THA JouErnal Pu blOished byS the SPteelheRad ComEmittee Y International Federation of Fly Fishers SM

Dedicated to the Preservation of Wild Steelhead • Issue No. 81 MAY 2015 Faith in Nature: The Missing Element in Salmon Management and Mitigation Programs by Jim Lichatowich and Richard N. Williams — Alder Fork Consulting and The College of Idaho —

Jim Lichatowich provides fisheries ing on salmon management and recov - Columbia River Federal Power sys - consulting services through his firm ery in the Pacific Northwest during the tem, the preparation of which was Alder Fork Consulting in Columbia 90s believed that the ESA listings imposed by the ESA, has been rejected City, Oregon and is former Assistant would shake the foundation of salmon by the courts four times and the most Chief of Fisheries for the Oregon recent one may be on the way to a fifth Department of Fish and Wildlife. The salmon crisis has rejection. The recovery prescriptions Richard N. Williams, PhD has worked in the BiOps have been too close to the on Columbia River salmon and steel - failed to cause status quo for the courts to take the head issues for over 30 years. He is the proposed solutions seriously. Senior Conservation Advisor to the introspection and The status of salmon remains a crisis. International Federation of Fly Fishers There is no other way to view the list - and is a member of the Steelhead critique by salmon ings under ESA. Unfortunately, howev - Committee. He lives in Eagle Idaho. er, it is a crisis that has failed to cause Both authors have served on numer - managers of what led introspection and critique by salmon ous salmon management technical managers of the record leading up to panels. to the ESA listings. the listings. This failure is, in part, due to impediments to the incorporation of he 1990s were a calamitous management enough to change the sta - current science into salmon manage - period for salmon and steel - tus quo. We were wrong. ESA rules ment and mitigation programs head management. The cen - intended to improve the salmon’s sta - (Lichatowich and Williams 2009), a tury-long decline in abun - tus were bureaucratized, ritualized general lack of historical perspective dance reached alarming and normalized to the point that they among salmon managers (Pauly 1995), lTevels leading to the listings of twenty- and to a pathology resulting from a became part of the status quo, result - eight Evolutionarily Significant Units ing in little real change. Case in Point: command and control approach to (ESU) 1 under the federal Endangered the Biological Opinion (BiOp) for the salmon management (Holling and Species Act (ESA). Many of us work - Continued on Page 4

FAITH IN CHAIR’S CORNER: STEELHEAD & A MCKENZIE RIVER VICTORIES ON THE IN THIS NATURE KINDRED SPIRITS WARMING CLIMATE WILD CHINOOK EAST FORK LEWIS — PAGE 1 — — PAGE 3 — — PAGE 9 — — PAGE 13 — — PAGE 17 — ISSUE: 2 MAY 2015 THE OSPREY • ISSUE NO. 81 FROM THE PERCH — EDITOR’S MESSAGE Believing in Nature’s Bounty by Jim Yuskavitch THE OSPChRair EY Norm Ploss very wild fish advocate is have rejected the idea that Nature can well aware of how histori - supply enough fish on its own to sup - Editor cally abundant salmon and port prosperous fisheries, may be Jim Yuskavitch steelhead once were. They unaware of how many fish the rivers crowded the rivers during they manage once produced and rely Contributing Editors sEpawning runs and easily supported almost solely on the technical fix of sustainable fisheries for Native hatcheries. To make matters worse, Pete Soverel • Bill Redman American tribes along with commer - that view and philosophy tends to be Doug Schaad • Norm Ploss cial fishermen and sport anglers. And passed down through generations of William Atlas • Schuyler Dunphy as every wild fish advocate also knows, salmon managers. Scott Hagen that incredible abundance is largely What is to be done? It won’t be easy Contributors gone and river systems that once pro - to convince salmon managers that they Jim Lichatowich • Richard N. Williams duced many thousands of fish may now continue to rely on a flawed conceptual Norm Ploss • Lisa Crozier produce just hundreds, or dozens, and foundation, and hatcheries in particu - in too many cases, none at all. lar. But there are examples out there, Michelle McClure • Dave Thomas But that is not because Nature is no such as Osoyoos Lake sockeye recov - Arlen Thomason • Steve Jones longer capable of producing abun - ery, that don’t rely on traditional mod - Layout dance, as Jim Lichatowich and Rick els that should stimulate a rethink of Jim Yuskavitch Williams observe in their important how we can again return natural abun - cover story in this issue of The Osprey . dance to our salmon and steelhead Letters To The Editor It is because many salmon managers streams. The Osprey welcomes submissions and letters to the editor. Submissions may be Visit The Osprey on the Web at: made electronically or by mail. The Osprey www.ospreysteelhead.org P.O. Box 1228 Sisters, OR 97759-1228 [email protected] The Osprey Blog: (541) 549-8914 www.ospreysteelheadnews.blogspot.com The Osprey is a publication of The International Federation of Fly Fishers and is published three times a year. All Join the International materials are copyrighted and require Federation of Fly Fishers permission prior to reprinting or other Invest in the future of “all fish, all waters,” with a use. The Osprey © 2015 membership in the IFFF — a nonprofit ISSN 2334-4075 organization. Your membership helps make us a stronger advocate for the sport you love! The International Federation of Fly Fishers is a unique non-profit organization con - cerned with sport fishing and fisheries International Federation of Fly Fishers Your membership The International Federation of Fly Fishers (IFFF) 5237 US Hwy 89 South, Suite 11 includes a subscription supports conservation of all fish in all waters. IFFF has a Livingston, MT 59047-9176 to Flyfisher, the long standing commitment to magazine of IFFF. solving fisheries problems at the grass roots. By charter and incli - nation, IFFF is organized from ❑ Name ______the bottom up; each of its 360+ SM $35 Individual clubs, all over North America ❑ Address ______and the world, is a unique and $15 Youth (under 18) self-directed group. The grass ❑ City ______State _____ roots focus reflects the reality $25 Senior (65 and older) Zip ______Phone______that most fisheries solutions ❑ must come at that local level. $45 Family E-Mail ______❑ Join by phone at 406-222-9369 Payment Enclosed THE OSPREY IS PRINTED ON RECYCLED PAPER or www.fedflyfishers.org USING SOY INK THE OSPREY • ISSUE NO. 81 MAY 2015 3 Kindred Spirits CHAIR’S CORNER

by Norm Ploss — Chair, Steelhead Committee —

efore and since my hip Drought. “Gov. Jerry Brown’s decision demands for scarce water resources) replacement I’ve had plen - to require 25 percent mandatory urban and based on expert judgment”, the ty of time to follow a broad conservation while ignoring agricul - authors “assessed the most likely spectrum of news. This ture — which consumes 80 percent of future of wild salmon runs in the comes to me naturally by developed water supply — has been Central Valley in 2100.” They “posed tBraining and personal interest. Some of widely criticized. But most people seven open-ended questions to senior that news relates directly to fisheries barely are aware that the heaviest bur - salmon science and policy experts in and some relates importantly but tan - den to conserve water is on our federal and state agencies; local, gentially. Good news is out there some - beloved San Francisco Bay estuary — regional, and national organizations; where, but negative news is easy to and as a result the Bay may experience non-governmental organizations; and find: a wave of species extinctions in the universities. With a promise of com - coming months and years.” plete and permanent anonymity, these • New twist to the Chambers Creek experts provided answers. Most [Washington] Steelhead story. NMFS is experts concluded that by 2100 wild moving from a Draft EIS (years in salmon in the Central Valley will be progress) backwards to a Draft EA. extirpated or minimally abundant if Fish conservation advocates argue current trends continue.” that only through the process of com - pleting a full EIS can NOAA adequate - • A bill has been introduced in the ly evaluate the cumulative effects of House of Representatives that would all Puget Sound hatchery programs on amend the Magnuson-Stevens Act in threatened and endangered species detrimental ways. The act governs including Puget Sound's wild steel - marine fisheries management in the head. United States. Representative Don Young (R-Alaska) introduced H.R. • Steelhead Summit Alliance re: Skagit President Theodore Roosevelt and natu - 1335, the misleadingly named River. April 18th meeting at the ralist John Muir at Yosemite Valley, “Strengthening Fishing Communities University of Washington. The Skagit, California in 1903. and Increasing Flexibility in Fisheries once home to returns of 100,000 wild Management Act,” which would steelhead and a favorite destination • An article by a pair of authors from reverse years of progress made in US for many anglers, has been reduced to Oregon State University published in fisheries management. less than four percent of its historical San Francisco Estuary & Watershed abundance, as described by biologist Science [13(1)]. Forecasting the Most • Lastly as I get to the point of this col - Nick Gayeski of the Wild Fish Likely Status of Wild Salmon in the umn, the articles in this current issue Conservancy. Yet according to California Central Valley in 2100 . of The Osprey , without subtlety, high - Gayeski, the river has lost only a third “Since the mid-1800s the light the perilous conditions wild of its productive habitat since the Sacramento–San Joaquin river system salmon and steelhead today as we face early 19th century. "Prospects and in the California Central Valley has the future. potential for recovery are not as grim experienced a dramatic decline in the as you might think," he said. Many distribution and abundance of wild Often enough, I encounter environ - speakers hoped that with a settlement- salmon, along with many extirpations. mental situations or groups working on mandated cessation of hatchery plants The causes of the decline are many, an issue that looks insurmountable. into the Skagit River for the next 12 and have been well studied. Despite Almost every time, I recall a (c.1980s) years, the river's wild fish might have restoration efforts spanning decades visit to the Gray Lodge Wildlife Area a chance at unhindered recovery. and involving large expenditures, runs in California’s Sacramento Valley. Enough, so that the reopening of a sus - of wild salmon in the Central Valley Gray Lodge is primarily a waterfowl tainable winter catch-and-release continue to decline. Using the most refuge and seasonal hunting area and angling season may happen. probable policy and ecological scenar - also contained formerly abundant pop - ios (i.e. effects of continued harvest, ulations of wild pheasants. At the • An opinion piece in the San Francisco continued stocking from hatcheries, Check Station, I picked up a standalone Chronicle on April 20th. Don’t ignore changing climate, continued human reprint of an article from the Sierra San Francisco Bays Needs during the population growth and associated Continued on page 19 4 MAY 2015 THE OSPREY • ISSUE NO. 81

Faith in Nature Chinook and sockeye salmon in recent mines how problems are defined and Continued from page 1 years the total run has remained below the range of appropriate solutions. It is the Council’s modest goal. a powerful part of any management or Meffe 1996). These shortcomings have Since 1989, the Council’s mitigation mitigation program; yet it is rarely left managers ill prepared to deal with program included independent scien - acknowledged or critically evaluated the crisis and have actually caused a tific review and evaluation. The (Lichatowich et.al. 2006). The Council retreat into the status quo and the poli - review panel created in 1989 has had a and the ISG rightly believed an exami - cies that are responsible for the succession of three names: Scientific nation of the conceptual foundation of salmon’s impoverishment. In this Review Group (SRG) 1989 – 1994, the the FWP was warranted. essay, we explore this conundrum Independent Scientific Group (ISG) The ISG completed its work on the through an examination of the nexus of 1994 – 1995 and the Independent FWP’s conceptual foundation in 1996 a flawed conceptual foundation and the Scientific Advisory Board (ISAB) 1995 and published a summary of its report problem of shifting baselines. Our to the present. While the group’s name to the Council in Fisheries Magazine focus is on the Columbia River where, changed several times, up until about (Williams et al. 1999). We quote from for thirty-two years, a massive fish Williams et al. (1999): “We conclude and wildlife mitigation program has that management of the Columbia been underway. The authors have a Fisheries managers River and its salmonid populations has combined 29 years of service on inde - have at best a weak been based on the belief that natural pendent science panels working in ecological processes comprising a association with that mitigation pro - understanding of the healthy salmonid ecosystem can, to a gram. large degree, be replaced, circumvent - history of their ed, simplified, and controlled by Background humans while production is main - profession and the tained or even enhanced.” The ISG In 1980, the U. S. Congress passed the then identified three global assump - Pacific Northwest Electric Power former magnitude of tions that form the FWP’s conceptual Planning and Conservation Act (Power foundation. Act), which did three things of signifi - pristine abundance. 1. “The number of adult salmon and cance for the Columbia Basin’s salmon. steelhead recruited is primarily a pos - itive response to the number of smolts It created the Northwest Power and 2000, its membership and its assign - produced. This assumes that human- Conservation Council (Council), a ment to provide scientific evaluation induced losses of production capacity quasi-governmental entity composed of the Council’s FWP was largely can be mitigated by actions to increase of two members from Montana, Idaho, unchanged. In 1996, the Power Act was the number of smolts that reach the Washington, and Oregon and directed amended to create the Independent ocean, for example, through barging, it to work toward greater parity Scientific Review Panel (ISRP), which the use of passage technology at dams, between salmon conservation and was given the task of providing annual and hatchery production.” hydroelectric power production. The peer review of individual projects pro - 2. “Salmon and steelhead production Power Act also directed the Council to posed for funding within the frame - can be maintained or increased by develop a fish and wildlife program work of the FWP. The ISAB and the focusing management primarily on in- (FWP) to mitigate fish and wildlife ISRP are still performing scientific basin components of the Columbia losses due to the operation of the evaluation of the FWP and the individ - River. Estuary and Ocean conditions basin’s hydroelectric system (Willis et ual projects associated with it. al. 2006). The first FWP was released are ignored because they are largely in 1982 and it has gone through a series uncontrollable.” of revisions since then. The FWP has The FWP’s Conceptual 3. “Salmon species can effectively be been called the world’s largest ecosys - Foundation managed independently of one anoth - tem restoration program (Lee 1993). er. Management actions designed to The Council estimated the size of the In 1995, the Council asked the protect or restore one species or popu - predevelopment annual run of salmon Independent Science Group (ISG) to lation will not compromise environ - in the Columbia River at ten to fifteen review the conceptual foundation mental attributes that form the basis million fish. Then it set a modest miti - underlying salmon mitigation efforts for production by another species or gation goal of five million salmon in the basin — a project that the ISG population (Williams et al. 1999).” (Williams et al. 2006) amounting to a had independently started a couple The ISG then concluded: “After doubling of the average run size of two years earlier, but was not able to give it reviewing the science behind salmon and a half million fish in the early the attention it deserved. restoration and the persistent trends 1980s. In the thirty-two years since What is a conceptual foundation as of declining abundance of Columbia release of the first FWP and after a the ISG understood and defined it? It River salmon, we concluded that the total expenditure of about fifteen bil - is the set of principles, assumptions, FWP’s implied conceptual foundation lion dollars, adult salmon production and possibly myths that give direction did not reflect the latest scientific has not reached the goal of five million to management and research activi - understanding of ecosystem science of fish. Even with the large runs of fall ties. The conceptual foundation deter - Continued on next page THE OSPREY • ISSUE NO. 81 MAY 2015 5 Continued from previous page salmonid restoration” (Williams et al. 1A 1B 1999). The three assumptions describe a highly simplified salmon production system and the extensive use of tech - nology. Natural resource managers often simplify the resource they are overseeing to the commodity that can be derived from it such as number of fish harvested, logs, amount of water diverted for irrigation, and so on. In the simplified system, the commodi - ty’s abundance is the primary measure of management’s performance. This reduces the amount and complexity of information needed to “manage” and at 1C 1D the same time gives the illusion of con - trol and predictability over the produc - tion of commodities (Holling and Meffe 1996; Bottom 1997; Scott 1998). In salmon management, the sense of control is enhanced by the ease with which salmon can be artificially propa - gated in hatcheries. The Council, recognizing inadequa - cies in its early versions of the FWP (NPPC 1994), released a revised plan in 1994 that included ecological elements consistent with current science as well as elements consistent with the con - Figure 1. Shifting Baselines shown by Columbia River salmon and steelhead harvest of ceptual foundation described above. four different time periods (a-d) starting with 1991 ESA Listings. Note shaded boxes incor- The Council coordinates the develop - porate the previous graph into the next longer time series. Years of harvest are shown with ment of the recovery plans, but it can harvest in pounds (x 1000) on the Y axis in each graph. only recommend, not dictate, which dations, even one with serious flaws, to Here is a brief description of the syn - parts of the plan are implemented. influence decisions. drome. As each generation of fisheries Salmon mangers actually determine Why would managers implementing biologists enters the profession, it con - implementation of the FWP through a salmon mitigation program that siders the status of fish stocks at that their selection of projects and the pro - expends well over a hundred million time as the baseline, the standard posals they submit for funding. The dollars annually cling to a flawed con - against which progress or lack of it is managers chose to implement those ceptual foundation? We believe an to be measured. In the case of a declin - parts of the 1994 plan that were consis - important part of the answer lies in the ing fishery, this leads to a gradual tent with the familiar, but flawed con - concept of shifting baselines — and downward shift in the baseline as each ceptual foundation. Consequently their their consequences! generation of young biologists enters selection of projects focused primarily the profession and ultimately to the on artificial propagation and fish pas - Shifting Baselines impoverishment of the fishery, as can sage. They largely ignored those parts be seen in Columbia River Harvest of the plan based on current ecological Fisheries managers have at best a data from 1865-2000 (Figure 1). The science including protecting biodiver - weak understanding of the history of insidious feature of this process is that sity and creating native salmon and their profession (Smith 1994). They are the warning signs on the way to impov - steelhead refuge watersheds. In its also largely unaware of the magnitude erishment largely go unnoticed review of the suite of projects actually of the difference between the pristine (Roberts 2007). implemented, the ISRP noted that, abundance of important fish stocks Harvest trends in Columbia River “There is a noticeable discrepancy and their current status. In recent salmon (Figure 1a and 1b) in recent between the mix of projects actually years, several authors have tried to years show the low abundance of popu - funded and the ISRP’s interpretation correct this deficiency, but its persis - lations through the 1990s with rebuild - of the intent and priorities of the tence has created and maintained the ing starting in 1999. Examining har - [1994] FWP” (ISRP 1997). By their shifting baseline syndrome (Pauly vest trends over a longer time series selection of projects, managers clearly 1995; Roberts 2007; Jackson et al. 2011; (Figure 1c and 1d) helps put the very showed the power of conceptual foun - Bolster 2012). Continued on next page 6 MAY 2015 THE OSPREY • ISSUE NO. 81

Continued from previous page problem. Because we don’t know the ally lead to practices that attempt to historical produc - maintain those populations in their tivity of salmon in impoverished state (Roberts 2007). the smaller eco- The shifting baseline syndrome clear - 67,500 Snake River Spring/Summer regions of ly hides the magnitude of the decline m

a 60,000 Chinook ESU Columbia River in a fishery by ignoring longer-term D Basin, we fail to historical records and consequently, e t i 52,500

n understand and the magnitude of management’s fail -

a 2A r appreciate the ure. A shifted baseline allows the peri -

G 45,000

r latent productivity odic occurrence of “record runs” that

e 5-Year Geomean

w 37,500 that can be are actually a small fraction of the o Natural Origin Fish L released when real, historical baseline (Lichatowich

30,000

@ environmental and 2013). Since the magnitude of manage -

h human caused con - ment’s failure is hidden, there is little s i 15,000

F straints are incentive for critical review or change

n i reduced or elimi - in the status quo. Failed management

g 15,000 i r nated. We have, practices are continued as in the exam - O

l 7,500 however, had snap - ple of the Council’s 1994 plan a r

u shots of that capac - described above. t a ity in 1991-1993, The nexus between a shifting base - N 1962 1968 1974 1980 1986 1992 1998 2004 and 1999-2004, line and a flawed conceptual founda - when a combina - tion has another important conse - tion of high smolt quence. If the managers falsely production (most - believe that the impoverished state of ly hatchery ori - the salmon when they entered the pro - 8000 Upper Columbia gin), and favor - fession is the baseline, it will cause

7000 Spring Chinook ESU able environmen - them to conclude that natural produc - tal conditions in tion cannot be expected to make a sig - the river and nificant contribution to the existing 6000 2B ocean resulted in fisheries and satisfy the growing Total Natural Origin Fish large runs of demand from an expanding population. h

s 5000 i 5-Year Geomean salmon and steel - We have, while serving on independent F

n head (Figure 2). scientific review panels, frequently i g

i 4000

r Managers have heard managers claim that natural O

viewed these production cannot sustain a fishery. l a

r 3000 spikes in abun - This belief persists even though histor - u t

a dance as evi - ically, natural production sustained

N 2000 dence that the harvest levels that have never been artificial produc - equaled by artificial propagation. We 1000 tion system for characterize this attitude on the part of salmon is work - salmon managers as a loss of “faith in

0 ing. A few politi - nature.” It is an attitude that helps 1979 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 cians have gone ensure that a flawed conceptual foun - as far as to dation and its failed mitigation prac - declare salmon tices will persist. It’s a self-reinforcing recovery efforts strategy. The loss of faith in nature Figure 2. Returns of natural origin (a) Snake River Spring/Summer successful. That justifies the reliance on hatcheries to Chinook, 1962 – 2005, showing a sharp increase and decrease interpretation is boost the number of salmon. The between 1999-2005 and (b) Columbia River Spring Chinook, 1979 consistent with weight of evidence now supports the – 2003, showing a sharp increase and decrease in 2001. the conceptual conclusion that those hatcheries are modest gains achieved in recent years foundation. Unfortunately, it misses contributing to diminished productivi - into perspective compared to histori - the larger lesson, which is that salmon ty of natural production, which rein - cal abundance. The longer trendlines and steelhead have an innate ability to forces the lack of faith in natural pro - also underscore how depressed cur - respond rapidly to favorable ecologi - duction (Chilcote et al. 2011; Christie et rent populations are compared to his - cal conditions. This is even more true al. 2011; Araki et al.2007a; Araki et al. torical abundance. Shifting baselines of wild fish than for hatchery fish. 2007b; Kostow and Zhou 2006). causes us (inadvertently) to overlook If a generation of salmon managers historical records and see current views already impoverished popula - Discussion modest successes as something more tions of salmon as the baseline against than they actually are. which the performance of their mitiga - We discuss two examples of recent Shifting baselines cause another tion programs is measured, it can actu - Continued on next page THE OSPREY • ISSUE NO. 81 MAY 2015 7

Continued from previous page (Kahler 2013). The success started with studies of the Osoyoos sock - eye’s life history and the identifi - benefitting cation of ecological factors that limit survival during the part of their life cycle spent above Wells Dam. In 1999, following a review of the capacity of spawning habi - tat, the sockeye escapement tar - get was increased from 38, 900 to 58, 730 spawners with provision to increase to 135, 471 (McMillian 2013). This in itself showed a con - siderable faith in nature. Then a Fish-Water Management Tool (FWMT) was developed. The FWMT is a decision support model that helped managers reduce density independent mor - tality on eggs and fry. The FWMT was also used by managers to help reduce oxygen depletion and tem - perature constraints on juvenile rearing habitat. Once the FWMT was implemented in water year Figure 3. Abundance of Okanagan/Osoyoos Lake Sockeye, 1977-2014, showing the dramatic 2005, smolt production jumped increase in recent years. Figure courtesy Bill McMillan from an average three hundred salmon recovery programs. One illus - increase in natural production of thousand a year to three million with a trates a strong faith in nature and Osoyoos sockeye salmon. Improved high of over eight million (Kahler shows why its loss is not justified. The survival passing the main stem dams 2013). other illustrates that the loss of faith in and improved ocean conditions were The FWMT shows how technology nature can lead to bizarre decisions. factors, but they couldn’t have been was used to inform management and the main cause, because if they were, boost Osoyoos sockeye runs. In this Okanagan River/Osoyoos it would have led to dramatic increases example, technology (the FWMT) was Lake Sockeye in other salmon populations. Instead, it embedded in a conceptual foundation appears the main causative factor was based on the salmon’s natural life his - a “non-traditional mitigation measure” The Columbia River sockeye salmon Continued on next page followed the general trend in declining abundance of the other salmon species in the basin. The commercial fishery for sockeye was terminated in 1972. Number of Number of Restoration The average run over the 35 years fol - River Dams Anadromous Habitat Focus lowing the closure of the fishery was Salmon about 72 thousand fish. In 2008, the Okanagan River/Osoyoos Lake sock - eye (Osoyoos) underwent a dramatic increase in abundance with 213, 607 fish crossing Bonneville Dam. This Major higher level of productivity has contin - Osoyoos 9 1 restoration Natural ued through 2014 with 614, 179 sockeye effort though production counted at Bonneville (Figure 3). The FWMT Osoyoos sockeye made up about 80 percent of the counts of sockeye salmon over Bonneville dam and most Major hatchery of the Osoyoos sockeye crossing 8 (5 sp Pacific Pristine habi - program Bonneville Dam are wild. Hatchery Elwha 0 salmon, steelhead, tat above old superimposed production makes up about 10 percent coastal cutthroat and dam sites on recovering of that run. Keep in mind that the bull trout natural Osoyoos sockeye spawn above nine production dams in the Columbia River. Several factors contributed to the Table 1. A comparison of the Osoyoos and Elwha salmon restoration programs. 8 MAY 2015 THE OSPREY • ISSUE NO. 81

Continued from previous page after the sediment lev - els drop to a normal tory and knowledge of the ecological range. In its review of constraints on survival. That approach the Elwha restoration focused on restoring ecosystem link - program the Hatchery ages and the sockeye’s inherent pro - Scientific Review ductive capacity instead of the more Group (HSRG) stated: conventional approach that circum - “The main concern the vents those linkages with artificial HSRG has with the propagation. It also required a strong Elwha Plan is the faith in nature (and the sockeye potential unintended salmon!) to go against conventional negative consequences wisdom and invest in an ecological of excessive and pro - approach above nine dams. longed hatchery influ - ence (HSRG 2012).“ The author Dylan The Elwha River Ecosystem Tomine summed up the Removal of the Elwha Dam offered a prime opportunity to Restoration Program situation on the Elwha let nature restore the Elwha River’s anadromous fish runs at a public meeting on instead of the same old hatchery model. Photo courtesy The removal of two large dams on the the Recovery Program. John R. McMillan, NOAA/NWFSC Elwha River in 2012-2014 has received He said “We have lost faith in Mother national attention. Those dams blocked shifting baselines shown in Figure 1 3 salmon migration to the upper basin Nature.” We agree! (Lichatowich et al. 1996). since early in the 20 th century. It is our conclusion that shifting base - Removal of the dams gives salmon Faith in Nature lines and a loss of faith in nature access to pristine habitat inside the allowed the false assumptions and the Olympic National Park. The circum - “And most important, only when gov - resulting flawed conceptual founda - stances in the Osoyoos and the Elwha ernments that typically ensure eco - tion to persist in spite of its record of restoration programs could not be nomic interests and values over all oth - failure. Successful salmon recovery more different (Table 1). ers decide that they are willing to re- programs that deviate from the cur - The removal of the Elwha dams giv - construct the human salmon relation - rent approaches, such as the Osoyoos, ing salmon access to pristine habitat ship as an ecological one rather than should cause the Council and salmon seems to establish a set of circum - an economic one will the true salmon managers throughout the region to stances that would not require a strong wars, the wars between society and the reexamine, once again, the underlying faith in nature to emphasize the recov - salmon be over.” (Scarce 2000). conceptual foundation of the FWP. ery of natural production. However, Perhaps with Osoyoos as an example of the recovery plan contains this state - If we go way back to the beginnings success and with a renewed faith in ment “This section introduces the use of salmon management by Euro- nature, managers may be willing to of artificial propagation for certain Americans, we would clearly see that reconsider the assumptions made so stocks as a primary (emphasis added) the conceptual foundation identified in long ago and move beyond their con - and effective means to meet plan Williams et al. 1999 and reproduced straints into a more ecological rela - preservation and restoration objec - earlier in this paper has its origins in a tionship with the salmon. tives. (Ward 2008)” 2 As a result, the few basic assumptions made by those recovery plan emphasizes the use of first managers. Salmon managers artificial propagation. We believe this today will often bristle at the sugges - emphasis is unwarranted and unneed - tion that their work is predicated on Citations: ed for the recovery of natural produc - assumptions made 130 years ago. But tion in the basin. Furthermore, the the assumption that the supply of 1 ESUs are the salmon equivalent to superimposition of a large hatchery salmon could be maintained if the nat - Distinct Population Segments (DPS) program will likely hinder the restora - ural production system was simplified commonly used in ESA listings and tion of natural production among the and controlled has been documented as recovery planning. Elwha’s diverse salmonid stocks. management’s initial conceptual foun - 2 Part of the recovery program dation (Lichatowich 1999). Over time, Page ix Elwha River Fish Restoration includes a new sixteen million dollar that conceptual foundation has been Plan hatchery. Part of its purpose is to pro - adjusted to reflect changes brought on 3 Tomine’s statement at the meeting vide a refuge for native salmon during by new technology and industrial was shown in the documentary film the expected high levels of sediment development in the Columbia Basin. Dam Nation . during dam removal operations; how - However, the basic assumption that ever, there is little doubt that the simplifying and controlling production hatchery will remain at full capacity remained the underpinning of salmon management through all the periods of THE OSPREY • ISSUE NO. 81 MAY 2015 9 Steelhead Persistence and Adaptation in a Warming World

By Lisa Crozier and Michelle McClure — NW Fisheries Science Center, NOAA Fisheries — Michelle McClure is currently the divi - endangered under the Endangered high, extending the time horizon fur - sion director for the Fishery Resource Species Act, and thus additional stress ther into the future when mean Analysis and Monitoring Division at from climate change poses a more omi - changes due to climate change will be the NW Fisheries Science Center nous challenge. How will steelhead detectable. (NOAA) in Seattle. She spent many respond to climate change? Our dis - Nonetheless, many climate models years conducting research and work - cussion complements a recent review project more extreme storm events in ing with policy makers on issues relat - of ocean stages by Kate Myers and the cool season, while drier summers ed to the recovery and conservation of Nate Mantua (“Climate Change and become the norm. Increased winter salmonids in the Columbia River Ocean Ecology of Northwest flooding and summer drought may thus Basin, and co-led the Interior Steelhead,” The Osprey , May 2013); we pose increasing threats to salmon Columbia River Technical Recovery here focus on climate impacts and freshwater stages. Team for salmon and steelhead. She responses expected in freshwater life How will these physical changes has been working on issues of climate stages. affect steelhead? Rising temperatures change related to endangered species, present the greatest direct risk for and is beginning to focus on marine populations that already experience species subject to harvest as well. Rising temperatures near-lethal summer temperatures. Lisa Crozier has worked in the Fish These include steelhead in warmer Ecology Division at the Northwest are the greatest risk streams in California, southern Fisheries Science Center since 2004. Columbia and Snake Rivers, and west - Her primary research goal since com - for fish populations ern Oregon. High temperatures limit ing to NWFSC is to quantify the effects survival of adult migrants, especially of climate change on population viabil - that already those that migrate long before spawn - ity of Pacific salmon, considering both ing, “summer-run” fish, and juveniles ecological and evolutionary responses experience near-lethal that typically spend one or more sum - over the full life cycle. She works most - mers in freshwater. ly on salmon in the Columbia and summer temperatures. More than other salmon, adult steel - Sacramento rivers. head in the Columbia River use cool Projected Climate-Induced tributaries as thermal refugia along their migration route. In general, the ith a geographic range Changes in Freshwater more time they spend in these refugia, that once extended as Habitats the lower their survival. Seeking head - far south as Baja, water tributaries in Idaho, however, is California, the broadest Rising year-round temperatures and also associated with lower survival. range of life histories shifts in hydrological regimes are the The primary reason thought to explain aWnd highest thermal tolerance of any these observations is that steelhead major climatic changes to freshwater Pacific salmon, Oncorhynchus mykiss that will impact salmon life history and concentrated in smaller refugia or is arguably the most diverse and individual fitness in the coming tributaries become more vulnerable to adaptable of the six Pacific salmon decades. Under a business-as-usual harvest. Importantly, even catch-and- species ( Oncorhynchus spp. ) native to carbon emissions scenario, air temper - release fishing causes far higher mor - the U.S. As climate change progresses atures in the Pacific Northwest are tality for salmon in warm conditions, and aquatic environments adjust, the expected to rise 2.3-9.2°F in winter and and females are more likely to die ecological and genetic diversity of 3.4-9.4°F in summer within the next 50 after handling than males. steelhead will likely prove decisive in years. Water temperatures will likely Exposure to high water temperatures facilitating this species’ persistence. warm at about 80% of the rate of air and low flow is often punctuated by Like other salmon, they excel at colo - temperature. Reduced snowpack at disease outbreaks, which can lead to nizing newly created habitat and higher elevations will also produce an dramatic fish kills. In 2002, roughly adapting locally to complicated earlier and smaller spring freshet. 70,000 Chinook salmon died in the dynamics. However, 11 out of 14 pop - Changes in precipitation are far less Klamath Basin when gill rot disease ulations of steelhead on the West Coast certain, and variability in historical flourished. The warm temperatures are already listed as threatened or precipitation has always been very Continued on next page 10 MAY 2015 THE OSPREY • ISSUE NO. 81

Continued from previous page sustain minimum functioning. The quences are highly site specific. optimal temperature for growth is In sum, most projections indicate and low flows caused by the combina - therefore higher in very productive that salmon habitat will decline with tion of a drought year and human environments with few fish and lower climate changes anticipated during the water diversion provided perfect con - in more nutrient-poor environments 21st century, although O. mykiss suf - ditions for the disease to spread quick - with higher density. Thus, a web of fers less than other salmon because ly and reach epidemic status. interactions affects juvenile steelhead they spawn in the spring. Despite this Warming can increase virulence of a physiology. general pattern of habitat decline variety of diseases by accelerating Winter water temperature also has across salmon species, growth will population growth rates and move - important ramifications. Food is likely improve in some cases, such as ment of disease agents. Disease trans - scarce in winter, placing a priority on warming of relatively cool habitat. mission among fish also increases minimizing energetic expenses over Similarly, streams with low flows tend when fish are tightly concentrated into prey capture. Shorter, warmer winters to improve with projections of limited pools. Furthermore, salmon could bring higher energetic costs and increased fall and winter rain, immune systems are compromised by higher mortality. Come spring, juve - although these projections are uncer - thermal stress. Thus high tempera - nile steelhead “determine” whether tain. tures and close concentrations of and when to smolt, based in large part Negative effects of warming often salmon are very strong predictors of on growth rates and lipid reserves. If appear in summer and winter, when high mortality. juveniles grow quickly enough to consumption cannot compensate for Sub-lethal temperatures are just as lower their mortality risk in the ocean, increased metabolic demands. important as lethal temperatures in but not so quickly that conditions in Reduced precipitation in summer shaping population response to climate freshwater favor skipping the ocean exacerbates the risks posed by change. Exposure of adults to sub- stage altogether, they will smolt. extremely low flows. Changes in lethal temperatures during migration Salmon are carried downstream by growth rate also affect the timing of may impair egg viability, either the spring freshet during their juve - vulnerability to predators such as through reduced egg provisioning or nile migration, and lower flows (result - bass, which are size selective. direct thermal stress in utero. ing from reduced snow accumulation A specific analysis of vulnerability Developmental temperatures can over winter) typically lead to lower for Pacific Northwest steelhead found affect skeletal and muscle morpholo - smolt survival. Migration timing also that populations in the southern part of gy, as well as fin position. However, plays an important role in smolt sur - the region face greater threats from the influence of temperature on rates vival, and will likely advance earlier in temperature, while those in the interi - of growth and development is perhaps the year with warmer, smaller and ear - or and northern parts will likely con - most important of all. lier spring flows. Ocean arrival timing front substantial flow changes. Metabolic rates increase exponen - profoundly influences marine survival; Unfortunately, many populations that tially as temperatures rise, affecting however, it is not clear whether already face severe conservation chal - development and energy balance at all changes in ocean conditions will shift lenges also face the greatest threats life stages. For example, in warmer the optimal arrival time. from climate change. water, fry emerge earlier and smaller, In mid-elevation basins, peak flows with smaller yolk reserves. These might shift from spring to winter, with Anthropogenic Stressors smaller reserves increase the urgency potential effects on egg survival, of switching to an external food supply growth, and migration timing. More in early winter or spring. Historically, The direction of these impacts is sim - intense storms in fall and winter are ilar to that of many anthropogenic natural selection has favored emer - likely and would result in floods of gence timing that matches the avail - effects already confronted by salmon greater magnitude and frequency dur - populations. Many habitat modifica - ability of food, leading to highly popu - ing these seasons. These drivers are lation-specific spawn timing. Changes tions raise stream temperature, expected to negatively influence fall- increase the intensity of flooding and in thermal regimes will alter both of spawning salmon and trout. However, these processes, potentially resulting reduce summer minimum flows. Loss rainbow trout and steelhead might be of shading from riparian vegetation in a mismatch between fish needs and better suited for this hydrological prey availability. This in turn will and interchange of flows between the regime because they spawn after win - channel and subsurface flows, for direct pressure on and possibly drive ter flooding. The effects on adult evolution in spawn timing. example, raise stream temperature. migration might be population-specif - Water that transits through the ground Once they reach the juvenile stage, ic, with access to spawning areas growth rates have an optimum temper - is cooler and more consistent than dependent on migration timing that is water exposed directly to radiative ature that reflects the trade-off appropriately matched to adequate between increased food consumption heating. flows for passing over physical barri - Barriers, armoring, and incised chan - and the acceleration of metabolic rates ers. In some cases, the current migra - at warmer temperatures. At warmer nels all reduce connectivity between tion timing might be less successful streams and their floodplain, limiting temperatures, food is usually more due to the new combination of thermal abundant; however, prey quality can the natural ability to maintain diverse stress during migration, low flows, and stream habitats that would otherwise also decline, and fish need more food to winter flooding. However, these conse - Continued on next page THE OSPREY • ISSUE NO. 81 MAY 2015 11

Continued from previous page strongly genetically determined, and of all individuals in a population. will likely require strong selection in Nonetheless, some examples of genet - provide refugia from high tempera - order to change. Nonetheless, O. ic change have been shown in migra - tures and flooding. Irrigation with - mykiss contains genetic variability for tion timing. drawals exacerbate low flows, leaving this trait, as shown by rapid laboratory Serendipitously, several decades ago some streams completely dry in sum - selection of rainbow trout with greatly researchers in Auke Bay, Alaska mer. enhanced heat tolerance. Similarly, inserted molecular markers into the Construction of dams and storage developmental sensitivity to tempera - genome of pink salmon to differentiate reservoirs for flow control and year- ture is generally considered to have between early and late modes of a nat - round power production has altered low plasticity, although exposure to urally migrating population. One both the thermal and hydrological warm temperatures during particular marker specifically identified the late regime of regulated rivers. These developmental windows has been migrants, while neutral markers effects are similar to climate change shown to alter these responses in some tracked levels of genetic drift in the effects in some cases, but opposite in fish. Like heat tolerance, developmen - population to separate natural selec - others. In the Columbia and Snake tal responses in O. mykiss have adapt - tion from random processes. Rivers, freshets are much smaller and ed locally to natural habitat hetero - Frequencies of these early vs. late peak earlier in the year than would geneity using genetic variation that migration markers have been indepen - occur in a free-flowing river. exists in many populations, and hence dently monitored for both odd- and Reservoirs typically increase sum - could theoretically evolve in response even-year populations of pink salmon mer temperatures by lengthening the to climate change. In fact, many traits since the 1970s. In both populations, time for equilibration between water the late-migration mode disappeared and air temperature, and increase in the early 1990s, coincident with transit time for smolts. However, The complexities of some unusually warm years in the some dams are managed to release stream. Loss of the molecular marker water that is cooler in summer and climate change make indicated that the entire late-migrant warmer in winter than a free flowing segment of the population had disap - river. Targeted releases of deep, cool it difficult to predict peared rather than their descendants water from stratified reservoirs such having shifted to an earlier migration as Dworshak Reservoir in Idaho can the rate of genetic (a plastic response). lower temperatures in some reaches. Migration timing, like most traits, These cases present opportunities for response to a changing incorporates both plastic and genetic mitigating some effects of climate components. In the Columbia River change. environment. basin, steelhead, sockeye, and Chinook salmon have also shifted their migra - Adapting to Climate Change: tion timing since the 1950s. Most adult Plasticity and Genetic involved with juvenile growth and sockeye and spring/summer Chinook development, age at smolting and age salmon stocks migrate prior to warm Change at maturity have successfully adapted summer temperatures, and they now in less than 30 generations to new habi - migrate earlier than in the 1950s. In response to all of these environ - tat after Chinook salmon were intro - Conversely, many fall Chinook and mental changes, organisms can alter duced in the southern hemisphere. steelhead stocks migrate after sum - their exposure or sensitivity to unfa - Although historically, genetic adapta - mer temperatures decrease, and they vorable conditions by changing behav - tion to local environments clearly has have shifted their migration date later ioral or physiological traits. occurred in nearly all traits, it is diffi - in the year. Both responses allow fish Phenotypic traits, such as migration cult to predict rates of response to to avoid peak temperatures in the timing or thermal tolerance vary in future climate change because of the mainstem, which now consistently how “plastic” they are. Plastic traits complex selection landscape in the hover over 20°C for much of the sum - change systematically with environ - wild. Many traits are tied together mer. mental conditions within the lifetime physiologically or temporally. For Later migration appears especially of an individual. This relationship is example, if you change migration tim - advantageous for steelhead adults called a “reaction norm.” Highly plas - ing, the subsequent life stage may face because it reduces the bioenergetic tic traits that have shifted quickly in a total different set of conditions. Our cost of holding over the entire winter. response to recent climatic changes predictive ability is further hampered This cost increases exponentially with include age at juvenile migration, because it is usually not possible to temperature, so a difference of even growth rate, size at age, seasonal tim - employ standard methods for demon - 1°C in mean temperature entails loss ing of adult migration and spawning, strating evolutionary change in of precious reserves that will not then and fecundity. response to recent climate change in be available for reproductive activity. Evolutionary adaptation, on the other salmonids, because we cannot directly In the Columbia River basin, these hand, reflects selection acting on a compare modern and ancestral popula - shifts are likely a plastic response to trait, and occurs over generations. tions under the same conditions, nor environmental cues used by individu - Thermal tolerance, for example, is can we usually identify the parentage Continued on next page 12 MAY 2015 THE OSPREY • ISSUE NO. 81 Continued from previous page all populations respond similarly to a Further reading given climate. Nonetheless, many of als to modulate their behavior, at least these swings do correlate with major Beechie, T., H. Imaki, J. Greene, A. in part. However, evidence from an changes in climate, from regime shifts Wade, H. Wu, G. Pess, P. Roni, J. analysis of sockeye salmon migration of the Pacific Decadal Oscillation to the Kimball, J. Stanford, P. Kiffney, and N. survival suggests that selection may Little Ice Age. Generally, warmer cli - Mantua. 2013. Restoring salmon habi - have acted on these populations as mates have been less favorable for tat for a changing climate. River well. salmon, demonstrating limits in the Research and Applications 29:939-960. Selection has acted by shifting the ability to compensate for climate reaction norm for migration timing change. Crozier, L. G., A. P. Hendry, P. W. over the past 60 years. Steelhead and These impacts are similar in direc - Lawson, T. P. Quinn, N. J. Mantua, J. other salmonids have been well served tion to many anthropogenic impacts Battin, R. G. Shaw, and R. B. Huey. by a combination of genetic and plastic already confronted by salmon. On the 2008. Potential responses to climate responses that have allowed them to plus side, the similarity between change in organisms with complex life occupy diverse habitats and condi - anthropogenic and climate change histories: Evolution and plasticity in tions. They can respond quickly to impacts provides an advantage: Pacific salmon. Evolutionary changes in the environment, but natur - restoration to mitigate anthropogenic Applications 1:252-270. al selection refines the response over impacts can also lessen many impacts time. Thus evolution and plasticity act of climate change. Tim Beechie and his Dalton, M. M., P. W. Mote, and A. K. together to shape the behaviors that colleagues have laid out a clear frame - Snover. 2013. Climate change in the support anadromy in Pacific salmon work for conducting restoration to mit - Northwest: Implications for our land - and that allow them to respond to a igate for climate change. Their guide - scapes, waters, and communities . changing world. lines for conservation prioritize Washington, DC: Island Press. However, populations must persist in restoring natural processes that keep order to adapt. A primary concern waters cool and habitats diverse. Katz, J., P. B. Moyle, R. M. Quinones, J. regarding modern climate change is Restoration of these processes will Israel, and S. Purdy. 2013. Impending that depressed populations may lack require maintenance of natural flow extinction of salmon, steelhead, and sufficient genetic variation to provide regimes, reconnection of streams with trout (Salmonidae) in California . the raw material for rapid evolution. their floodplains, and expansion of Environmental Biology of Fishes This would mean salmon populations riparian vegetation. 96:1169-1186. are closer to going extinct in response Like other salmon, adult steelhead to strong selection or chance events can be most vulnerable when they seek NorWest. Regional Database and simply because they have a smaller thermal refuge in deep pools or head - Modeled Stream Temperatures. starting point. Thus, a process that water tributaries. Fish hold in these http://www.fs.fed.us/rm/boise/AWAE/p might have eventually produced a bet - pools and are relatively easy to catch rojects/NorWeST.html. ter-adapted phenotype could die out during such periods. Even if released before it has time to spread within or after catch, steelhead and other Wade, A. A., T. J. Beechie, E. among populations. Nonetheless, in salmonids experience high rates of Fleishman, N. J. Mantua, H. Wu, J. S. natural populations, some traits have mortality after handling. Thus, protec - Kimball, D. M. Stoms, and J. A. already adapted in response to recent tion of thermal refugia in general and Stanford. 2013. Steelhead vulnerability climate change. from fishing in particular is a key com - to climate change in the Pacific ponent of preserving a successful sum - Northwest. Journal of Applied Ecology What Can We Do? mer-run life cycle. 50:1093-1104 Steelhead face many challenges in In summary, the major climatic the coming years as temperatures con - Web Resources change to the freshwater environment tinue to rise, stream flows change, and that will impact steelhead in the com - humans demand more of limited fresh - http://www.nwfsc.noaa.gov/assets/4/81 ing decades is rising temperature. water. The odds of persistence for this 53_09302014_105020_Crozier-Lit-Rev- Risk of increased mortality is greatest species are enhanced by a natural abil - Climate-Change-BIOP-2013.pdf in summer, but shifts in flow regime ity to adapt to variable environments. may increase winter flows and storm However, to foster this resilience, we http://www.nwfsc.noaa.gov/trt/index.cf intensities, resulting in decreased must ensure that populations remain m snowpack with an earlier spring abundant and that heterogeneous habi - freshet and lower minimum flows. tats remain accessible to the greatest http://www.nwfsc.noaa.gov/research/di Despite the high adaptability and extent possible. visions/fe/wpg/ecosystem_processes/cl flexibility of steelhead, long histories imate_change.cfm of salmon abundance from the paleo - logical record and historical documen - http://www.nwfsc.noaa.gov/research/di tation reveal large swings in popula - visions/fe/estuarine/oeip/jb-climate- tion size over time. Not all of these scale-phys-varia.cfm fluctuations are climate-driven, nor do THE OSPREY • ISSUE NO. 81 MAY 2015 13 McKenzie River Chinook Salmon: A Legacy Population in Peril

By Dave Thomas and Arlen Thomason — McKenzie Flyfishers —

David Thomas is a member of the itself shrunk to an alarmingly small and freshwater harvest in the lower McKenzie Flyfishers and for 60 years a size, recently recording an all-time Columbia River during the early years, committed fly fisher, conservationist low. The “last best hope” for saving it’s known that those rates were often and nature photographer. Trained as a UWB Chinook salmon from complete extremely high, requiring strict regu - population biologist and biostatisti - extinction is in serious danger. How we lations to avoid extirpation of the cian, he taught at the University of got to this point and what is being done entire Columbia River salmon run. California and later was a researcher or could be done to reverse this trend Nevertheless, at that time it was pro - at NIH and in the pharmaceutical is the subject of the remainder of this posed that the McKenzie River could industry. article. The usual suspects—habitat, potentially still support up to 80,000 Arlen Thomason is Conservation harvest, hatcheries, and hydropower— spawning Chinook. However, between Chair for the McKenzie Flyfishers, and all play their roles. 1942 and 1969, a series of dams were is an author, outdoor photographer, and The McKenzie River begins high in constructed in the Willamette Basin, life-long fisherman. He trained as a the extensive lava field aquifer of the creating barriers to substantial pro - molecular biologist and worked for central Oregon Cascades and tumbles portions of spawning habitat. Three many years in biomedical research. west for 90 miles through a National dams were constructed on the You can learn more about the Wild and Scenic River corridor to its McKenzie River — Blue River Dam, McKenzie Flyfishers at: https://mcken - confluence with the Willamette River Cougar Dam and Trail Bridge Dam — zieflyfishers.wordpress.com resulting in the loss of approximately 22% of potential spawning habitat. he Willamette River origi - The wild McKenzie Along with the wild population of nates in the Cascade McKenzie Chinook salmon, the Oregon Mountains and drains most River Chinook Department of Fish and Wildlife of northwest Oregon, join - (ODFW) or its precursors have main - ing the Columbia River near population is the most tained a hatchery stocking program on PTortland. The tributary rivers of the the river since 1907. Prior to World Upper Willamette River Basin (UWB) genetically intact in War II the Chinook hatchery program have supported a spring run of followed a practice of blocking the Chinook salmon ( O.tshawytscha ) since the Upper Willamette entire salmon run in the lower river to long before humans arrived. The stock allow the collection of eggs and milt. is assumed to have evolved its early River basin. Today this practice would be consid - seasonal run timing in response to the ered astounding; however at the time, need to pass the Willamette Falls near fishery managers assumed that all fish Oregon City when there was sufficient near Springfield. The river drains a of one species were essentially inter - flow. It has been estimated that in the basin of 1,340 square miles and is fed changeable and could be replaced or Nineteenth Century, Chinook escape - by several major tributaries, most reassigned as Man found it convenient. ment in the basin could have numbered notably the South Fork, which is 30 At the same time, hatcheries were con - 275,000, with approximately 40% miles long and historically provided sidered more efficient at producing returning to spawn in the McKenzie prime spawning habitat. Like the rest fish equivalent to those spawned in River subbasin. Since then, the wild of the basin, the McKenzie subbasin nature. Thus it was thought that hatch - Chinook population has decreased dra - saw substantial anthropogenic envi - ery spawning was a boon both to the matically, with only two of seven sub - ronmental (habitat) degradation dur - fish and to those who benefited from basin populations still considered ing the late Nineteenth and early their harvest. Today we know differ - viable. Of those two, the McKenzie Twentieth centuries. By the late 1940s, ently about the true effects of hatch - River population is by far the an estimated 46,000 spring Chinook eries, a subject we will come back to strongest, remaining the best hope for returned to the McKenzie River. Part below. recovery of UWB Chinook salmon, and of this reduction was certainly due to From 1945 to 1960 an average of it has been designated a “legacy” or habitat degradation and water 18,000 returning Chinook on the “stronghold” population by fishery removal, particularly in the developed McKenzie River was observed, with a managers. That fact notwithstanding, lower river. And though there is little high of about 46,000. However the con - or no exact documentation of the ocean the McKenzie Chinook population has Continued on next page 14 MAY 2015 THE OSPREY • ISSUE NO. 81

Continued from previous page ued to decline from the post-WW II evidence of a positive effect on wild baseline. The estimate for 1990-2005 Chinook salmon recovery. On the con - dition of the river changed substantial - was an average 2,104 wild Chinook trary, the fishery science literature ly with the initiation of the Upper returning annually. Most of the blame has increasingly demonstrated that in Willamette Project managed by the for the continuing decline has focused most instances interaction between Army Corps of Engineers (COE). This on the dams. However, while there is hatchery-origin and naturally-spawned project was intended to provide flood little doubt that the dams have con - anadromous fish exert strong negative control, irrigation support, hydropow - tributed, they block access to only effects upon the wild fish population. er, and recreation opportunities in the about 20% of the potential spawning As the evidence has accumulated, Willamette Basin. The project ulti - habitat in the McKenzie basin, failing attention of the scientific and conser - mately resulted in the construction of to completely explain the approxi - vation communities has progressively 13 dams, starting in 1942 and complet - mately eight-fold decline in the wild turned to the likelihood that hatchery ed in 1969. In the McKenzie River two salmon population. Still, as dams were operations are a major contributor to dams, Blue River Dam on Blue River the most visible change and very like - the demise of wild populations. (Araki (1969) and Cougar Dam on the South ly had some impact, they seem to have and Schmidt 2010) Such harmful Fork McKenzie (1963), were construct - become the preferred culprit. As a effects were already well known by ed. In addition, Trail Bridge Dam result, the COE and the State of 1999. In that year, as the number of (1963) blocked the mainstem of the Oregon agreed that as mitigation, the McKenzie Chinook dropped below river for fish passage at river mile 82. federal government would support 1,500 spawners, the National Oceanic The latter dam was constructed by a McKenzie Hatchery production of and Atmospheric Administration local utility company and is intended to about 840,000 smolts, based on the (NOAA) listed the spring Chinook provide power to the metropolitan area number of returning salmon that the salmon in the entire Upper Willamette downstream. The same utility also dammed rivers were assumed to have Basin as threatened under the owns Leaburg Dam on the McKenzie otherwise contributed. The COE main - Endangered Species Act (ESA) and River, three miles east of the town of tains ownership of the hatchery, which designated the spring Chinook salmon Leaburg. It was built in 1929 to divert is managed under contract by ODFW. an Evolutionarily Significant Unit water from the river’s mainstem to a The number of Chinook smolts (ESU) of their species. Following list - hydropower plant. The water is subse - released in the McKenzie River from ing, the agencies (in this case the COE, quently returned to the river down - this hatchery averaged about 1,200,000 Bonneville Power Authority (BPA) and stream. As the dam is of low height and annually from 1990 to 2011, with Department of Reclamation) responsi - has a functioning fish ladder it is not ODFW funding production of the ble for managing the species were considered a serious impediment to excess over 840,000. required to provide a Biological fish passage. In total, these dams Despite the concept that hatchery Assessment (BA) of the status of the denied fish passage to about 40 miles output was intended to “supplement” species, factors contributing to its of potential Chinook spawning habitat. the native spawning Chinook numbers being threatened, and corrective After dam construction was complet - in addition to mitigating lost angling actions that will lead to the species’ ed the number of naturally spawning opportunity, there has been little or no recovery. This document was prepared Chinook in the McKenzie River contin - and sent to the section of NOAA that oversees these issues, the National Marine Fisheries Service (NMFS), which has the authority to approve programs or require changes it judges as “prudent and necessary” to improve the situation. Beyond the BA, a hatch - ery program that could harm the listed ESU requires submission and approval of a Hatchery Genetic Management Plan (HGMP) that defines the bound - aries of the program, and describes actions that will be taken to assure that there are no effects that are signifi - cantly detrimental to recovery of the wild stock. Further, NMFS regulations require systematic monitoring of the status of the listed species or stocks so that trends, positive or negative, can be identified and the consequences of actions determined. Thus COE submit - ted a BA and draft HGMP to NMFS for A wild spring Chinook salmon on spawning beds in the upper McKenzie River, review and comment. A program for Oregon. Photo by Jim Yuskavitch Continued on next page THE OSPREY • ISSUE NO. 81 MAY 2015 15

Continued from previous page unacceptably high. The number of wild infeasible. Further, the dates set by the Chinook continued a downward trend. 2008 BiOp for downstream passage of systematic monitoring of the status of On the administrative side, NMFS had fish spawning above Cougar Dam had Chinook salmon in the basin was put in not accepted the originally submitted come and gone; and the program for place and executed by ODFW under BA, and there was no HGMP agreed to incorporating native spawned Chinook contract with the COE. by all the participating parties. into the hatchery broodstock was not As a result of this lack of progress, in being followed. The key issues specific to the 2007 the Willamette Riverkeepers and Equally concerning was the lack of McKenzie River identified in the BA the Northwest Environmental Defense any credible programmatic response and subsequent responses from NMFS Center filed a complaint in federal to a rapidly evolving scientific litera - were the following: court contending that the involved fed - ture demonstrating the surprisingly eral agencies were in violation of the severe impact of hatchery origin fish • Provide fish passage for Chinook ESA for not completing the required spawning in the wild, or to new molec - salmon at Cougar Dam to reestablish program documents or actuating the ular tools for monitoring these effects the South Fork run. programs. In early 2008, the agencies on natural populations. For example, settled the case, with NMFS agreeing recent papers have raised serious • Modify the release of water from the to produce a Biological Opinion (BiOp) questions regarding the ability of project dams to reduce impact upon in response to the various drafts of “integrated” hatchery practices to spawning and rearing of salmon below HGMPs; that the COE would proceed avoid reduction in reproductive per - the dams. with their Cougar passage project; and formance among wild spawners. (See the effort to reduce genetic introgres - for example, Chilcote, M. W., K. W. • Reduce genetic introgression (inter - sion by removing hatchery strays at Goodson, and M. R. Falcy. 2011. breeding) between wild and hatchery Leaburg Dam was to proceed. This “Reduced Recruitment Performance stock. At that time the plan was to cap - resulted in an Upper Willamette Basin in Natural Populations of Anadromous ture all hatchery-origin fish that did 2008 BiOp from NMFS which stated Salmonids Associated with Hatchery- not return to the hatchery before they the action items and timelines for com - Reared Fish.” Canadian Journal of could cross Leaburg Dam into the pletion, and the COE produced a new Fisheries and Aquatic Sciences 68 (3): upper river, thereby creating a “wild BA because the prior document was 511–22. doi:10.1139/F10-168.) One con - fish sanctuary” for native spawners now obsolete. Notably, the issues and clusion that can be drawn from this above the dam. their proposed solutions did not analysis is that the effective popula - change much from what had been dis - tion size (Ne) of naturally spawning • Create a systematic monitoring pro - cussed during the previous 8 years, salmonids is substantially smaller than gram consistent with the ESA require - though the data accumulated over this the total number of spawners. This ments. This would include fin clipping, time reinforced the need for action. subject warrants considerably more and later otolith marking to confirm In 2011 NMFS and ODFW produced a analysis but it should caution us that whether a fish was truly naturally document entitled “Upper Willamette just counting redds and carcasses may spawned even if it appeared not to be River Conservation and Recovery Plan substantially misstate what is going on clipped. for Chinook Salmon and Steelhead” in the rivers and mask issue which (http://www.nmfs.noaa.gov/pr/pdfs/rec arise from small breeding populations • Based on new standards for reducing overy/chinook_steelhead_upper - (e.g., inbreeding, allele loss and adap - potential impact of gene exchange willametteriver.pdf ), which generally tation to changing environments). between wild and hatchery stocks, covered the requirements of the BiOp (Allendorf, Luikart Aitken, 2013) increase the incorporation of wild but largely omitted firm time frames Based upon the above information, spawners to about 20% of the brood - for achieving these goals, or penalties we concluded that continued high lev - stock (i.e., create an “integrated” for failing to do so. During their prepa - els of genetic introgression could hatchery stock). ration of public comments on this doc - threaten the viability of the McKenzie ument, the McKenzie Flyfishers and River Chinook ESU regardless of prior The various agencies’ responses to Steamboaters became concerned by assessments of this risk. Following dis - these requirements were at best the lack of progress on implementing cussions with each of the agencies mixed. Some progress was made in actions specified in either the 2008 involved in managing this fishery, and setting new standards for release of BiOp or the 2007 settlement agree - with support from the Western water from project dams, and a moni - ment. For instance, while the BiOp Environmental Law Center, in toring program was initiated to track stated that the percentage of hatchery December 2013 the McKenzie the status of native spawning Chinook origin spawners (pHOS) in the Flyfishers and Steamboaters filed a and the numbers of hatchery fish that McKenzie River should be < 10%, the complaint in Federal Court alleging escaped to spawn. However, there was observed values consistently averaged that the COE and ODFW were in viola - no tangible progress in establishing around 40% or more for the river tion of the ESA and its associated fish passage at Cougar Dam. The below Cougar Dam; and the major plan administrative requirements. The newly-implemented monitoring pro - for reducing pHOS, involving installa - complaint alleged that the agencies gram documented that the level of tion of a hatchery/wild fish sorter at operated the McKenzie Hatchery for genetic introgression continued to be Leaburg Dam, had been abandoned as Continued on next page 16 MAY 2015 THE OSPREY • ISSUE NO. 81

Continued from previous page ate, and thus ODFW was protected did not find ODFW liable for ESA vio - from liability. Based on this reasoning, lations, but feel that the court’s finding years without an approved HGMP; the court also accepted ODFW’s right that genetic introgression is harmful allowed a genetic introgression level to release the 605,000 smolts that they to endangered fish is an important of at least four times the limit set by were proposing. This number effec - precedent, with implications for many NMFS; and failed to establish fish pas - tively cuts the smolt release number in issues involving anadromous fish. We sage at Cougar Dam, despite the half from the historic program levels, are also gratified that the court is requirements set out in the 2008 BiOp. and should have some positive effect maintaining jurisdiction over the The plaintiffs asked for a summary on reducing genetic introgression. development of critical corrective judgment barring the release of more Importantly, however, the court also actions to the management of this fish - than the number of Chinook smolts affirmed, as did the court in the simi - ery. At the same time, we observe that the COE has not yet announced a deci - sion on whether to complete a project for downstream fish passage at Cougar Dam, despite the commitment Historical Perspective they made in the 2014 settlement agreement. Also, ODFW recently sub - Willamette Spring Chinook mitted its own HGMP for the McKenzie Hatchery independent of the COE, even though COE owns the hatchery and has always been regard - 350,000

h ed as the agency primarily responsible s i 300,000 for HGMP submissions. COE has F

f 250,000 Natural Fish Hatchery Fish

o objected to the approval of such a doc -

r 200,000

e ument, asserting that ODFW has no b 150,000 standing in the process. We are cur - m

u 100,000 rently monitoring the situation. N 50,000 Today it’s generally agreed that, of 0 s 0 0 0 0 0 0 0 0 0 0 0 the various stocks of Chinook salmon 0 0 1 2 3 4 5 6 7 8 9 0 0 9 9 9 9 9 9 9 9 9 9 0 8 1 1 1 1 1 1 1 1 1 2 1 1 in the Upper Willamette Basin, it’s likely that only the Clackamas and Decade McKenzie River stocks are sufficient - ly productive to avoid extirpation; and that the McKenzie River population is needed for conservation purposes lar Sandy River Case, that the evi - the most genetically intact and most (reestablishing a spawning population dence accepted by all parties clearly likely to be the source of recovery of above Cougar Dam) until there was an confirms that genetic introgression these iconic wild fish. Sadly, although approved HGMP defining the scope of between hatchery origin and wild fish the conservation value of these fish is the program. The matter was set for a of the same species harms the latter. unquestioned, the escapement has con - settlement conference in June 2014. Further, the judge ruled that the target tinued to drop over the past 12 years That process resulted in the COE and set in the 2008 BiOp for the maximum and in 2014 was at the lowest number the plaintiffs agreeing to an immediate acceptable genetic introgression, as of natural spawners ever observed on three-fold reduction in Chinook smolts measured by the pHOS proxy, must be the McKenzie River. released into the McKenzie River, the met in a reasonable time frame accept - COE’s submission of an updated able to the court. Specifically his order HGMP for the McKenzie Hatchery to states that “…the defendants need to Bibliography of Citations: NMFS within 45 days, and their final understand that this may not be kicked decision on the program for fish pas - down the road endlessly. Accordingly, Araki, H., and C. Schmidt. 2010. Is sage at Cougar Dam no later than the court intends to oversee this Hatchery Stocking a help or harm? March 2015. process to ensure that the target is met Evidence, limitations and future direc - However, ODFW refused to settle the in a realistic time frame.” The court tions in ecological and genetic surveys. case and it ultimately went before a stated that its ruling in favor of ODFW Aquaculture 308:S2-S11. federal judge in Eugene, Oregon at a is “contingent upon defendants con - hearing on March 2, 2015. The judge’s sulting with NMFS to establish a time Allendorf, F.W., G. Luikart and S.N. ruling, released on March 13, denied frame for defendants to achieve a less Aitken. 2013. Conservation and the the plaintiffs’ request for summary than ten percent pHOS and submitting Genetics of Populations, 2 nd Ed. judgment and injunctive relief, on the a proposal of the deadline to this court Willey-Blackwell, Chichester, U.K. grounds that there had been corre - for approval. Defendants have ninety (See Chapters 6-8 and 14-18). spondence between ODFW and NMFS days to submit the proposal to the indicating that the latter found court.” ODFW’s proposed program appropri - We are disappointed that the court THE OSPREY • ISSUE NO. 81 MAY 2015 17 Wild Fish Victories on Washington’s East Fork Lewis River

By Steve Jones — Clark-Skamania Flyfishers —

Author Steve Jones is President of 1,000 fish. All would be distributed in Clark-Skamania Flyfishers. Founded in the East Fork Lewis to the south. After 1975, the group’s members are tireless Conservation is the trucking the totes to the river, the advocates for wild fish, habitat and work is done by hand. Using a pike, a conservation on the lower Columbia core of flyfishing that hoe-like tool with a spike on the end, a River and its tributaries. To learn more club member spears each fish and toss - about them, visit their website at: creates an energetic es it into the water at various points www.clark-skamania- along the river. Decomposing carcass - flyfishers.org/index.html community of anglers. es add nutrients to the river, which provide food for bacteria and insects any are attracted to fly at the base of the aquatic food chain fishing in their search is a regular part of the discussion. It’s steelhead need to thrive. for a way to pursue a also a regular part of the action. Logged, burned, mined, over-fished fish without consuming On a weekday morning in December, and over-developed, the East Fork it. To them, catch and 2014, about a dozen club members Lewis River has gone from a source of rMelease makes sense. When your prey milled around offices of the legendary steelhead runs to a river swims away to fight again, angling Washington Department of Fish and crowded with hatchery plants and becomes a better way to enjoy a river Wildlife Lewis River hatchery. Many vague promises that one day the or a wilderness or an afternoon away of them were regulars at this event. natives would recover. By the 1990s, from the job. People become fly fisher - They sipped coffee and swapped sto - the native steelhead had dwindled to men when they realize that fly fishing ries about recent outings and lousy endangered status. In the mid 2000s is not about how to fish, it’s about how weather. Ed Wickersham, a long-time CSF members began volunteering to to be. CSF member and past president, place hatchery carcasses in the East It’s about giving back to the lake, stepped out of the office to announce Fork to replace the biomass lost from sharing what you know, picking up they would be handling four bins of your litter, fencing the cattle out of the salmon carcasses that day, nearly Continued on next page river, restoring the meandering tribu - tary, replanting the banks, conserving the water, removing the invasive species, reestablishing the native fish. Without conservation, fly fishing risks becoming quaint or merely pic - turesque. With conservation at its core, fly fishing can create an energetic com - munity of anglers like Clark-Skamania Flyfishers. The club was founded in 1975 by fish - ermen concerned about the declining quality of water and fishing on the Washougal River in Clark County, Washington and the Wind River in Skamania County to the east. Since its founding, the club has had a conserva - tion director among its regular offi - cers. Conservation directors, such as Mark Heirigs today and past directors Craig Lynch and Dennis Ward, work to keep the club abreast of fisheries issues. Today the club has 176 mem - bers and regularly draws about 100 to Members of the Clark-Skamania Flyfishers place salmon carcasses along the East monthly meetings where conservation Fork Lewis River as part of the stream enrichment program. Photo by Steve Jones 18 MAY 2015 THE OSPREY • ISSUE NO. 81 Continued from previous page native runs and give what natives remained a source of nutrients. Now CSF members lead the effort, which has placed more than 10,000 carcasses in the East Fork so far this year. CSF also participated in a detailed two-year evaluation of the East Fork that resulted in its designation as one of three gene bank tributary rivers of the lower Columbia River for winter and summer run steelhead. And earlier in 2014 when CSF members were alert - ed to a potential logging operation on private land adjacent to a popular East Fork campground, the club quickly joined Friends of the East Fork, a local environmental group, in an appeal to Washington State land use officials. Simultaneously, Friends of the East Fork began searching for a conserva - tion buyer for the tract. As land use officials began uncovering problems with the logging plan, the landowner Clark-Skamania Flyfishers contributed $15,000 to help the Columbia Land Trust pur - changed his mind about cutting and chase property along Pine Creek, an important tributary of the Lewis River. Photo sold the land to a conservation buyer. courtesy Columbia Land Trust And CSF is putting its money where its mouth is too. The club has made combined with a previous 2,330-acre more than $8,000 in grants during the purchase, now protects nearly the past decade to conservation work on creek’s entire upper watershed. Sorry about that the East Fork. It will join with others to When you fly fish you come to appre - help finance another East Fork restora - ciate every day miracles. You can go We misidentified U.S. tion project in 2015. through a run time and again with no Congressman Jared Huffman in Money for such efforts comes from results and then be surprised with a S. Craig Tucker’s article on the the annual CSF Banquet. The club has rambunctious big fish. Good fly fishers Klamath River dams in the held an annual fundraising banquet for understand the better fly they tie, the 38 years and in that time has raised better cast they present, the better January 2015 issue of The and donated more than $185,000 to con - chance of a fish pulling tight on that Osprey . servation and outreach efforts. Most of line. For a generation, members of CSF Congressman Huffman is a the club’s spending is focused on con - have understood the better stewards servation in Washington and the lower Democrat who represents we become, the better environment we California’s 2nd District. We Columbia River basin. CSF has used its create, and the better we all are for it. cash to support like-minded environ - apologize for the error. mental groups such as the Gifford Pinchot Task Force in its fight to pre - vent mining on Green Mountain, in the headwaters of the Lewis River. And to THE OSPREY OFFERS ELECTRONIC MAILING help introduce new generations to fish - ing and conservation the club has sup - Subscribers may now, at their option, receive The Osprey as a PDF file ported the local Klineline Pond kids attached to an e-mail. fishing day since 2008 and the Salmon If you are an existing subscriber who would like to switch to e-mail deliv - in the Classroom program since 2009. ery or a new subscriber for either printed or e-mail delivery, please complete One of CSF’s most recent contribu - the redesigned coupon on Page 19 and send it to the Federation of Fly Fishers tions to wild fish conservation was its with your contribution to support The Osprey and the cause of recovering $15,000 grant to the Columbia Land wild steelhead and salmon. Trust for its effort to protect critical Effective immediately you also have the option of making a secure credit bull-trout habitat on Pine Creek, a card donation to support The Osprey and wild steelhead and salmon by going Lewis River tributary. Those funds to the following link: http://www.fedflyfishers.org/Default.aspx?tabid=4329 . were used by the land trust towards By either means, the steelhead and salmon will thank you for supporting the purchase of more than 2,800 acres The Osprey . of forest and riparian land that, when THE OSPREY • ISSUE NO. 81 MAY 2015 19

Chair’s Column, continued from page 3 weeds and conducting habitat restora - 43 total organizations. Three on the list tion. are ones to which I’m a Life Member Club entitled “Kindred Spirits” [or “The transfer of federal lands to the including the International Federation some title very similar]. states would result in one likely out - of Fly Fishers. Two more I’ve been an Recent reports of efforts on two come: the fire sale of these lands to the annual member for years. And another fronts caught my attention as they highest bidder – billionaires and for - half dozen are organizations I feel an regard the thesis offered by “Kindred eign corporations who may neither affinity towards. Spirits”: understand nor value America’s out - Some of the organizations involved in door heritage. Once privatized, these both cases have paid Washington DC • Klamath Basin Restoration lands will become off limits to most staff, permanent office headquarters Agreement [KBRA]. KBRA would sportsmen in perpetuity.” also staffed. change and share water distribution in While both lists of partners are truly the Klamath Basin and set the stage for I posted a Facebook comment regard - substantial, the number of “Kindred removal of dams thus opening many ing the TRCP item similar to this: “If Spirits” in my imagination is much miles of habitat for migratory fish. It is Hunters- Fishermen/Women- larger. These two are examples the official that Lower Klamath National Environmentalists joined together, the concept is building. However, we’ve Wildlife Refuge, [founded during the coalition would be unstoppable.” This still got a ways to go to build the Theodore Roosevelt presidency as the is the core concept of the “Kindred unstoppable coalition working and pro - first refuge for migratory waterfowl], Spirits” article. tecting diverse environments. The will receive no water this year. [Many To my surprise, a reply came from unstoppable coalition that naturally will recall the salmon kill of 2002 in the TRCP pointing me to the “Partners” would support wild salmon and steel - Klamath River. I have received a copy page of their website. The list includes head! of the April 20, 2015 letter to three Congress members (including mine) signed by numerous organizations and To receive The Osprey, please return this coupon with your businesses urging Congressional check made out to The Osprey - IFFF approval of the (years in the making) agreement. These include: national & state fisheries and waterfowl advo - cates, Northern California Council of the IFFF, plus commercial fishing THE OSPREY interests & recreational fishing guide NAME services/shops. There were 37 signato - ries total. ADDRESS • Theodore Roosevelt Conservation Partnership (TRCP) on the potential sale of public lands. “WHAT’S AT CITY/STATE/ZIP STAKE” “OUR LANDS FOR SALE”“America’s 640 million acres of PHONE federal public lands – including our national forests and Bureau of Land Management lands – provide hunting E-Mail and fishing opportunities to millions of I Am a New Subscriber ❑ Send My Copies By E-Mail (PDF Electronic Version) ❑ Americans. I Am An Existing Subscriber ❑ Send My Copies by Standard Mail (Hardcopy) ❑ “Without these vast expanses of prairie and sagebrush, foothills and Yes, I will help protect wild steelhead If you are a new subscriber, how did you hear about towering peaks, the traditions of hunt - ❏ $15 Basic Subscription The Osprey? ing and fishing as we have known them ❏ $25 Dedicated Angler Level ❏ Friend or fellow angler for more than a century would be lost. ❏ $50 For Future Generations of Anglers ❏ Fishing show “Efforts are afoot across nine ❏ $100 If I Put Off Donating, My Fish ❏ Fly shop, lodge or guide Western states (Arizona, Colorado, Might Not Return Home ❏ Idaho, Montana, Nevada, New Mexico, Another publication.Which? ❏ Oregon, Utah and Wyoming) to wrest $ Other, Because ❏ Club or conservation group meeting public lands from the federal govern - ❏ Other ment and put them under state owner - ship. I am a . . . The Osprey — Steelhead Committee “States are simply not equipped to ❏ Citizen Conservationist International Federation of Fly Fishers shoulder the enormous costs associat - ❏ Commercial Outfitter/Guide 5237 US Hwy 89 South, Suite 11 ed with fighting wildfires, maintaining ❏ Professional Natural Resources Mgr. Livingston, MT 59047-9176 roads and trails, treating noxious ❏ Other Thanks For Your Support Non-Profit Org. U.S. Postage Paid PAID THE OSPREY Bozeman, MT Permit No. 99

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