Idaho Letter

August 31, 2021

Greg Cameron, Chairman Idaho Fish & Game Commission P.O. Box 25 Boise, ID 83707 Re:

2021 Snake River Steelhead Return

Commissioner Cameron: The Conservation Angler (TCA) requests that the Idaho Fish and Game Commission immediately close all recreational steelhead fishing through June 30, 2022. TCA believes this closure is necessary and reasonable to protect ESA-listed Snake River steelhead, which are experiencing their worst return on record.1 In particular, TCA believes closing steelhead fishing on the Salmon River is one of several substantial interventions necessary to support the survival and recovery of several quasi-extinct populations in the watershed. Regrettably, these populations and others are too vulnerable to withstand catch-and-release mortalities caused by hatcheryfish retention and non-retention fisheries. The 2021 steelhead fishery should be closed.

The Columbia River Basin is experiencing the worst steelhead return since passage counts began in 1938.2 Between July 1st and August 30th, 35,106 steelhead have crossed Bonneville Dam, which is 27% of the current ten-year average (2011-2020) for this period and 13% of the previous ten-year average (2001-2010).3 On August 30th, the U.S. v. Oregon Technical Advisory Committee updated its 2021 A-Index steelhead return forecast to 42,600 total A-Index steelhead, consisting of 25,700 hatchery AIndex and 16,900 unclipped A-Index steelhead through October 31.4 The B-Index steelhead 1

Columbia Basin Bulletin. More Bad News For Columbia River Basin Steelhead: A-Run Forecast Plummets 60 Percent, Worst on Record. Aug. 19, 2021. https://www.cbbulletin.com/more-bad-news-for-columbia-river-basinsteelhead-a-run-forecast-plummets-60-percent-worst-on-record/ (last viewed on Aug. 26, 2021).

2 Id. 3 Columbia Basin Research, School of Aquatic & Fishery Sciences, University of Washington. DART Adult Passage Annual Counts http://www.cbr.washington.edu/dart/wrapper?type=php&fname=adultannual_1630446161_815.php (last visited August 31, 2021).

4 Email from Nichole Kloepfer on behalf of Ryan Lothrop, Columbia River Fishery Manager, Washington Dept. of Fish and Wildlife, to David Moskowitz, Executive Director, The Conservation Angler (Aug. 31, 2021 12:40 PM PST) (on file with author).

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forecast remains at 6,600 hatchery fish and 1,000 unclipped fish until further notice.5 Based on these forecasts, a total of 50,200 steelhead are expected to pass Bonneville Dam between July 1st and October 31st. The forecasted total is 22,266 fewer fish than the second-worst upriver return period on record, July 1 – October 31, 2019.6 Of particular concern is the forecast for wild B-run steelhead. The current forecast of 1,000 wild fish will not be updated by the US v. Oregon TAC until about the third or fourth week of September. Downriver fisheries have already been authorized and conducted based on that forecast. Based on figures in the most recent Joint State Staff Report7, in 2017, the wild B-run pre-season forecast was 1,100 fish, yet only 751 were counted at Bonneville Dam, and only 263 counted as crossing Lower Granite Dam (a 65% conversion rate8). In 2019, the pre-season wild B-run forecast was 950 fish, only 899 wild B-runs were counted at Bonneville Dam and only 400 of those fish were counted at Lower Granite (a 55.5% conversion rate). While it is true that Brun returns do not always track the accompanying A-run, the uncertainty facing managers demands a cautious approach in setting fisheries that will affect wild B-run spawning success.

Any bag limit over one hatchery fish will double the encounter rate for these iconic and imperiled fish.

The 2019 steelhead run total and the forecasted 2021 return demonstrate that Snake River steelhead are in serious decline and thus warrant additional protection. Several populations are quasi-extinct or on track to be quasi-extinct by 2025. An April 2021 presentation from the Nez Perce Tribe to the Northwest Power and Conservation Council demonstrates the perilous state of these populations.9 Among other compelling facts, the tribe’s biologists provided the following key information about 16 ESA-listed Snake River steelhead populations10: •

Three out of 16 populations of Snake River steelhead (19%) are quasi-extinct, which include the Pahsimeroi River, Little Salmon River, and Secesh River populations.11

5

Columbia Basin Bulletin. More Bad News For Columbia River Basin Steelhead: A-Run Forecast Plummets 60 Percent, Worst on Record.

6 Columbia Basin Research, School of Aquatic & Fishery Sciences, University of Washington. DART Adult Passage Annual Counts http://www.cbr.washington.edu/dart/wrapper?type=php&fname=adultannual_1630446161_815.php (last visited Aug. 31, 2021). The worst upriver steelhead passage occurred in 1975, the year Lower Granite Dam was completed. See Columbia Basin Research, School of Aquatic & Fishery Sciences, University of Washington. DART Adult Passage Daily Counts for All Species. https://www.cbr.washington.edu/dart/query/adult_daily (last visited August 26, 2021).

7

2021 OR-WA Joint Staff Report: Stock Status and Fisheries for Fall Chinook Salmon, Coho Salmon, Chum Salmon, Summer Steelhead, and White Sturgeon, Tables 6 & 7 at p. 39-40. https://wdfw.wa.gov/sites/default/files/2021-07/2021_or_wa_fall_joint_staff_report.pdf 8 Conversion Rate is the term used to convey the loss of fish between fish passage structures due to all factors (harvest, natural mortality, predation, illegal harvest, mortality caused by the fish passage structure, as well as straying to other rivers).

9

Memorandum from Patty O’Toole, Fish and Wildlife Director, to Northwest Power and Conservation Council members re: Nez Perce Tribe staff presentation on their analysis of Snake River Basin Chinook and Steelhead – Quasi-Extinction Threshold and Call to Action (April 27, 2021) (https://www.nwcouncil.org/sites/default/files/2021_05_4.pdf) (last visited Aug. 31, 2021).

10 Data was not available or was insufficient for the other nine Snake River steelhead populations. Id. 11 Id., at slide 15.

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•

A steelhead population is considered quasi-extinct when there are 50 or fewer spawners within a population for four consecutive years.12 At these levels, the “[p]robability of recovery [is] low without substantial intervention.”13

•

Snake River steelhead are declining at a rate of 18% per year, with even worse declines for B-Index steelhead.14

•

In four years, seven out 16 populations of SR steelhead (44%) will be quasi-extinct, which include the following groups: the Middle Fork Salmon River (Lower Mainstem), Lemhi River, Salmon River (Upper Mainstem), Lolo Creek, Pahsimeroi River, Little Salmon River, and Secesh River populations.15

•

15 out of 16 populations have been declining over the last 10 years.16

Regrettably, a quarter to one-third of steelhead bound for Idaho that crossed Bonneville Dam between July 1st and today will perish before crossing Lower Granite Dam. A February 2021 NOAA Fisheries memorandum regarding adult steelhead survival in the Columbia River Basin reported the following percentages of steelhead die before reaching McNary Dam: “Temperature on day of passage at Bonneville Dam was the strongest individual predictor of survival, with estimates dropping from above 80% during temperatures of 13-17°C to 67% when the river reached 23°C. A majority of steelhead (61%) entered the Bonneville Dam to McNary Dam reach at temperatures of 20-22°C, and thus had an expected temperature-determined survival of about 73%. This estimate included observed catch rates, so reducing catch would increase estimated survival at high temperatures.”17 Another 10% of Snake River steelhead will die between the McNary and Lower Granite Dam reach.18 Every steelhead that has crossed Bonneville Dam since July 1st of this year has experienced daily temperatures above 20C, with some experiencing multiple days of temperatures at or above 23C.19 Despite the low impact of sport fisheries, relative to the four Lower Snake River dams, poor ocean productivity, hatchery impacts, and other factors, TCA believes that closing recreational steelhead and commercial fisheries are part of the “substantial intervention” necessary to 12

Id., at slide 2.

Id. 14 Id., at 16.

15 Id., at 17.

16 Id., at slide 28.

13

17

Crozier, L. et al. (Feb. 2021), Reframing Steelhead Migration Behavior: A Population Perspective on Migration Rate and Survival Through the Columbia and Snake Rivers, NOAA Technical Memorandum NMFS-NWFSC-164, at 36 (Emphasis added).

18 Id., at 29. ("Across all years and MPGs, survival from McNary Dam to Lower Granite Dam was near 90%, ranging from 0.88 to 0.97 across years; means per MPG ranged from 0.89–0.92.”); see Attachment 2.

19 Fish Passage Center. https://www.fpc.org/WebForm2013/CurrentTempReportwithExport.aspx (last visited August 31, 2021).

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prevent quasi-extinction of multiple Snake River steelhead populations, not to mention slowing the declines of 15, if not more, individual populations.20 TCA has requested the Oregon and Washington State Fish and Wildlife Commissions to close their recreational steelhead fisheries in the Columbia River Basin, as well as commercial fishing below Bonneville Dam. We have made these requests, in part, to protect ESA-listed Snake River steelhead. The Oregon and Washington Departments of Fish and Wildlife have recently closed several fisheries, which will help protect steelhead returning to Idaho and elsewhere. We urge you to join the collective state effort to protect these populations by closing recreational steelhead fishing in Idaho this year.

Our organizations appreciate your commission’s desire to support recreational steelhead angling – all of us signing this letter are passionate steelhead anglers. However, we simply do not believe that fishing for ESA-listed steelhead during their worst return on record is appropriate for these fish or future generations of fishermen. For a species that has provided generations with memorable fishing experiences, asking fishermen to sit a season out is reasonable and necessary considering the circumstances.

Thank you for considering our request.

Sincerely, David A. Moskowitz (via electronic mail) David Moskowitz Executive Director The Conservation Angler

The Conservation Angler * 3241 NE 73rd Avenue * Portland, OR 97213 * www.theconservationangler.org

20

Attachment to Memorandum from Patty O’Toole, Fish and Wildlife Director, to Northwest Power and Conservation Council members re: Nez Perce Tribe staff presentation on their analysis of Snake River Basin Chinook and Steelhead – Quasi-Extinction Threshold and Call to Action, at slide 2.

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