To: WDFW Commission
Fr: Sam Wright
Re: Hatchery Fsh Management Zones and Extinction of Wild Fish
WILD FISH EXTINCTIONS CAUSED BY THE LONG-TERM USE OF HATCHERY FISH ZONES TO MANAGE PACIFIC SALMON (ONCORHYNCHUS) IN WASHINGTON AND OREGON
A common management practice in Washington and Oregon since the early 1960s is the planned, deliberate overfishing and eventual extinction of wild Pacific salmon populations in order to harvest comingled populations of salmon that are produced by artificial production (Wright 1993). In Washington, the Final Environmental Impact Statement (EIS) for the Wild Salmonid Policy identified 89 separate naturally spawning Pacific salmon populations that were being subjected to this practice or nearly one-third of all existing Pacific salmon populations in the State (Washington Department of Fish and Wildlife (WDFW) 1997: Table II-1, p. 9).
I was the project leader and lead author for this EIS process and had to work with an Assistant Attorney General (AG) assigned to WDFW. My original language in Table 3 described the process in part as “planned, deliberate overfishing and eventual extinction of wild salmon populations in order to harvest comingled hatchery fish”. The AG stated that “this sounded like something illegal” and changed the language of the Table title to “Current fish management plans and practices overfish 89 wild stocks in order to harvest comingled hatchery fish at rates that are not sustainable by wild populations.” This is an example of one of many ways that have been used to disguise the process.
My initial attempt to stop this practice occurred in the early 1980s when I was administrator of the Habitat Management Division for the Washington Department of Fisheries (WDF). My work included involvement in a wide array of habitat protection, enhancement and mitigation projects. I soon began to wonder if I was knowingly committing illegal acts. Was it illegal to commit public funds to habitat improvement work when I knew that viable adult salmon spawners were never going to be provided to reap projected project benefits? Was it illegal to force a landowner to correct an upstream fish passage problem when I knew that spawners were never going to be provided to utilize habitat above the obstruction? Was it illegal to force a developer to fund a costly mitigation project when I knew that spawners were never going to be provided to justify the expenditure? I was also concerned that the “secret” would eventually be revealed to the public and that this could destroy our future ability to protect salmon habitat.
In 1982, I advised WDF that it was essential to end this practice since it was probably illegal in several different respects. The practice appeared to be illegal under the legislation that created WDF and had never been reviewed under the State Environmental Policy Act (SEPA). In addition, all of the more recent hatcheries requiring environmental reviews did not even hint at this practice in their environmental documents. At best, the practice was simply very poor resource stewardship. I then provided a plan to eliminate this practice that was later described in Wright (1993).
The first part of my recommendation was to mark all hatchery Chinook salmon (O. tshawytscha) and all hatchery coho salmon (O. kisutch) by removal of their adipose fins. The basic principle involved was the ability to manage wild and hatchery salmon as “separate species” and the adipose mark enabled this to be done in practice. The second part of my recommendation was that natural spawning escapement objectives needed to be established for all existing naturally spawning salmon populations and that all fisheries would then be managed to achieve these objectives. The third part of my proposal was that existing and planned hatchery programs would be adjusted as necessary to make them compatible with achieving these natural spawning escapement objectives.
The adipose marking proposal was initially rejected by everyone, but gradually came to be accepted and is now widely implemented. The problem is that it was decoupled from both the establishment and management for natural spawning escapement objectives and the need to make hatchery programs compatible. Adipose marking is meaningless by itself when the same high exploitation rates continue to be applied in non-selective fisheries harvesting comingled wild plus hatchery salmon and hatchery programs continue to be incompatible.
My only successful attempt to expose this problem in a formal publication occurred in Wright (1993). The subtitle was “Salmon managers need to abandon the use of hatchery fish management zones.” WDF tried to stop publication but had to settle for a disclaimer stating that “The views in this essay are those of the author and do not necessarily represent those of the Washington Department of Fisheries.” There was a great deal of luck involved in the peer review process since two of three reviewers were not from Washington or Oregon. Two subsequent attempts to expose the problem in formal publications failed when the majority of peer reviewers were from Washington and Oregon.
I initially had high hopes for resolution of the problem when Puget Sound Chinook and Lower Columbia River Chinook were listed as Threatened under the Endangered Species Act. Both areas had many Chinook populations on the list of 89 that were being deliberately overfished (WDFW 1997). However, all of these same populations were then assumed to be indistinguishable from hatchery Chinook or “genetically extinct” as wild populations. In Puget Sound, a total of 37 defined Chinook salmon populations were divided into 22 “A” and 15 “B” populations, with the latter group judged to be extinct. The situation in the Lower Columbia River was far worse, with North Lewis River fall Chinook being the only remaining population that was not determined to be extinct.
Unfortunately, my prediction of mass extinctions had been fulfilled. This extinct classification allowed the status quo practices of existing hatchery programs and high exploitation rates to continue for all of these populations. Some even had “escapement goals” identified to complete the public illusion of responsible resource management. Many hatchery Chinook never make it all the way back to existing hatchery traps and end–up spawning naturally. These can then be identified as an escapement goal without compromising the desired hatchery programs and high exploitation rates.
Over the years, there have been many varied attempts to disguise hatchery fish zones such as the “escapement goals” established for 15 Puget Sound “B” group Chinook salmon populations. The only citable reference that precisely identifies salmon populations where there is clear, unambiguous management intent to put adequate numbers of viable natural spawners on the spawning grounds is the Salmon Fishery Management Plan of the Pacific Fishery Management Council (PMFC 2003: Table 3-1,15p.). This confirms the solitary status of North Lewis River fall Chinook and that both the entire Columbia River system and the entire South Puget Sound Region are huge hatchery fish zones for coho salmon. As predicted for wild Chinook salmon, there have also been massive extinctions of wild coho salmon populations.
The common practice of deliberately overfishing naturally spawning salmon populations in order to harvest comingled hatchery fish continues to be alive and well in Washington and Oregon (albeit with some new disguises commonly called “hatchery reform”). The solution is still exactly what it was in 1982. At a minimum, resource managers in Washington and Oregon should at least be honest about what they are doing so that countless millions of dollars will not continue to be spent in hatchery fish zones when the same money could be spent much more productively in wild salmon zones. Hundreds of millions of dollars have already been spent and the management status (wild or hatchery zones) has never been used (as a criteria) to prioritize competing project proposals.
PFMC 2003. Fishery management plan for commercial and recreational salmon fishery off the coasts of Washington, Oregon and California as revised through Amendment 14. Pacific Fishery Management Council, Portland, OR.
WDFW 1997. Final environmental impact statement for the Wild Salmonid Policy. Washington Department of Fish and Wildlife, Olympia, WA.
Wright, S. 1993. Fishery management of wild Pacific salmon stocks to prevent extinctions. Fisheries 18(5):3-4.
Author: Sam Wright, 1522 Evanston Ct. NE, Olympia WA 98506 (360-943-4424, firstname.lastname@example.org)