Action Alert. Enviros to shut down our hatcheries-Need help!

[Fishnut]

Please forward this to everyone you know. Family and friends need to sign on. We need giant numbers of responses.

Attached is a letter at the bottom that you can cut and paste, then email to NOAA. We have been outgunned by a particular non profit that is in the works of shutting down all of our hatcheries through litigation.

Are we going to allow lawsuits to manage our fisheries. We have a nonprofit organization that has continually sued the state, and received grant money from them, trying to stop hatchery released fish. Hatcheries are mitigation for damns and habitat loss. Step back and think about this for a minute. These lawsuits are going to force us into Boldt 2. We have a treaty with the tribes to keep them in fish. When these lawsuits force the shutdown of our hatcheries, it will break our treaty agreement with the tribes. BOLDT 2 is now in the process of becoming reality.
This is happening in our world today. This paragraph is taken from the Reel News from April 2014. It is written by Darrel Ticehurst that worked with PFMC and recreational fishing. He is in California and has seen it turn upside down. It talks about the biggest threats to recreational fishing. Here is the first point.

1. Runaway Environmentalism
Yes, most of us consider ourselves to be environmentalists. We care about our heritage and want to leave it intact for our grandchildren. But these runaway enviro groups have long passed beyond those basic motivations. Environmentalism is now big business. They are raising huge amounts of funding to support their enormous staffs of lawyers and idealists lobbying at state and federal levels. And they are anti-fishing, whether commercial or recreational. Why? Because if they can magnify the crisis, overstress the current situation, they can raise more funds. Their contributors need to feel they are “doing good” so the runaway enviro movement feeds them the overstated and manufactured environmental crises they need to open their checkbooks. Overfishing is rampant on our Pacific Coast? Check. Never mind that the Pacific Fisheries Management Council (PFMC) has been intelligently managing overfishing for the past 15 years. Facts and science are only tools to be used for political advantage, not to save a resource.
Runaway environmentalism is here to stay and the science no longer matters. What matters to them is that they get a “win” and their next round of funding.

Cut and paste this letter below and sign it. Feel free to craft your own letter. The other group has already responded previously and had 2000 requests to not release these fish. They went uncontested. We have to go way beyond this count and please be cordial. They are on the pay to causing hatchery extinction.

Please submit them by email to on or before August 13 to:
EWShatcheriesEIS.wcr@noaa.gov

August 5, 2015

National Marine Fisheries Service
Sustainable Fisheries Division
510 Desmond Drive SE
Suite 103
Lacey, WA 98503

Subject: Early Winter Puget Sound Hatchery Steelhead HGMP EIS Scoping, Federal Register Notice RIN 0648-XE039, July 14,2015

The following are my comments in response to above Federal Register Notice (FRN).
As a concerned citizen and fisher of the state of Washington, we believe that hatcheries are not the problem causing the decline of our Steelhead in our river systems today. Our steelhead are in trouble from California to Alaska and this is not an isolated problem, but a coastwide problem.
Please allow no time extensions At a minimum, this means that there should be no extensions allowed on comment periods and no discretionary grants of additional time so that proponents can run to the courthouse and cause a delay, running the clock out.
Poor habitat causes take of fish every day. Currently, our warped idea of conservation translates into closing hatcheries and fisheries and doing nothing to address the degraded habitat which precludes salmon recovery.

Hatcheries can help rebuild natural populations or buffer impacts on natural populations, meet treaty fishing rights, and critically important tribal and non-tribal fisheries simply could not happen today without hatcheries.

We want to see the Published Final end date for EIS (Environmental Impact Statement) NEPA Record of decision, and final ESA decision be on or before March 1. This allows time for litigation and the release of the smolts in a timely manner.
Please dedicate all of your resources to these particular EWS HGMPs so to meet the timeframe and not run the clock out on this program. We have wasted the last two years of broodstock and if this third year brood stock is lost, it will kill this program for ever.

For the alternatives you asked for , we would like to see an alternative added to the list:
Please use added alternative #5 below, with alternative #2 as a second choice
Please add Alternative 5: Increasing annual early winter hatchery production to one million or more smolts. This is to ensure fair consideration of a full range of possible alternatives and to recognize that marine and freshwater habitats are continuing to decline such that increased hatchery production will be necessary to compensate.

Sincerely,
Name
(Your Organization if affiliated)
Address
Phone
E-mail

[Fishnut]

More talking points

Additional talking points not directly applicable to these comments (but maybe for later?)

• Hatcheries are required for salmon recovery and harvest as mitigation for habitat damage; yet, these hatcheries, built to make up for lost fish because of damaged habitat, are increasingly under attack, while the condition of habitat continues to worsen and goes unchecked due to inadequate habitat protections, climate change, and other environmental and ecological factors (such as climate change, or pinniped predation) that have nothing to do with hatcheries or harvest
• The fact that these programs were developed as mitigation for lost habitat and resultant natural salmon and steelhead production is well documented and very clear to everyone including myself
• Because of the ongoing habitat loss, we have been forced to become more and more dependent on hatcheries to provide any steelhead or salmon for our fisheries – today, the vast majority of our harvest is dependent on hatchery fish, including all the steelhead caught in recreational fisheries that are the subject of this evaluation
• Funding for hatcheries continues to be cut from crippled budgets that have already resulted in significant hatchery closures and reductions – in just the past six years alone, the Washington Department of Fisheries has cut more than 50 million dollars from its budget, much of it from hatchery production
• Meanwhile, greatly worsening effects from climate change are causing more and more harm to steelhead and salmon throughout their life cycle (use example of the current drought to emphasize that these effects, heaped on top of already depleted freshwater and marine habitat, are causing the vast majority of the problem/99% of the problem and something Has to change)!
• That something is the share of the conservation burden not being carried by habitat
• Chief opponents mainly just want all of the hatcheries to be shut down (and the alternatives as initially presented by NOAA Fisheries only offer this same failed remedy), yet, if wild fish continue to disappear primarily as a result of lost habitat and hatcheries are reduced or closed, there won’t be any fishing, or ANY fish left the fact that these programs were developed as mitigation for lost habitat and resultant natural salmon and steelhead production is well documented and very clear to everyone including myself
• Comanagers have greatly reduced harvest of wild stocks and have significantly changed hatchery programs to reduce wild stock impacts
• Hatchery programs, and recreational and commercial harvest programs that depend on them, are well managed/the tribes and state operate safe, responsible hatchery programs that are guided by the best available science and we will need these programs for as long as habitat continues to limit production from our watersheds
• NOAA Fisheries’ NEPA and ESA risk assessments should support hatchery and harvest programs that employ best management practices
• If simply eliminating hatcheries and harvest was the solution, we would have accomplished natural stock rebuilding a long time ago. Though these programs have been crippled and greatly curtailed or eliminated in many instances, the stocks have not rebounded and are declining at a faster rate than ever because habitat quantity and quality drives steelhead and salmon health. We have lost more steelhead and salmon due to disappearing habitat than have ever been harvested or lost due to hatchery effects
• These hatchery programs support the economy and way of life for all Washingtonians, and the current climate of litigation, hatchery closures, and reductions has harmed all of the citizens of Washington State. NOAA Fisheries must do a better job in this EIS to recognize the importance of harvest to all constituencies, the economy, and the northwest way of life
• The burden of conservation must be better shared by habitat if we ever going to recover steelhead or salmon and state and tribal hatcheries and fishers have been carrying most of the weight for far too long/or, and we/I have been carrying…..
• NOAA Fisheries must adequately clarify interactions between habitat, natural production and hatchery production in the EIS for early winter steelhead hatchery programs and their relative cumulative effects and
• Hatchery programs, where severely depleted fish populations exist due to degraded habitat conditions, should be managed appropriately for all factors affecting viability and not solely on hatchery effects. Until these populations are healthy, these hatchery programs are essential and must not be reduced or eliminated - all this will lead to is no fish whatsoever
• Habitat is the cause, the mitigation, and the solution to recovering our imperiled steelhead and salmon populations, not any further devastating cuts to hatchery and harvest programs and NOAA Fisheries’ NEPA and ESA risk assessments must consider all factors affecting priority salmon populations, not just Tribal and State hatchery and harvest programs
• Hatcheries can help rebuild natural populations or buffer impacts on natural populations, meet treaty fishing rights, and critically important tribal and non-tribal fisheries simply could not happen today without hatcheries.
• Hatcheries help recreational fishers and tribes pass on the culture of fishing between generations, preserve the icon of our state, and the important values and treaty rights that depend on them, affecting all citizens
• Hatchery fish are used daily in management to assess the status of natural populations through marking, tagging tracking studies, etc, e.g., Indicator Stocks, or, related to the marine mammal predation problem: Recent radiotagging and tracking studies show that >80% of WILD juvenile steelhead die in Puget Sound before they reach the ocean
• As already presented in the scoping, the DEIS suggests that the only options to benefit conservation are through reduced hatchery production. This is ludicrous! There are other actions that can actually achieve conservation benefits that don't include reduced production.
• In general, the DEIS scoping has a very negative connotation to it (i.e. issues, concerns, impacts) that already sets the tone for the scoping that the actions themselves are harmful and destructive, while ignorig the immense benefits.

So what is the best way to move forward?
• Adjust parts of some programs, possibly (in very few cases)... but if at all, do it based on rational thinking, not rapid reaction to lawsuits
• Base considerations on hatchery, harvest AND especially, HABITAT.
• No closures, injunctions, or reductions before NEPA and ESA processes are COMPLETED, which is unfair a illegal
• Use the comanagement process at all stages. It’s the law anyway - - -
• State and Tribes must work, and are working, together to prevent 3rd Parties from subverting the process any more than they have already done
• Tribes and sport fishers are weighing in on NEPA and ESA consultations this time around to let everyone know who the majority is in Washington State
• TOGETHER, the State, Tribes, and the Federal Government must vigorously fight any future injunctions that would threaten to unfairly eliminate these programs through attrition even before they have been evaluated
• While it is highly likely, or it should be anyway based on the best available science, that the final decision by NOAA Fisheries on these hatchery programs may result in a no jeopardy determination, for ALL of the proposed early winter steelhead hatchery programs, but if yet another injunction is unfairly allowed before the facts are in, they will be killed anyway, and that will not be acceptable and will only trigger additional litigation
• I think each watershed should have its own balance of natural and hatchery production, based on the needs of treaty and non-tribal fisheries, tailored to its own needs based on the unique habitat conditions, the specific hatchery practices, and the status of the hatchery and natural populations and the robustness of the watershed’s natural production potential
• Hatchery programs that is based on habitat condition & coordinated with habitat restoration & protection
• The only approach that will lead to long-term sustainable salmon and steelhead resource, and the only way this NEPA evaluation can begin to adequately encompass the scope of possible and realistic alternatives, is to integrate all of the “H’s” into the effects analysis of the proposed alternatives. The programs do not occur in isolation and their evaluation must recognize the cumulative effects of all of the actions on steelhead viability, which is NOAA Fisheries’ responsibility under the ESA anyway

[Sandlance]

Excellent write-up. I would suggest that this e-mail also go to Senator Patty Murray and Senator Cantwell. However, they will likely not respond - it's an election year coming up. Unfortunately, NOAA may not respond - they already dragged this out for two years and essentially eliminated future hatchery operations for winter steelhead on a number of Puget Sound streams. A full blown EIS process can take many years and the track record for NOAA so far is "delay the process as long as it takes". For many fisheries, this is a tactic that has been used over and over -delay the process as long as you can and either the program (i.e., hatchery production) or the fishermen fade away and give up. For example, winter-run steelhead fishing was allowed below the Lake Washington locks. They eventually closed it due to low returns, but with the premise that runs would be built up and the fishery would once again flourish. This was about 20 or 30 years ago. Today - still closed. Same for Sammamish Slough - still closed. Same for Sauk and Skagit (I believe) - closed.
Many staff people in WDFW work hard to both improve habitat and try to keep the hatcheries going (e.g., this year's drought has been a huge challenge). This is really commendable. However, now that WDFW has provided no real resistance (my opinion) to the Wild Fish Conservancy on winter steelhead in some Puget Sound streams, there is no reserve system left to even hold on to the current winter-run steelhead runs for those hatcheries affected (i.e., no plants/no returns/no broodstock - particularly if any wild fish are hit hard with the drought conditions).
Fishermen generally support harvestable populations based on wild fish, as long as they have the opportunity to catch one once in a while. They also support protections for wild fish (e.g., limited seasons, barbless hooks, mark/selective fisheries). Some species such as chums, pinks, and coho currently do fairly well supporting harvestable numbers of wild fish in some streams. However, steelhead and Chinook appear to be more challenging. It is really unfortunate that the WDFW and NOAA abruptly eliminated the winter-run steelhead hatcheries releases on those streams affected. There should have been a much better longer termed plan (as you indicate) that balances the return of habitat (it may not be possible in many areas) with hatchery releases until if and when the habitat returns.
You are probably also correct in predicting that the abrupt elimination (i.e., no phasing out over time as wild fish returns increase) of winter-run steelhead is not the last step - Chinook and other species are likely next. All fishermen that want to have their sport continue for salmon or steelhead should send the e-mail as soon as possible.