2008 amendment comment

Date: October 9, 2008 To: Mr. Bill Booth, Council Chairman, and Mark Walker, Director of Public Affairs Northwest Power and Conservation Council 851 SW Sixth Avenue, Suite 1100 Portland, OR 97204-1348 From: Christopher A. Beasley Member, Ad Hoc Supplementation Workgroup Subject: comment to Draft Amendments to the Fish and Wildlife Program, document 2008-11 Dear Chairman Booth and Mr. Walker, In April of this year, the Ad Hoc Supplementation Workgroup (AHSWG) submitted to the NPCC in the first round of public comment on the Draft Amendments to the Columbia River Basin Fish and Wildlife Program, the “final draft” report: Recommendations for Broad Scale Monitoring to Evaluate the Effects of Hatchery Supplementation on the Fitness of Natural Salmon and Steelhead Populations - Final Draft Report of the Ad Hoc Supplementation Monitoring and Evaluation Workgroup (AHSWG). This report has since been revised to provide greater focus and clarification of the AHSWG recommendations. We respectfully submit the Final Report of the AHSWG (attached) for consideration during the current period of public comment on the draft amendments to the Program. The Planning Assumptions section within Vision for the Columbia River Basin in the amended Fish and Wildlife Program indicates that artificial production actions must have an experimental, adaptive management design – a design which enables one “to evaluate benefits” and which “addresses scientific uncertainties” regarding effects of these programs on natural populations. Within the Artificial Production Strategies section, it states that when used to protect and rebuild naturally spawning populations, artificial production programs “should clearly benefit that population”, but that “the science on this issue is far from settled”. These “risks and uncertainties” associated with hatchery supplementation indicated in the Program, were addressed by the ISRP and ISAB in their report Monitoring and Evaluation of Supplementation Projects (2005-15). The ISRP and ISAB concluded that for reasons both scientific and financial/practical, an evaluation of the long-term effects of hatcheries was not possible from the current situation involving a series of disconnected project-by-project assessments. Instead, they concluded that a basinwide approach to evaluating hatchery impacts – one which coordinates collection and analysis of monitoring and evaluation information from across populations, both treated (supplemented) and reference (non-supplemented). The AHSWG was formed in response to an additional recommendation of the ISAB and ISRP, that an interagency group of scientists and managers be created to describe an appropriate analytical design for such an evaluation. The recommendations of the AHSWG contained within this report call for a multidirectional approach to making this needed evaluation – an approach which carries specific implications relative to the design of artificial programs, and associated monitoring and evaluation programs financed through the Fish and Wildlife Program. As indicated previously, the AHSWG is a volunteer group of fisheries scientists and managers working on issues related to Columbia River fisheries for a variety of tribal, state, federal and private agencies. The attached report summarizes our collective views, but should not be construed to represent an official position of any of the agencies for which we work. We hope the Council will find the report informative, and we remain available to respond to any questions the Council members may have regarding the recommendations and associated content in the report. Sincerely, Christopher A. Beasley