Open Letter to Members of Congress regarding HR 5376 Congress must rethink Section 70203 in H.R. 5376 of the Build Back Better Act. Our organizations heartily support the principal sections – including Section 70201, 70202 and 70204 – as these are historic and will be significant investments in conserving, protecting, and restoring the region’s wild salmon and their home watersheds into the future. However, it is a $400 million blunder to invest in artificial production of salmon and steelhead based on a decades-long failure of hatcheries that ignores the science-based and practical experience of the West Coast’s wild salmon and steelhead recovery effort. Section 70203 is a blank check that will undermine years of previous wild salmon and steelhead recovery efforts. Our Ask for H.R. 5376 - Section 70203 We the undersigned ask that Congress seriously consider the grave risks to wild salmon and steelhead posed by the existing hatchery production system. Congress has several options before you regarding Section 70203, so collectively, we ask that Congress amend Section 70203 to prioritize funding for the following actions: Option 1) To bring hatcheries into compliance with the Hatchery Scientific Research Group recommendations and the Endangered Species Act, condition the appropriation provision on completion of a scientifically sound federal review and implementation of recommended reforms of regional hatchery practices and actions by the Hatchery Scientific Review Group (HSRG). Compliance with these frameworks is vital for protecting genetic diversity in wild populations. Option 2) Greatly reduce the amount of the appropriation to a level that continues meeting Tribal Treaty obligations. Treaty obligations must be met in a manner that is consistent with the Endangered Species Act. Option 3) Use the appropriations in this section to guide planning for the transition of rivers from hatchery-based fisheries to wild based fisheries management. Hatchery programs are by their very nature unsustainable, reliant on wild salmon and steelhead populations, and carbon dioxide emitting. Currently most hatcheries have no date to sunset for their operations and very few plans exist to transition rivers with larger habitat investments back to wild fish management. A forward-looking bill like the Build Back Better Act must address this transition in the same way that it addresses a transition from our fossil fuel-based economy to an economy based on renewable energy sources. We must begin to transition from the unsustainable, industrial production of hatchery salmon, the natural production of wild salmon from healthy, restored watersheds.
Option 4)
If there is not a means to amend the provision, it should be struck in its entirety.
Our Vision for Wild West Coast Salmon and Steelhead Our organizations share a vision of thriving wild salmon and steelhead populations that are self-sustaining despite the combined anthropogenic threats of climate change and habitat loss/alteration. Our vision includes the opportunity, for all who are interested, to harvest wild fish but also to simply admire them as wild creatures perfectly adapted to their home rivers. To achieve this vision, we must make historic investments in the protection and restoration of healthy marine and freshwater habitats and promote the natural resilience of salmon by protecting their diverse genetics from the negative impacts of hatchery fish and overfishing. The Build Back Better Act represents a historic opportunity to take a forward looking, climate changeproactive, and science-grounded approach to addressing the challenges that lie ahead for Northwest communities, environments, and native fish populations. Our Rational Why Section 70203 Could be Catastrophic Congress Should Not Continue to Make Catastrophic Investments in Northwest Hatcheries The draft reconciliation bill reveals Congressional intent to make the largest investment in northwest hatchery infrastructure on record. This bombastic subsidy to overcapitalized west coast salmon and steelhead fisheries will cause irreparable damage to declining wild salmon and steelhead populations and to at-risk Southern Resident killer whales. The proposed $400 million-dollar pork-barrel proposed for state and tribal hatcheries will negate Congress’s historic investment in critical regional efforts to restore and conserve Pacific wild salmon and steelhead habitat. Hatcheries are well-known as one of the four “H’s,” which also include hydropower, habitat, and harvest. Hatcheries are a direct and primary threat to populations of wild salmonids and have contributed to the precipitous decline of wild fish populations throughout the northwest since the passage of the Mitchell Act in 1938. Hatchery fish have reduced genetic diversity and have lower survival and reproductive rates than wild fish. Hatchery fish that escape capture by hatchery programs and spawn with wild fish also reduce the reproductive output of those wild fish. What is particularly concerning about hatchery fish is their observed reduced ability to deal with climate change in comparison to wild fish. Hatchery fish are wellknown to have lower return rates in years with poor ocean conditions. It is therefore confounding that a bill with a goal to address climate change would earmark so much money on infrastructure that would reduce the ability of multiple threatened or endangered species to adapt to climate change. Since the majority of Pacific Northwest wild salmon and steelhead are listed as Threatened or Endangered under the Federal Endangered Species Act (ESA), and the ESA-listed Southern Resident killer whales are teetering on the edge of extinction, it is inconceivable that that Congress is directly undermining the impact of heroic regional recovery efforts and additional vital investments in habitat restoration and intensive monitoring with this dangerous and damaging investment in an activity that has not recovered a single ESA-listed wild salmon or steelhead species in the past 32 years.
Straight talk: 1. Increasing or maintaining the current capacity of hatcheries will impede recovery and further harm wild salmon and steelhead. 2. Hatchery production is the single largest contributor to carbon emissions from state and tribal fishery agencies across the Northwest. 3. The North Pacific Ocean is already an over-grazed “pasture” from the current level of hatchery salmon and steelhead releases from multiple Pacific Rim nations. 4.
Hatchery production and increases will not save the Southern Resident Killer Whales.
5. Mass hatchery production and releases dramatically increase predation from marine mammals, birds, and other fish creating a disproportionate adverse impact on co-occurring wild populations whose migratory behavior “spreads the risk” over time and space to avoid predation. 6. Greater releases of hatchery salmon and steelhead result in more intense fisheries in marine and freshwater which negatively impact wild populations. 7. There are foundational “limits to growth” based on the ultimate limit in the total amount of universal energy – energy being consumed in the production and release of hatchery fish is not returned in kind to our watersheds in terms of returning adult hatchery salmon and steelhead. It is encouraging that scientific understanding has helped lead Congress to promise the single largest investment in history in salmon ecosystem restoration, climate resiliency projects and fish population monitoring through these important reconciliation and infrastructure bills. However, the same confidence in our shared scientific understanding on the value of habitat restoration and the urgency to act on climate change adaptation and resilience must also be applied to the use of hatcheries as a conservation tool or fishery subsidy. Fact: Hatcheries have not recovered a single wild salmon or steelhead population on the west coast despite their ubiquitous and widespread use since 1877. Examples of hatchery fish “recovering” wild populations involve Snake River fall chinook and Snake River sockeye salmon - both instances where the hatchery supplementation is ongoing - so there is no proof that these hatchery-supplemented salmon returns would be sustained if the hatchery releases ended. Hatchery fish survive at much lower levels than do wild fish once they are outside the hatchery fence. Hatchery fish exhibit domestication characteristics even in their first generation. Over 140 million juvenile hatchery salmon and steelhead are released annually in the Columbia Basin and long-term trends continue to decline.
In what is the most recent and most thorough scientific assessment of hatchery production, after thoroughly reviewing the scientific literature on the effectiveness of hatcheries in 2020, the top scientists for the Washington Department of Fish and Wildlife (WDFW) found that there was “scant evidence” of conservation success and “few examples” where the risks from reliance of hatchery programs where outweighed by the benefits. (WDFW 2020 A review of hatchery reform science in Washington State). These enormous federal spending increases in hatchery fish ignore decades of independent federal advisory and review panels that recommended across-the-board reforms that have yet to be implemented and will only further neutralize the science-based thresholds in previous hatchery reform policies. Without a science-based framework, it is inexcusable that Congress is proposing to fund massive increases in hatchery production that will only amplify the harmful impacts hatchery salmon and steelhead impose on wild populations daily. Worst of all, Congresses’ decisions to spend even more money than is already spent on hatcheries are occurring without any environmental scrutiny and are proceeding in the face of warnings from independent and government scientists who know well the likely consequences of these decisions to increase or even maintain hatchery production. We believe that the proposed investment in habitat restoration and effective monitoring of the region’s progress will be effective in addressing three of the main limiting factors. These sections will help restore freshwater rivers and estuaries (Habitat), reduce thermal loading in rivers (Heat) and address streamflows and migration barriers (Hydro). However, Congress must reverse course on H.R. 5376 section 70203’s $400 million hatchery repair, replacement and enhancement blunder. It will be a case of putting good money after bad – as federal expenditures for regional hatchery production have failed – after spending hundreds of millions of dollars on hatchery production all while wild salmon and steelhead populations have continued to decline. Congress must fail-proof its historic, significant proposed expenditures for wild salmon and steelhead recovery in Sections 70201, 70202 and 70204 so these expenditures are truly effective and reinvigorate the region’s effort to address all the limiting factors currently preventing the recovery of the region’s wild salmon and steelhead. To ensure the broader success of the Build Back Better Act, Section 70203 must be struck or revised because it will irreversibly blunt the impact and significance of Congress’s historic investment in wild salmon and steelhead monitoring, restoration, and conservation. Re-stating Our Ask 1)
To bring hatcheries into compliance with the Hatchery Scientific Research Group recommendations and the Endangered Species Act, condition the appropriation provision on completion of a scientifically sound federal review and implementation of recommended reforms of regional hatchery practices and actions by the Hatchery Scientific Review Group (HSRG).
2)
Greatly reduce the amount of the appropriation to a level that continues meeting Tribal Treaty obligations.
3)
Use the appropriations in this section to guide planning for the transition of rivers from hatcherybased fisheries to wild based fisheries management.
4)
If there is not a means to amend the provision, it should be struck in its entirety.
We, representing the undersigned organizations, appreciate the arduous work that has produced the Build Back Better Act and its significant investment in coastal community climate change resilience, broadbased wild salmon and steelhead protection, conservation and recovery efforts, and wild salmon and steelhead population monitoring and assessments. We respectfully request that the Congress re-think and refine the proposed investment in hatchery repair, enhancement and expansion described in Section 70203 so that if appropriations are made that they reflect the same future-forward approach to a scientifically-sound and holistic conservation and recovery strategy that relies on the productivity, diversity and resilience of wild salmon and steelhead populations which will still form the fundamental basis for west coast-wide salmon economy, ecology and culture into the future.
Sincerely,
Brett Hartl, Government Affairs Director Center for Biological Diversity
Tom Logan, Conservation Chair Flyfishers International
Mark Sherwood, Executive Director Native Fish Society
Becky McCrae, President The North Umpqua Foundation
Greg Topf, Board Chair Wild Steelhead Coalition
David Moskowitz, Executive Director The Conservation Angler
Contact: David Moskowitz, The Conservation Angler david@theconservationangler.org 971-235-8953 (direct)