. The latest search for industrial-scale

gold and copper started in 1969 whenDuval Corporation acquired the MountMargaret mining rights and drilled 150core samples in the 1970s. Followingthe eruption of Mount St. Helens in1980, Duval sold their claims to theTrust for Public Land. For over adecade, there was little interest in min-ing in the Green River valley until1993, when Vanderbilt Gold Corp.applied for a mining permit in thearea. The Bureau of Land Management(BLM) concluded that mineral concen-trations in the area were too low to beprofitable and denied the permit.In 2004, Idaho General Mines, Inc.

(later known as General Moly Inc.)acquired a 50% interest in the MountMargaret deposit and applied for ahardrock mining lease. The local con-servation group, Cascade ForestConservancy (CFC), then called theGifford Pinchot Task Force, respondedby rallying support from the communi-ty. The cities of Longview, Kelso, andCastle Rock, which depended on theGreen and Toutle Rivers for theirdrinking water supplies, all passedresolutions against the mine proposal.During the public comment period forthe mining permit’s EnvironmentalAssessment, over 33,000 peopleexpressed their concerns about theproposal. In 2008, the BLM denied thelease. In March of 2010, the Canadian-basedmining company, Ascot ResourcesLtd., purchased the mining rights fromGeneral Moly Inc. In a very short time,and without an environmental assess-ment, the Forest Service approvedAscot’s drilling plan. By August thecompany had drills in the ground tak-ing core samples. CFC requested aninjunction and stopped the drilling bythe summer of 2011. Ascot Resources

Mining Again Threatens Mount St. HelensArea Wild Fish and Habitat

By Matt Little

— Cascade Forest Conservancy —

http://cascadeforest.org

quickly submitted a new permit in late2011, which this time the ForestService and BLM approved. However,CFC prevailed in 2014 when a federalcourt invalidated the permits and theparties withdrew their appeals. Not to be discouraged, Ascot started

writing another application in 2015. InJanuary of this year, the ForestService yet again approved the permitand passed it along to BLM for theirreview and concurrence. It is likely theagency will concur with the decisionvery soon, making it final.An industrial-sized mine in the Green

River valley would be catastrophic forfish, wildlife, and recreation. Thesetypes of mines often require huge openpits to process the amount of rock andminerals necessary to be profitable.They also require massive contain-ment ponds held back by earthen damsto hold the toxic materials and heavymetals left in the tailings sludge aftermining, including copper, lead,cyanide, cadmium, mercury, andarsenic. These “ponds”, are notoriousfor leaking or failing over time. If oneof these is built in the steep GreenRiver valley, which is in a seismicallyactive area in the shadow of an activevolcano, the earthen dams are almostguaranteed to fail. In 2014 a tailingsdam at British Columbia’s MountPolley Mine failed, destroying wholesalmon rivers with toxic sludge.Nobody wants this to happen to theGreen River.A leak containing even the smallest

amount of dissolved copper can dis-rupt a salmonid’s olfactory senses, andat 2.3–3.0 mg/L it can be lethal. Heavymetals not only impact fish, but theybuild up in the living tissue of organ-isms as they travel up the food chainand affect just about every living crea-ture in the ecosystem, includinghumans. Mercury is notorious for thisand is a potent neurotoxin, greatlyaffecting the nervous system.Exploratory drilling alone can havesignificant impacts to fish and recre-ation along the Green River. AscotResources has plans to perform testdrilling at 23 drill pads that will create63 boreholes. The drills use chemicaladditives during the drilling processand a bentonite-based grout after-wards that can have impacts to

groundwater and surface waters. Theclosest drilling sites are just 150 feetfrom Green River tributaries and oth-ers are approximately 400 feet fromthe Green River itself. Also, trees willbe removed and formerly closed roadswill be reconstructed, which will fur-ther impact the streams and fish.Drilling, truck traffic, and other

activities will create 24/7 noisethroughout the summer into mid-fall,the same time of year that people visitthis area for backcountry recreationand solitude. Bow season for elk anddeer begins in September and the pro-posed mining site is where most back-country trips begin, since it is the endof the road and it is where the horsecamp and trails begin. The fishingexperience would certainly be disrupt-ed, as well as the direct impacts toother fish and wildlife from the projectitself.A large coalition of recreation and

conservation groups have partneredwith the Cascade Forest Conservancyto oppose this mine. The ClarkSkamania Flyfishers (CSF), estab-lished in 1975, is one of the most vocalopponents of the mine because ofpotential impacts to the local fishery.In a powerful video about the mine onCascade Forest Conservancy’s web-site, CSF’s Steve Jones is documentedfly fishing the Green River and talkingabout the inevitable impacts that min-ing will have on the 14-16 pound steel-head he loves. Others opposed to themine include the Cowlitz Indian Tribe,the original owners and managers ofthis land, and even the Portland-basedrock band Modest Mouse, who current-ly has an ad out against the mine ontheir main webpage. All these calls to action have been

heard by decision makers, includingleaders in Congress. Washington’sDemocratic Senator Maria Cantwell isan important ally for mine opponents,especially through her role as RankingMember on the Senate Energy andNatural Resources Committee. In a2016 Committee hearing on the ForestService budget, Senator Cantwellgrilled the former Chief of the ForestService, Thomas Tidwell, on hisagency’s insufficient review of thismine and the impacts it will have onthe valley.Ironically, all of the 900 acres cur-

rently under consideration for

exploratory drilling were once ownedby the conservation-focused Trust forPublic Land (TPL), who had purchasedit from Duval. In 1986, following thecreation of the Mount St. HelensNational Volcanic Monument, TPLdonated and sold their land and themining rights to the Forest Service.During the land transfer, TPL wrotethat they expected that the mineralrights “would be removed from entryunder the General Mining Laws.”Fortunately, some of these lands werealso purchased using money from theLand and Water Conservation Fund(LWCF).

The Land and Water ConservationFund Act was established by Congressin 1964 to use money generated fromoff shore oil and gas leases to acquirelands for conservation and recreationpurposes. Since its inception, LWCFhas protected over five million acresof conservation and recreation landsacross the country. A mine establishedon these lands would be devastatingnot only to the Green River valley, butfor public lands everywhere.So what’s next? The Cascade Forest

Conservancy and its coalition partnerswill continue to fight drilling in theGreen River valley, including throughmore litigation if necessary. The coali-tion hopes for a permanent end to min-ing in this valley and is asking ourleaders in Congress to lead a solutionthat will preserve the area’s exception-al fish populations, wildlife habitat,and backcountry recreation opportuni-ties. The Land and Water ConservationFund has strong bipartisan support,and any solution should also preservethe integrity of this law and the publiclands it has protected.The Green River valley is unique, andthe fish, wildlife, and communities thatdepend on it for their livelihoodsdeserve our long-term support andprotection. To learn more about thisproposal and see a video of this beauti-ful landscape, go to: cascadeforest.org/our-work/mining/

Also, please consider joining theCascade Forest Conservancy as wework toward the long-term preserva-tion of this treasured watershed.

16 MAY 2018 THE OSPREY • ISSUE NO. 90Continued from previous page

Author Patrick Myers is Director ofDevelopment and Outreach for theWild Fish Conservancy, which works toconserve wild fish through science,education and advocacy. Learn moreabout their work at: wildfishconservancy.org

On March 22, 2018,Governor Jay Insleesigned into law landmarklegislation representingthe world’s largest ever

legislative removal of Atlantic salmonnet pens. This historic action was notonly a major environmental victory forWashington state, but it set a prece-dent for our colleagues around theglobe fighting the very same battletheir own public waters.Yet as we continue to celebrate and

countdown to 2022, when CookeAquaculture’s final leases expire, wehave discovered a new and seriousthreat to our wild salmon posed by thisindustry that cannot be ignored foranother four years.

Back in February, Wild FishConservancy sent tissues samplestaken from 19 Atlantic salmon that hadescaped from a net pen near CypressIsland to an independent lab to be test-ed for Piscine Reovirus (PRV), a virusthat may spread to and harm wild fish.The lab results showed that every sin-gle one of the 19 fish tested positivefor the virus. Even more shockingwere the results of the geneticsequencing, which revealed the originof the virus to be sub-genotype 1a, orof Norwegian origin, and clusteredtightly with a PRV-isolate fromIceland.This is the first time the Icelandic

PRV-isolate has been found in Pacificwaters, and the finding raises a criticalquestion — if the eggs used in CookeAquaculture’s Atlantic salmon hatch-ery in Rochester, Washington comefrom Norwegian-born fish raised in

Iceland, has the industry been allowedto import PRV-infected eggs and con-sequently plant infected fish intoWashington’s public waters?

As a consequence of these testresults, Wild Fish Conservancy draftedand sent a letter to Dr. KennethWarheit, supervisor of the fish-healthand genetics lab at the WashingtonDepartment of Fish and Wildlife,requesting the department to test forPRV in Atlantic salmon juvenilesready to be transferred into openwater net pens and in all currently

operating Atlantic salmon net pens inWashington state.WDFW responded swiftly to our con-

cern, and agreed to test both Atlanticsalmon hatcheries and Atlantic salmonnet pens in Washington for PRV, andfurther agreed to halt the transfer ofAtlantic salmon juveniles and removeinfected fish from open-water net pensif the PRV virus was found.We applaud WDFW’s decision to test

Atlantic salmon for PRV, and we sharethe agency’s opinion that Atlanticsalmon infected with PRV should notbe grown for harvest in Washington’swaters. We believe WDFW’s decisionto exclude PRV-infected fish from pub-lic waters is well in line with a precau-tionary approach, an approach that isnecessary when considering the needsof wild Pacific salmon and steelhead.

We have deep concerns, however, overthe agency’s chosen means for testingfor this virus. We understand thatWDFW has dictated that a private vet-erinary consulting group will be con-ducting viral sampling and testing forPRV, and that this chosen group is cur-rently a consultant for, and has pub-licly testified on behalf of, the Atlanticsalmon aquaculture industry inWashington state. Due to the potentialconsequences of PRV testing inAtlantic salmon hatcheries and open-water net pens, we are concerned thatany private entity, even an entity thathad not previously exhibited apredilection for the aquaculture indus-try, could fall under the influence ofoutside interests, and could experiencedifficulty in testing for PRV in animpartial manner.To bring this issue to the agency’s

attention, Wild Fish Conservancydrafted, and is gathering signatureson, a letter of petition requestingWDFW to conduct PRV testing inter-nally. It is WFC’s belief that state con-ducted viral testing is the only way toassure the public that PRV test resultswill be free from bias. Wild Fish Conservancy will be circu-lating the petition via the Our Sound,Our Salmon campaign, a coalition of100+ businesses and organizations aswell as nearly 12,000 individuals whoworked over the past year to bringabout a legislative phase out ofAtlantic salmon net pens inWashington state.

Dear WDFW Acting Director JoeStohl,

We, as members of a coalition of busi-nesses, organizations, commercial andrecreational fishermen, and individu-als under the name of Our Sound, OurSalmon, write to respectfully urge the


Has the salmon farming industry beenallowed to import

PRV-infected eggs andthen plant infected fishinto Washington’s public waters?


By Patrick Myers

— Wild Fish Conservancy —

Piscine Reovirus Documented in EscapedPuget Sound Farmed Atlantic Salmon

http://wildfishconservancy.org

Washington Department of Fish andWildlife (WDFW) to reconsider themeans by which farmed Atlanticsalmon and ready-to-transportAtlantic salmon smolts in Washingtonstate hatcheries are to be tested forPiscine Reovirus (PRV).

In the aftermath of the CypressIsland escape last August, PRV wasfound in every fish that was tested forthe virus. Even more shocking were theresults of the genetic sequencing,which revealed the origin of the virusto be sub-genotype 1a, or of Norwegianorigin, and clustered tightly with aPRV-isolate from Iceland.This is the first time the Icelandic

PRV-isolate has been found in Pacificwaters, but it raises a critical question— if the eggs used in CookeAquaculture’s Atlantic salmon hatch-ery in Rochester, WA come fromNorwegian-born fish raised in Iceland,has the industry been allowed toimport PRV-infected eggs and conse-quently plant infected fish intoWashington’s public waters?Recent scientific evidence has shown

that PRV is amplified by net pens inthe marine environment, and that thevirus can spread to and potentiallyharm wild fish. Considering this con-cerning possibility, we applaudWDFW’s decision to test Atlanticsalmon for PRV, both in open-water netpens and at any Atlantic salmon hatch-ery intending to transfer fish into pub-lic waters, and we share the agency’sopinion that Atlantic salmon infectedwith PRV should not be grown for har-vest in Washington’s waters. Webelieve WDFW’s decision to excludePRV-infected fish from public waters iswell in line with a precautionaryapproach, an approach that is neces-sary when considering the needs ofwild Pacific salmon and steelhead.

We have deep concerns, however,over the agency’s chosen means fortesting for this virus. We understandthat WDFW has dictated that a privateveterinary consulting group will beconducting viral sampling and testingfor PRV, and that this chosen group iscurrently a consultant for, and has pub-licly testified on behalf of, the Atlanticsalmon aquaculture industry inWashington state. Due to the potentialconsequences of PRV testing in

Atlantic salmon hatcheries and open-water net pens, we are concerned thatany private entity, even an entity thathad not previously exhibited apredilection for the aquaculture indus-try, could fall under the influence ofoutside interests, and could experiencedifficulty in testing for PRV in animpartial manner.As is stated in WDFW’s own inves-

tigative report into 2017’s CypressIsland Atlantic salmon escape, theAtlantic salmon net pen industry inWashington state has misled the publicon a number of occasions in the pastyear. As a result, public confidence inthe industry’s willingness to act can-didly and in the best interests of PugetSound has eroded.

A fundamental principle of goodresource management is to assurethe public that the outcome of conse-quential testing is the result of rigor-ous science conducted by indepen-dent investigators free from any rea-sonable perception of bias and/orconflict of interest. Following thisprinciple, the signees of this letterurge WDFW to conduct PRV testinginternally, using appropriately quali-fied staff.As an agency, WDFW owns both the

scientific means and legal authority tosample and test for PRV in operatingnet pens and hatcheries, and we, as acoalition, would have far more confi-dence in test results from a governmen-tal agency than in results coming fromthe industry’s consultant. We urge WDFW to make the results ofthose tests available to the public assoon as is feasible, and we stress thatan impartial testing process is essen-tial to assure the public that theAtlantic salmon net pen industry is notcausing additional harm to our marineenvironment and our cherished marinespecies.Thank you for taking our concerns

into consideration.

More information on PRV isn PugetSound can be found at:

https://www.oursound-oursalmon.org/prv-1/


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Orca. Photo courtesy Robert Pitman,NOAA

take to protect and begin to recoverthis population on the brink of extinc-tion.

While three causes of decline aregenerally accepted, insufficient preynumbers is the top priority. Withoutmore fish in the very near-term theseorca don’t stand a chance. Further, theother two issues to address, toxins andvessel noise, are made much worse bythe shortage of prey. Lack of food, forexample, leads to burning blubberstores where toxins concentrate.Burning fat mobilizes these toxins andheightens their harms to orca repro-duction and immune systems and ulti-mately can lead to death.The plight of orca and central need

for significant increases in salmonabundance regionally has recently per-meated into many natural resourcevenues and vehicles. Advocates haveincluded endangered orca among theclaims of Columbia-Snake River Basinbiological opinion litigation for the lastten years. Orca figures prominently indiscussions in NOAA’s Columbia BasinPartnership — a new regional forum ofstakeholders working together to iden-tify recovery levels for salmon andsteelhead. Ben Enticknap, senior scien-tist with Oceana, recently delivered apresentation about orca at the 2018Lake Roosevelt Forum in Spokane,Washington. Federal agencies (BPAand Army Corps) assure us that thecourt-ordered environmental review ofsalmon recovery alternatives for theColumbia Basin will include a full andfair analysis of impacts and opportuni-ties for the Southern Residents.Across all these forums, orca advo-

cates have joined forces with salmonadvocates to press urgently for theremoval of the four lower Snake Riverdams. Not only is it one of the singlemost beneficial actions that we cantake to protect and restore endangeredsalmon (NOAA’s own finding in 2002),it will also restore significant popula-tions of the large, fatty spring Chinookwe now know Southern Residents tar-get in winter and early spring at themouth of the Columbia River. TheSnake River and its tributaries arehighly productive habitat forspringers; historically this drainageproduced nearly half of the spring

Chinook in the entire basin. Restoringthe lower Snake River by removing itsfour deadbeat dams is no silver bulletfor orca survival, but according toexperts, it is very difficult to see howwe protect them from extinction withthese dams in place.The plight of the Southern Resident

orcas is a poignant reminder of the roleof Northwest salmon as a connector ofpeople, of place and of ecosystem.Their precarious status today bringsnew urgency and argument for mean-ingful action and much-needed leader-ship. Already high stakes have gottenhigher for the Northwest and thenation; it remains to be seen if the citi-zens and leaders of our region will stepup to the challenge.

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