Washington State Wild Steelhead Status

Washington State Steelhead Status

Washington Steelhead Management Plan

“In 2004, the Director of the Washington Department of Fish and Wildlife challenged the agency to develop a scientific foundation for a Statewide Steelhead Management Plan (SSMP). The scientific foundation for the SSMP comes from the Department’s steelhead science paper “Oncorhynchus mykiss: Assessment of Washington State’s Anadromous Populations and Programs” (Draft February 2, 2008), which provided several findings and recommendations to rebuild Washington’s wild stocks. The findings and recommendations represent the underpinnings of the Statewide Steelhead Management Plan.

“The steelhead management plan is necessary because in spite of seventy years of conservation efforts directed at the state’s steelhead stocks, many of these stocks are at a fraction of their historic numbers. Five of the seven distinct population segments that exist in Washington are currently federally listed under the Endangered Species Act.”

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Scott, James, B. and William T. Gill. 2008. Oncorhynchus mykiss: Assessment of Washington State’s Steelhead Populations and Programs Washington Department of Fish and Wildlife. Olympia, Washington

Abundance and Productivity

Abundance and productivity are two of the four VSP characteristics that determine the health of natural populations and opportunities for sustainable fishing opportunities.  Productive, accessible habitat is essential for the long-term viability and productivity of steelhead populations.

Findings and Recommendations:

•  The status of steelhead populations varies substantially across Washington.  Over 90% of the populations in the Olympic Peninsula region and over 60% in the Southwest Washington region were rated as “Healthy”.  However, less than 20% of the steelhead populations were rated as “Healthy” in the five remaining regions of Washington.  Yet, recent data does suggest some reason for optimism.  Possibly due to improved marine conditions, the average escapement for steelhead populations throughout Washington increased by 48% in the years 1999 through 2006 relative to the prior 5 years.  (Chapter 8)

•  Population viability analysis identified thirteen populations of steelhead with the potential for substantive conservation concerns.  The population viability analysis (PVA) conducted for this paper can be used as a tool to filter data and identify populations with a potential conservation concern.  However, additional information is needed to fully assess the risk of extirpation.  PVA can be misleading, particularly  where population structure is uncertain or, as in the case with this analysis, the potential contribution of rainbow trout to population performance was not considered.  (Chapter 8)

Recommendation.  Conduct Status Assessments.  Reassess the status of all populations in Washington on a 4 to 8 year cycle to assure that opportunities for early action are not missed.  Use population viability analysis (PVA) to filter spawner abundance data and, for populations identified to have a potential conservation concern, broaden the analysis to evaluate the contribution of rainbow trout to population viability, the previous performance of the population, and factors affecting population status.  (Chapter 8)

Recommendation.  Formalize Assessment of At-Risk Populations.  Annually  monitor and review the status of populations at risk, identify limiting factors, and assess the effectiveness of management actions.  Recommend and implement new programs to address limiting factors, and potentially initiate

“rescue programs” like kelt reconditioning, natural stream channel rearing, or hatchery supplementation to conserve natural populations until limiting factors are addressed.  (Chapter 8)

•  The inability to monitor the escapement of populations introduces significant uncertainty and risk into the management of steelhead in Washington.  The status of 47% of the steelhead populations could not be rated because of the lack of a time series of escapement or other abundance data.  (Chapter 8)

Recommendation.  Improve Escapement Monitoring.  Prioritize monitoring, solicit funding, develop alternative estimation methods and sample designs, and enlist the assistance of other organizations to increase the percentage of populations assessed on a regular basis.  (Chapter 8)

Historic Abundance    Current Abundance    Average Decline

Grays Harbor (8 Rivers)

5,424                       17,993                  68%

Columbia River Mouth (6 Rivers)

13,706                       2,326                 56%

Southwest Washington (14 Rivers)    62%

Lower Columbia River Winter Steelhead (13 Rivers)

26,228                        5,218                73%

Lower Columbia Summer Steelhead (4 Rivers)

5,016                          2,412                 53%

LCR Winter and Summer (17 Rivers)  69%

Mid-Columbia Steelhead (6 Rivers)

100,409                      4,075                   87%

Upper Columbia Steelhead (4 Rivers)

18,838                           553                   98%   

Snake River Steelhead (4 Rivers)

 28,713                        1,910                    84%

Puget Sound

No data

Olympic Peninsula

No data

Bill McMillan’s assessment of these tables

            The “pre-settlement” steelhead numbers indicated in the 2008 WDFW estimates are clear indications of lack of research into available fishery history with a resulting example of what has been termed the shifting baseline syndrome.    As an example, in 1895 the Grays Harbor weight of steelhead canned was 395,479 pounds which at 8 pounds per winter steelhead (in the ballpark of what the average steelhead was at that time as indicated in the earliest literature) would represent 49,435 steelhead harvested alone.  If harvest was 50% of run-size it would mean a run-size of 100,000 steelhead to the Grays Harbor system of streams.  If harvest was 70% of run-size it would be 70,621 steelhead.  This does not take into account the thousands of steelhead that were used for subsistence, fertilizer, and to feed livestock by the settlers of the region which in Puget Sound was estimated in an 1895 U.S. Fish Commission report to be equal to all the commercial steelhead catch that year on the Stillaguamish River.  This was further confirmed as likely the case from other historic sources.  It also does not include the tribal subsistence fisheries at that time.  From the historic catch data of 1895 the probable realistic range of numbers of steelhead returning to the Grays Harbor system would have been 140,000-200,000 steelhead.

            The WDFW pre-settlement estimated run-size for the Grays Harbor systems is 17,993 steelhead, or 36% of what the reported commercial catch alone was in 1895.  WDFW indicates that the present wild steelhead run-size of the Grays Harbor systems is 5,424 steelhead and represents 68% loss of that at the pre-settlement period.  In fact, that estimate of 5,424 steelhead is 2.7-3.9% of what the wild steelhead run-size range more likely was at the time of 1895 at Grays Harbor, or 96.1-97.3% loss of former wild steelhead numbers.  This is consistent with the steelhead losses found by Gayeski et al. 2011 for the Nooksack, Skagit, Stillaguamish, Snohomish, and remainder of Puget Sound streams that have occurred since 1895. 

            As another example, in the winter of 1953-54 the Queets River of the Olympic Peninsula had a reported tribal catch alone of 13,182 wild winter-run steelhead.  In 1923 a cannery was in operation on the Queets River with 72,000 pounds of canned steelhead packed that would have represented 240,000 pounds of live steelhead if there was 70% wastage as can potentially occur.  Queets steelhead were found to average 9.8 pounds in the tribal catch of the 1930s and 1940s, somewhat larger average than typical for Puget Sound.  The 1923 cannery pack would have represented 24,490 wild steelhead.  If the cannery pack was 50% of the run-size some 48,980 steelhead returned to the Queets that year.  This does not include tribal subsistence catch or that of settlers in the area and is therefore very conservative.

            Wind River in the USFWS surveys of the Columbia River basin during the 1930s was estimated to have sufficient available gravel for about 15,000 spawning salmon based on the size of the average Chinook salmon redd (larger than that for steelhead).  At that time the only fish that had access to the majority of Wind River basin that is above Shepard Falls was summer-run steelhead.  That estimate of Wind River productivity based on available spawning gravel did not include Trout Creek basin now known to be one of the major producers of steelhead.  Therefore the 1930s estimate was conservative.  In 1951 it was estimated that Wind River had an escapement of 2,500 wild summer-run steelhead after a sport harvest of 7,500 pounds, or about 1,000 steelhead for a total of 3,500.  By 1951 Wind River was already in great steelhead decline, and the 1951 return had yet to benefit significantly from removal of the Carson Lumber Company mill dam near today’s Cannavina Road that had denied upstream passage since at least the 1930s to the majority of the best mainstem Wind River spawning habitat.  How WDFW came up with a pre-settlement run-size figure of 2,404 wild summer-run steelhead to Wind River is difficult to determine. 

            Regarding the Eastside streams the estimates are not as far off as for the Westside.  Nevertheless, they have commonly been low-balled.  As one example, Idaho’s Clearwater River as late as 1960 had an escapement of 45,000 wild summer-run steelhead past Lewiston Dam.  This was after the impacts of the commercial fishery in the lower Columbia, Columbia River sport fisheries, and the Snake River sport fishery.  It was long ago noticed in 1895 and 1896 U.S. Fish Commission reports that salmon and steelhead returns to the Columbia and Snake basins had collapsed since 1883 and that the last large returns were in 1878.  1960 was long after these known collapses.   Based on the 1960 steelhead numbers that remained, 19^th century Clearwater run-sizes of wild steelhead in the 200,000 range are realistic.  The Clearwater basin provides a low end measure of what the Yakima basin may have once provided.  Nevertheless, estimates based more on available spawning gravel as one relatively easy habitat measure of productivity may in the future provide estimates of more scientific justification – both historically and at present. 

            These are just a few examples of how WDFW and other Northwest fishery managers have low-balled wild steelhead and salmon productivity prior to habitat alterations and subsequent hatchery impacts.  This is precisely what Daniel Pauly came to term the “shifting baseline syndrome” in 1995 as a worldwide fishery phenomenon that denies the ability to prevent a continuous decline in both salt and fresh water fish populations and similarly prevents recovery as we progressively downgrade fish productivity by using faulty historic baselines.

Rebuilding Oregon Coastal Coho Salmon

Oregon Coastal Coho Recovery Is Beginning

To begin the rebuilding of wild coho salmon, a threatened species, the harvest rate has been reduced by 87% and hatchery coho salmon releases are reduced by 95%. The resulting rebuilding is approaching the abundance of wild spawning adult coho salmon that were in coastal rivers in the 1950s.  However, in the 1950s wild coho abundance was already depleted by harvest, hatchery and habitat abuse over the preceding 100 years or more.  Consequently, the status of wild coho in Oregon coastal streams is a fraction of their historic abundance, and using the abundance of wild coho in the 1950s as the goal for rebuilding and recovery would be relying on a shifting baseline in order to describe success. 

Managing For Failure Over The Last 135 Years

Quantifying Pacific Salmon Extinctions and Loss of Diversity

In 1991 Nehlsen et al. completed an analysis of Pacific salmon and steelhead losses in the western United States and its publication started a firestorm of controversy because for the first time the failure of fish management was made evident to the citizens in the states of California, Idaho, Oregon and Washington. 

A recent assessment by the National Marine Fisheries Service Northwest Science Center (Gustafson et al. 2007) builds on the Nehlsen et al. work by providing an estimate of extinction and loss of diversity in Pacific salmon.   They point out that salmonids that have a stream maturing life history are “much more vulnerable to anthropogenic (human caused) threats” and compiled a separate extinction data for the two types of salmonids (stream maturing and ocean maturing species).  The salmonids that exhibit the stream type life history are spring chinook, coho and summer steelhead.

According to the authors before Euro-American contact there were nearly 1,400 Pacific salmon populations historically occurring in the study area from southern California to the Canadian border including the upper Columbia River in British Columbia. Based on their study, they listed the number of species that remain and those that have gone extinct. Below I present the total numbers, leaving out the ecological regions that define this list of extinct and extant populations, but show the extant populations and (extinct) populations.

Steelhead            436 (131), extinct 23%

Chinook              237 (159), extinct 40%

Sockeye               38   (34), extinct 47%

Coho                  135   (50), extinct 27%

Chum                   89    (23), extinct 21 %

Pink                     42    (  9), extinct 18 %

Total                     977 (406), extinct 29%

“Nearly 1,400 Pacific salmon populations historically occurred in the study area, and an estimated 29% have gone extinct since substantial Euro-American contact.” The authors say that overall, the six species no longer occur in about one-third of the 6 ecological regions they once occupied in this study.

“The estimated proportion of extinct historical populations was relatively low in coastal drainages from Vancouver Island to northern California  (20%), but increased dramatically in southern California (31%), the California Central Valley (57%), and the interior Columbia River Basin (35-62% in areas still accessible to Pacific salmon).  All historical anadromous populations were extirpated from the Upper Snake River and Columbia River headwaters regions following installation of impassable dams.”

“Extinctions were also non-random with respect to species and major maturation types.  Coho salmon once occupied a range almost as large as that of chinook salmon and steelhead, which historically occupied all ecological regions, but native coho salmon populations have disappeared from large portions of California and the Columbia River Basin.  Coho salmon may be particularly at risk due to their lengthy (greater than one year) juvenile freshwater residence where they are exposed to freshwater habitat alterations) and a nearly fixed three-year life cycle (providing less of a buffer against year-class failure than most other salmon species).”

“Stream-maturing steelhead (summer steelhead) had significantly more proportional population losses than ocean-maturing steelhead (winter steelhead), and stream-maturing chinook salmon (spring and summer chinook) had a significantly higher proportion of population losses than ocean-maturing chinook (fall and winter chinook).  High losses of stream-maturing populations are likely due to widespread loss of crucial high elevation (generally 500 m) holding habitats and to their vulnerability during prespawning holding period.”

“The loss of major genetic groups (27%) was nearly as high as extirpation from ecological regions (33%), but the loss of major life history types was less extensive (an estimated 15%) and perhaps confined to two species (chum and coho salmon).”

“Estimated number of stream and ocean maturing steelhead and chinook salmon populations that are extinct in the study area.

Steelhead (stream maturing)        Total Extinctions in Study Area:    54 populations, 31% of populations.

Steelhead (ocean maturing)          Total Extinctions in Study Area:    77 populations, 19% of populations

Chinook (stream maturing)           Total Extinctions in Study Area:    124 populations, 19% of populations

Chinook (ocean maturing)             Total Extinctions in Study Area:    35 populations, 21% of populations.

Extinction of Ecological (33 populations), life history (15 populations), and genetic diversity (27 populations) of Pacific salmonids was also estimated.”

The authors say, “Our analysis indicated that Pacific salmon in this region retain substantial evolvability as demonstrated by the persistence of over two-thirds of historical populations…it is apparent that to preserve biodiversity at multiple scales in wild Pacific salmon, both the local population and its habitat (freshwater and marine) must become the basic unit of conservation.”

“Because over one-third of the remaining populations belong to threatened or endangered species listed under the U.S. Endangered Species Act, it is apparent that a critical juncture has been reached in efforts to preserve what remains of Pacific salmon diversity.”

The historical decline in wild salmonids, with 29% of these populations now extinct and losses in the diversity of existing populations over the last 135 years of salmon management constitutes a failure of management by any measure.

Gustafuson, Robin Waples, Rick, Jim Myers, Laurie Weitkamp, G.J. Bryant, Orlay Johnson, and Jeff Hard. 2007. Pacific salmon extinctions: quantifying lost and remaining diversity. Conservation Biology (4): 1009-1020.

NATIVE FISH SOCIETY IS THE WAY FORWARD FOR NATIVE WILD SALMONIDS

The Native Fish Society has an important mission that others believe in and support. We are making progress.  I have worked in native fish conservation for more than 40 years and have spent time with legislators in my constant effort to strengthen and fund conservation.  Senator Jan Wyers responded in the 1980s by funding five native fish conservation positions at ODFW.  It was though that program that key people were hired and important work for Oregon’s wild salmonids was accomplished.  In 2012 the legislature is again concerned about the future of wild salmonids as more and more populations are  protected under the ESA and others are lost forever.  The NFS Hatchery Accountability Project clearly states that there needs to be better accountability for biological and cost impacts of hatchery programs. There have been two hearings this session and in the next session our goal is to hold the agency accountable. 

At one time it was possible to expect administrative solutions to problems affecting native fish management by government agencies, but that has changed, so legal action is necessary to force the government  to follow its own rules and comply with state and federal law.  This is why we have put ODFW on notice to clean-up its Sandy Hatchery program so that wild winter steelhead, coho, fall chinook and spring chinook are protected and a path is opened up for their recovery under the ESA.   A 76% stray rate of hatchery spring chinook into the wild chinook spawning grounds is not acceptable under state or federal rules and it needs to be corrected. 

We are in Stevenson Washington tonight defending the management program for recovery of wild summer steelhead in Wind River.  This run has been protected as a wild steelhead management river since 1982, but there is local pressure for a stock and kill fishery.  We are involved in these public meetings to make sure that the Wind River wild summer steelhead continue to rebuild and eventually recover.

The NFS is working for wild salmon, steelhead and trout throughout the Northwest through direct action and by supporting the good work of other groups.  Our volunteer river stewards are working in their communities for healthy watersheds and native fish.  It is a big job and for a small organization and it can seem wild and wooly, but we are undaunted in our efforts and we have a record of success when we take time to look in the rear-view mirror. 

I am committed to the future of the Native Fish Society because it is an effective advocate for native wild fish in the Northwest.  We base our advocacy on the best available science and there is a lot of it being published that has direct bearing on our conservation work.  We have a history of success but we could do better with more funding and more folks to push our advocacy program forward.  The point is that as we grow our funding base we do so without sacrificing our mission for native wild fish.   The organization and its leadership have made that commitment and with the support of our members and friends we can be successful in solving complex and difficult problems for wild native fish in the region. 

Making Hatcheries More Accountable

Summary Comment

By Bill Bakke

For the Senate Environment and Natural Resource Committee

Oregon Legislature

January 18, 2012

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The accumulated evidence from both scientific and economic analysis over the last 130 years shows that salmon and steelhead are declining and that management investments have failed to mitigate for the loss and have been unable to recover the diversity, productivity, and abundance of wild salmonids in Oregon and the Northwest ecosystems that support them.  This evidence suggests that our response and our investments to curb this decline are not working.  They are not working because we are more concerned about hatchery production than with restoring the productivity and resilience of salmonid populations adapted to individual watersheds. 

The solution appears to be deceptively simple, but it isn’t because the institutions we fund with public money and rely upon to solve complex problems of salmon and steelhead recovery and watershed productivity have not been held accountable for their performance. 

The Legislature can help solve this problem by directing the Oregon Department of Fish and Wildlife to enlist the aid of the Department of Administrative Services to contract for a risk and benefit assessment of the fish propagation program by an independent outside source with the necessary expertise to do the work.  Funding for this assessment is currently available in surpluses to ODFW’s Commercial Fish Fund and Other Fund accounts.  It is appropriate that fishing interests, who are the direct beneficiaries of the hatchery program, be the ones to pay for the cost of assessing the benefits and risks of the hatchery program.

The Legislature should also add a performance measure for the agency that would establish a process to assure the Legislature that ODFW is complying with the recommendations that come out of this assessment of the hatchery program.

These actions are needed because the evidence points out these facts:

1. Salmon and steelhead are 3 to 5 percent of their historic abundance
2. Many populations are threatened with extinction and under federal protection
3. Hatchery fish survival is only about 10% of that for wild salmonids with a range of 6-45 percent
4. Hatchery fish contribute to the decline of wild salmonids
5. Many if not most hatchery programs are deficit spending programs
6. Hatchery productivity and cost effectiveness rely on having access to wild stocks
7. As hatchery costs increase and benefits decline funding will become a more critical problem
8. Continuing the conflict between hatchery performance and cost with wild salmonid productivity and recovery will continue to have a substantial impact on Oregon’s fishing economy  

HATCHERY SALMON AND STEELHEAD WASTE HABITAT

HATCHERY FISH WASTE HABITAT

“In the Clackamas River basin, the summer steelhead hatchery adults had poor reproductive success; fewer smolts were produced per parent than in the wild population, and almost no offspring of hatchery fish survived to adulthood (Kostow et al. 2003). The hatchery program was meant to provide a sport fishery, and the production of adult offspring was not intended. If successful hatchery reproduction had occurred, at least the offspring could have contributed to fisheries. Instead, the hatchery fish wasted basin capacity by occupying habitat and depressing wild production while producing nothing useful themselves. It is not unusual for hatchery adults to have poor reproductive success when they spawn naturally (other examples are provided by Reisenbichler and Rubin 1999, Kostow 2004, and McLean et al. 2004). The combined effect of poor hatchery fish fitness and depressed wild fish production due to competition with the hatchery fish poses a double jeopardy that could quickly erode natural production in any system.” 

Kostow & Zhou (2006) page 839:

Not only do hatchery fish waste habitat, making it less productive than it would be with wild salmon and steelhead spawners, the investments made in habitat restoration are also wasted when the habitat is over-run with naturally spawning hatchery fish.  When the benefits of habitat restoration are calculated the impact of hatchery fish on those benefits is never included. Habitat restoration is based on the dual premise that it improves the productivity of wild salmonids and that it is cost effective. It is also assumed that habitat is limiting in all cases and that to increase the production of wild salmonids habitat investment is necessary.  Because habitat restoration is typically not done within the context of fishery management by government agencies such factors as harvest and hatchery impacts are not addressed and the limitations these actions impose on the success of habitat investment is not acknowledged, evaluated and monitored.  

It is important that habitat restoration serves the fish, improves watershed productivity and benefits other wildlife and not become an official deception.  Habitat restoration should not be used by agencies to escape their accountability to protect wild salmonids and the healthy watersheds they require to be self-sustaining.

Hatchery Impacts on Wild Salmon and Steelhead

The following summary is my attempt to provide each of my readers with a well documented list of impacts that hatcheries impose on wild salmonids.  This information will allow you to understand the hatchery reform needed to reduce impacts on wild salmonids.  In the Northwest fish management has embraced the hatchery option for over 130 years as a way to "mitigate" for watershed development at the expense of wild salmon and steelhead.  This approach has promoted the degradation of watersheds and is forcing the replacement of wild native stocks with artificially propagated fish that have reduced reproductive success and interfere with the health and productivity of wild salmonids.  What is missing in the Northwest is a wild native salmonid conservation program that effectively protects wild salmonid productivity, identity, and abundance.

The listing of wild stocks under the federal ESA has resulted in little benefit to wild salmon and steelhead populations but it has justified $1 Billion in annual funding for salmon recovery.  The ESA has expanded the hatchery solution to wild salmon decline and the fish management agencies have been the primary beneficiaries of this annual flow of public tax dollars into the region.

It should be kept in mind that the primary goal of fish management agencies is not recovery of wild salmonids but to maintain an endless process of planning and the funding it provides.  The goal is process not conservation and recovery.  The only way that this perversion of the ESA will come to an end is when the wild salmon go extinct or are recovered.  Another way, of course, is causing the agencies to be accountable for their programs, actions and expenditures.  That requires oversight by government.  It takes an independent review to make the agency bosses uncomfortable.

The brief summary on the impacts of hatchery production below is focused on how hatcheries affect the viability of wild salmonids.  It needs to be expanded to include harvest reform measures, but it does capture the need to have minimum spawner abundance objectives that would be delivered by species for each watershed as purpose of harvest management.  These science based recommendations are sound and they can be done, but the fish managers are not comfortable applying science to their management, so progress will be resisted and defeated without a strong push by those interested in wild salmon and steelhead recovery.

HATCHERY SALMONID IMPACTS ON WILD SALMONIDS

By Bill Bakke

• Naturally spawning hatchery fish from long term hatchery cultivation produce 6-11% to the adult stage compared to wild fish. ( Leider et al. 1989, Araki et al 2006)

• In the first generation native broodstock hatchery fish (using wild steelhead for hatchery broodstock) the reproductive success of the hatchery fish spawning naturally in streams declines by 14% (males) and 2% (females) compared to wild fish spawning naturally in the river. (ISRP 2011)

• In later generations (second and third) the reproductive success of native broodstock hatchery steelhead spawning naturally in streams is 50% (males) lower and 77% (females) lower than naturally spawning wild fish. (ISRP 2011) 

• There is a genetic change in the hatchery steelhead that carries over to naturally produced progeny of hatchery-origin parents causing reduced reproductive fitness of wild-born descendants in the wild and the population fitness of subsequent generations. (Araki et al. 2009, ISRP 2011)

• In just 6 generations native broodstock hatchery steelhead reproductive success is 29% to 54% that of wild steelhead. (Berntson 2011)

• In order to maintain cost effective hatchery programs, access to healthy abundant wild steelhead populations is required. (Based on research by Araki et al. 2008)

• In order to protect and rebuild wild salmon and steelhead populations harvest targeted on hatchery fish must be regulated to protect wild spawner abundance, spawner abundance goals need to be adopted by species and watershed, hatchery transfers among watershed need to be eliminated, and naturally spawning hatchery fish need to be excluded from wild fish spawning areas. (Conclusions base on best available science)

• Impacts of hatchery fish on wild fish must be controlled so that competition for food and space for rearing juveniles in streams and the estuary support wild fish survival, predation and predator attraction by hatchery fish is controlled to protect survival of wild fish, and nutrient enrichment targets from natural spawning wild fish support and expand the productive capacity of the habitat. (Conclusion based on best available science)

• Competition between wild and hatchery fish spawning naturally in a common habitat can reduce the production of wild juveniles by 50% (Kostow  2004)

• The cost to produce a hatchery steelhead that contributes to the catch is $200 to over $400 per fish harvested.   Most hatchery programs funded with tax dollars are not cost effective, making the hatchery program vulnerable to loss of funding as hatcheries compete for funding with other social needs for available dollars. .  (Hans Radtke 2011, IEAB 2000)