ISRP Comment on the Yakama Nation's Response for the Klickitat Master Plan (#1988-115-35)

Tony and Mark,

The ISRP considered the Yakama Nation’s response to our questions about the Klickitat segregated steelhead harvest program. Based on the Yakama Nations’ response, we understand that this segregated steelhead program is funded through the Mitchell Act and operated by Washington Department of Fish and Wildlife. Consequently, this work is not part of the BPA funded Yakama Nation Master Plan and thus appears to be outside the Council and ISRP project review process. 

This situation is common where a Fish and Wildlife Program hatchery interacts with non-Fish and Wildlife Program hatcheries including PUD, Idaho Power, and Mitchell Act funded hatcheries. In past Step Reviews, the ISRP has not based a final Step recommendation on whether a Fish and Wildlife Program hatchery has comprehensively evaluated cumulative interactions with these other hatcheries or justified the other hatcheries’ actions. That said, the segregated steelhead program potentially has significant impacts on Klickitat steelhead and spring Chinook populations. The ISRP and ISAB have recognized the need for analysis of the cumulative effects of multiple programs at the subbasin, province, and basin levels. The ISRP is not aware of a comprehensive effort to address this cumulative effects issue, which extends well beyond this Klickitat Step Review.

The ISRP looks forward to reviewing the Yakama Nation’s Step Three submittal for the Klickitat Master Plan.  This Step Three submittal should include responses to the ISRP qualifications #2 McCreedy Creek Steelhead Supplementation and #3 Spring Chinook Integrated Harvest and Colonization, and address steelhead monitoring issue R1.2. raised in the Step Two review (ISRP 2013-01). The Klickitat Master Plan’s segregated steelhead monitoring proposes to use the proportion of smolts with hatchery parentage (<5%) observed in smolt samples as the primary guidepost. In the Step Two review, the ISRP concluded this monitoring was insufficient. The segregated steelhead program’s effects on natural populations extend beyond introgression, especially density dependent ecological effects.  The response of May 1, 2013 from the Yakama Nation specifically states they would continue to use the decision tree and introgression level for steelhead monitoring. In addition, the Step Three submittal should establish a monitoring design that recognizes and addresses disease, predation, and competition risks as well as genetic risks.

Sincerely,

Rich Alldredge