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Artificial Production Review Committee Meeting
Monday, June 14, 1999
NWPPC Conference Room, Portland, Oregon
Meeting in a workshop session, the Production Review Committee (PRC)
discussed the draft policy report that is to be submitted to Congress
later this summer. Facilitator Jim Waldo said he and the staff will
rework some passages in the document to reflect the committee members’
concerns; comments on the draft will be taken until June 22. The
committee launched into a discussion of how the region might implement and
fund the artificial production policies, deciding by day’s end to form a
subgroup to work up recommendations. A list of attendees is attached
to this report.
HIGHLIGHTS
Praise From Lohn
An Overview of the APR Report
A Crack at the General Policies
Guidelines and Performance Standards
Implementing the Artificial Production Policies
_______________________________________________________________________
Praise From Lohn
Bob Lohn, the new director of the Northwest Power Planning Council’s
Fish and Wildlife Program, said he was “struck and amazed” by the
amount of progress the Artificial Production Review had made on such a
difficult and polarized issue. It has become clear that there is a
significant role for artificial production in the region, he stated.
I don’t know reach-by-reach how artificial production will be used, but
it will be used, Lohn said. We are working hard to develop a unified
plan, and we know “the answer is not that we will have no artificial
production, but we need to find the right place,” he added.
Lohn explained that after the group spent some time polishing the
policy document, the day would be dedicated to discussing
implementation. We want to open up the discussion to the day-to-day
realities of funding and facilities, he said. Lohn indicated that
implementation would not be a part of the current report to Congress, but
he said it was time to start discussing what resources will be used to
implement the artificial production policies. The question is how do
we meet the needs of those of you who are managing the facilities and
trying to produce fish that will benefit the region, Lohn said.
So far we have focused on the “what” of the artificial production
policies, and we have not had a chance as a group to talk about
implementation, meeting facilitator Jim Waldo agreed. He said the
first part of the day would be spent on the policy document, adding that
it was not the intent to wordsmith the content. By June 22, I want
to receive any written comments you have, Waldo added. He said the
staff would take the comments into account in finalizing the
document. The second major issue of the day is the “how” and the
“who” of implementation actions, Waldo said.
An Overview of the APR Report
Consultant John Marsh walked the group through an overview of the
policy document (Attachment 1), noting that he had discussed the document
with some of the committee members over the last couple of weeks and
gotten some reactions. We have spent lots of time on the “what”
of artificial production, Marsh said. We aren’t all the way there
yet, but “we may not get complete consensus,” he added. Some of
you have said that “we do seem to be mostly there” with the
coordinated policy part, Marsh said. I have also heard comments that
the Executive Summary of the document paints an inaccurate picture of what
is in the report – it comes off as negative, he added.
The report has three sections, Marsh continued: background,
coordinated policy, and implementation recommendations. The background
states that there are limited funds for fish and wildlife (F&W)
programs and for hatcheries, so we want to maximize the benefits – “not
a controversial point,” he said. The route to maximizing the
benefits, Marsh explained, is to reconcile four areas: provide
broader harvest opportunities; improve the survival of hatchery fish;
avoid harming wild (naturally spawning) populations; and protect and
rebuild natural populations. The means to reconciling these four
issues requires a policy decision, he said.
The coordinated policy that comes out of the Artificial Production
Review will become a piece of the Council’s multi-species framework, and
it will become a part of the Council’s F&W program amendment
process, Marsh went on.
Hatcheries are subject to legal mandates, such as Treaty rights,
Endangered Species Act (ESA), and other federal laws, and the point of the
policy is not to supersede these, he stated. “The policy statement
needs to respect these,” Marsh added.
The policy lists five purposes for artificial production, he went
on: augmentation, the motivation for which is to increase harvest;
mitigation, to make up for destroyed habitat; restoration, to hasten
rebuilding stocks; preservation, to deal with populations faced with
imminent demise; and research, to find ways to use artificial production
for these other purposes. It should also be noted that an artificial
production program can have multiple purposes, and those can change over
time, Marsh added.
Stacy Horton, NWPPC staff, suggested that resident fish substitution is
a purpose of its own, aside from the categories listed in the report.
Overall, a coordinated policy must be scientifically sound and achieve
management objectives and biological goals, Marsh said. The report
lists nine general policy goals, he explained: artificial production
should be considered only in the context of the environment in which it
will be used; the benefits of artificial production over the entire life
cycle remain unproved and programs must still be considered experimental;
hatcheries exist as part of a larger system; artificial production should
seek to protect and restore biological diversity; locally adapted or
compatible broodstocks should be used; harvest is a legitimate objective,
but rates and practices must be geared to sustain naturally spawning
populations; all hatcheries should serve one or more of the purposes
listed in the report; decisions on artificial production should be made
within subbasins, but with a regional perspective; and risk management
strategies should be consistent with those applied to other stages of the
fish life cycle.
With regard to implementation, Marsh said the committee at its first
meeting had raised the question of how to get the policy recommendations
“to happen on the ground.” People saw the work as useless unless
it is implemented, he said. A part of implementation is to develop
performance standards, Marsh explained. Brian Allee of the Columbia
Basin Fish and Wildlife Authority is in charge of an ad hoc group that is
developing standards, he said, and they expect to have something completed
by September. People have commented that we need to get that work
done sooner, Marsh said.
The report recommends using existing processes to implement the
recommendations, but not everyone is comfortable with that idea, he
continued. Another recommendation is to re-evaluate hatchery
purposes over the next five years in the context of the subbasins, Marsh
said. The report recommends using an ad hoc group, including the
Science Review Team (SRT), to do that, he explained. Some folks do
not want the SRT to be involved, Marsh reported. Two ideas for
carrying out the review have surfaced, he said: one involves picking
one hatchery in each subbasin and doing “a full-meal deal” of a
review; a second idea involves using an accreditation approach in which a
hatchery would either be accredited or not. You could link this
review to funding or not, “but it does bring up that question,” Marsh
said.
The report addresses the issue of coordinating with other processes,
such as U.S. v. Oregon, he continued. Some say those negotiations
should be opened up to everyone, but there are legal reasons why that
cannot happen, Marsh said. But those who are participating in U.S.
v. Oregon need to give us some advice, he added. There seemed to be
a feeling among some I talked to that the draft carved out a role for the
Council that is “overstepping its authority,” and that the Council
could decide which hatcheries ought to go, Marsh said. People felt
that is not an appropriate role for the Council, he said. In terms
of coordinating with the multi-species framework and the Council’s
F&W program, people said the Artificial Production Review
recommendations need to go forward and could be sidelined by linking them
too closely with these processes, Marsh stated.
There is also a need to coordinate with what’s going on under the
ESA, he said, adding that the comment has been that we do not want to be
“overly reliant” on the ESA to implement the Artificial Production
Review recommendations. There is a potential timing issue here,
Marsh explained, and people have also pointed out that only listed stocks
are affected by the ESA.
According to the draft report, hatchery operators are to submit a
self-evaluation as part of the current funding review process, he
said. There is concern over whether the operators are the right
people to do an evaluation, Marsh reported. Other commenters said
funding artificial production on so short a cycle as annually is “ridiculous,”
he said. The report recommends that once an evaluation has been
done, consistency with the principles, purposes, policies, and performance
standards be required and funds made available on that basis, Marsh
concluded.
Committee Discussion
Waldo referred the participants to page 8 of the draft (Attachment 2)
and asked if the staff’s redraft had adequately addressed concerns that
the artificial production policy would be used as “an excuse” to
de-emphasize legal and Treaty obligations and fisheries. Stephen
Smith of the National Marine Fisheries Service (NMFS) said he thought the
language was much better than the last version.
We might want to address the issue that with dam removal, you take out
the mitigation responsibility, Bill Bakke of the Native Fish Society
pointed out, noting that recent events in Oregon had raised that
point. “That would take us into a few briar patches,” Waldo
observed.
Waldo asked if the language on page 9 that deals with purposes hit the
mark. The language is intended to acknowledge that a program may
have a combination of purposes, and as we learn more, we may shift
purposes over time, he explained. Evaluation should take into
account any change in purposes, Waldo added. We tried to line up the
purposes with evaluation, he said.
Horton suggested that this might be a place in the document to refer to
resident fish substitution. Kirk Truscott of the Colville Tribe said
a better explanation of substitution should be included under the
description of mitigation on page 14. Waldo indicated the staff
would put in some language for people to consider.
Doug Dompier of the Columbia River Inter-Tribal Fish Commission (CRITFC)
suggested that the statement should be broad enough to include both
anadromous and resident fish, since substitution takes place with
both. Would this discussion of substitution include the following
situation: you have a steelhead mitigation goal in one area that cannot be
met, so you substitute a bass fishery in another location? asked Don
McIsaac of the Oregon Department of Fish and Wildlife (ODFW). The
Council’s F&W program is clear that substitution refers to
documented losses in the blocked areas, Horton responded. The type
of program you are talking about is mitigation, she said. The
situation I described needs to be addressed, McIsaac said.
These purposes are intended to describe the reasons for artificial
production, Marsh stated. The issue here is not “what is
allowable,” he said. Waldo suggested that the discussion was
ranging over three situations: the first is the blocked areas, and
for those, you have substitution. Second, below the blocked areas
there are species that are gone or functionally gone, and you substitute
with another fish. Third, you have a mitigation requirement, but due
to whatever factors, you do not meet it with the species intended.
Is there a way to finish meeting the obligation through
substitution? The question is: what set of decisions will you
make to meet the obligation if you are not dealing with a blocked
area? We can capture that, he stated.
Don Campton of the U.S. Fish and Wildlife Service (USFWS) suggested
that a column for “goal” be added to the table on page 12.
Mitigation is a confusing term, he said. The purpose will be
different depending on the goal – whether it’s genetic conservation or
a lost fishery, Campton said.
Is there some reason why there is a distinction between what the SRT
wrote and what appears here? asked Nick Gayeski of Washington Trout.
These purposes are not exactly what was in the SRT report, Marsh
acknowledged. These are amalgams of what the SRT wrote and the
discussions we have had in the committee, he said. I don’t think
they are “untrue” to the SRT, Marsh added. The SRT had research,
preservation, and reintroduction as purposes, Gayeski said. There is
a disjoint between this and what the SRT said, he added. Of the five
purposes, there has not been much debate except on what is called
mitigation, Marsh responded. We had extensive discussions on that,
and it has been controversial -- we have struggled with it, he said.
We will go back and see how these relate to the descriptions in the SRT
report, Waldo stated. “We spent a huge amount of time on this,”
but we can probably clarify it, he said. I doubt it will change
much, Waldo added.
Lee Hillwig of USFWS suggested a wording change on page 14 to clarify
that mitigation is a hatchery purpose that would remain permanently.
We may need a goal statement, Bakke suggested. A goal would help
us relate the purposes to policies, he said. For example,
bio-diversity -- how is that to be achieved by each of these? Or is
one more likely to address it than another? Bakke asked. The
relationship of policies to purposes has not been worked out, he
said. The purposes relate a lot to habitat, but not all problems are
related to habitat, Bakke continued. Sometimes we have good habitat,
but too many strays, he said. The biological problem is not
comprehensively addressed just by looking at habitat, Bakke added.
The synergy between harvest, dam mortality, and drought can cause a
failure in the production system, he said.
Everything is connected, but we have to be careful -- we aren’t
writing the Columbia basin fish plan, Waldo responded. We can’t
let this get too diffuse if we want to make progress, he added.
Hatcheries receive funds because they respond to a problem, Bakke
said. We need to say how hatchery reform will help us address a
dynamic problem, he stated. “It is so simple, it is almost
misleading,” Bakke added.
I would disagree that we have oversimplified, Tim Stearns of Save Our
Wild Salmon stated. We have described five layers of review here,
from purposes and laws and Treaties through basin and subbasin goals, he
said. We have made this a pretty complicated layering, Stearns
observed. Artificial production policies can’t drive the overall
F&W policy in the region, but the converse can’t be true either, he
said. Our challenge is to come up with a more disciplined way of
going through the layers, Stearns suggested. The purposes are not
“good or bad,” he continued. They are only tools to use in this
layering process, Stearns said.
Almost all of the hatchery reviews have said we need to be clearer
about our purposes in the future, Waldo said. These purposes don’t
tell you the outcome, they just help you set up an analytical framework,
he stated.
The challenge is to create a structured way to look at this so all
decisions go through the same process in the future, Stearns said.
“Even good hatcheries get picked on because of the undisciplined way we
analyze performance,” he concluded.
A Crack at the General Policies
Waldo suggested the group “take a crack” at the general policy
statements. Bob Foster of the Washington Department of Fish and
Wildlife (WDFW) referred to page 17, policy 5. I have a
difference of opinion, he said. “Mimicking” the natural
population may not be the most effective approach, Foster said. The
habitat may be so changed, that is not the case, he stated. We tried
to express that as “a testable hypothesis,” Waldo responded. I
also question the way the information is ordered here, Foster said.
It gives the negative view first, followed by a modifier, he pointed
out. Artificial production is being painted as “a bad thing” in
every case, Foster said. I don’t see it that way, Waldo
replied. It is not “a pro or con,” but rather it is how would we
accomplish this, he said.
We need to clearly explain throughout the document when something is a
hypothesis that we are going to test, Horton suggested.
On page 18, policy 6, I suggest you add “only” to the statement,
Gayeski said, noting that the statement would then read: “Production
for harvest is a legitimate management objective of artificial production
only if implemented consistent with the principles and policies described
here.” Stearns suggested that some language could lead to the need
to amend “about 30 statutes.” If this document is stating policy
recommendations to Congress, I don’t see that we are creating any legal
problems by suggesting things that are not in the law now, Gayeski
responded.
Truscott suggested there be some explanation in policy 1 with regard to
“the natural environment.” We are “a far cry” from natural
environmental factors – a reservoir is not a natural environment, he
added. In evaluating whether a program will be successful, you look
at the environment in which a species will be living, Waldo said.
You still need to look at all factors – carrying capacity, species
interactions, and so forth, he added.
We are operating in an environment in which a part is artificial,
Hillwig observed. This policy sounds like all of the components have
to be there, when in fact artificial production may be totally replacing
one of those components, he said. The point is you look at the stage
at which you are interceding -- you look at the life cycle of the fish and
at the other limitations, Waldo said. We need to rework this, he
acknowledged.
We have nothing that explains this basin is an altered environment,
Foster commented. The readers may not even understand that blocked
areas exist, he said. We will go back and make sure that is here,
Waldo replied.
Policy 7 says that for a decision on a preservation hatchery, a plan
must be in place, Horton noted. She suggested that in some cases,
the Kootenai River white sturgeon, for example, a species could be lost if
there is not some provision for a low-cost, temporary measure. But
when do you say “enough is enough” when it comes to a temporary
program? Dompier asked. The solution may be to define “plan,”
Stearns said, adding that it could be something National Environmental
Policy Act (NEPA) based. Use NEPA as the criterion for a plan, he
suggested.
I don’t see anything that addresses a response to “the other four
Hs,” Hillwig said. How do we integrate with them? he asked.
Policy 1 is labeled the “core” policy, Bakke pointed out.
Aspects of policy 4, which deal with “the animal,” should be reflected
in policy 1, which deals with the environment, he suggested. Number
1 is not tied to the attributes of the animal, Bakke said. That
makes complete sense, Campton agreed. Policy 1 should say something
about maintaining the biodiversity of these resources, he added.
Why not take out the statement that policy 1 is a “core” policy,
Allee suggested. That seems to set up the idea of a priority here,
and it makes “a value judgment,” he observed. Yes, that may be a
better way to get at the issue, Waldo agreed.
Gayeski suggested policy 4 become policy 1. Congress will
remember the first thing listed -- it’s a tactical issue, he added. We
would not want policy 4 first, Dave Johnson of the Nez Perce Tribe
said. There is not consensus on moving those items, he stated.
Guidelines and Performance Standards
The issue is how do we get to a more specific translation of these
policies, Waldo said. The draft report says that the Council does
not now intend to recommend a definitive set of guidelines and performance
standards, but they will be developed by September, he indicated. We
didn’t feel we could work through these before we needed to submit the
report to Congress, and we didn’t want to do a hasty job since they will
be very important, Waldo explained.
The first set of performance standards will be generic and not specific
to facilities, Dompier observed. I can see the value of doing them
for each hatchery, he said. Dompier suggested a generic set of
performance standards be developed, put out for some public review, and be
made part of the report to Congress. We have to finish this,
he urged. “Everybody gets some breathing space,” and then the
next step, developing individual performance standards for each hatchery,
becomes most crucial, Dompier said.
We are delaying this again, Bakke said. We should make this a
complete report to Congress, he added. Why aren’t the SRT
guidelines on implementation in here? he asked. I don’t see this
as slowing or “watering down” the report, Waldo responded. With
a focused effort, we could get them done in pretty rapid time, he
said. If your question is whether this is an attempt “to punt,”
that is not my view, Waldo added. There is “a lot of meat” here
for Congress to absorb, and the rest can follow on, he said. On page
20, we indicate other important documents relative to artificial
production, and the SRT report is in the list, Marsh pointed out.
The performance standards will be a tough process to pull off, Stearns
observed. When we get to performance standards, we may revise this
document, he said. If you can’t measure or monitor it, it may not
be worth considering – some of the policies may become inoperable once
the performance standards are developed, Stearns suggested.
We have crafted this so policies and principles would not need to be
changed, Waldo replied. The rest is getting at the applications at
“a finer grain of detail,” he said. There will be more work, but
we do not envision changes in policies and principles, Waldo stated.
You may not need to make changes, Stearns agreed.
The Phase I deliverable to Congress is in July, Allee summed up.
We have a start on Phase II, with a deliverable to Congress at the end of
September, he continued. Doug is suggesting that ultimately you go to
individual hatcheries and classify each with purposes and objectives --
that is Phase III, Allee said. In my view, this is where we are
going, and outlining this to Congress would be satisfactory, he stated.
This afternoon when we discuss implementation, we can talk about this
further, Waldo said. Bill has expressed reservations that we are not
doing the performance standards now, he added. What is your reaction
to this approach? Waldo asked. I like it, Smith responded.
Generic performance standards is where we want to go, followed by
finetuning to the details of a facility, he said. This dovetails
with what we are doing in the ESA, Smith added.
I agree, Foster said. At this point, this is an unfunded activity
-- if we want to use BPA funds, we cannot fund this until 2000, he
observed. In the ESA, we are trying to prioritize which hatcheries
need things sooner than others, Smith said. Then we lay out the
priorities over a period of years to get actual individual plans, he
explained. There are quite a few remedial actions, like those
outlined by IHOT, that have to be dovetailed, Tom Rogers of Idaho
Department of Fish and Game pointed out.
I have the same concerns as Bill Bakke, but I understand the
difficulties, Gayeski said. He suggested that a risk assessment and
protocol are needed to deal with what to do when funds are not there.
With regard to performance standards, the SRT report made it really
clear that it would be inappropriate to have a generic set of standards
applied to both anadromous and resident fish, Truscott said.
Congress is gone much of July and all of August, Stearns said. If
we hand them something now, they will have trouble processing it right
away, he observed. Stearns cautioned against missing the September
deadline due to the schedule of Congressional budgets. He also
suggested some prototype testing of performance standards be done.
We need a fairly decent analysis of what it will take to implement and
what we will do with the data, Stearns continued. We have a few
hundred facilities, and we have to come up with a sensible program to do
this, he said. The more orderly we demonstrate we can do it, the
more likely we are to get funding, Stearns said. “I don’t want
to see this be an unfunded mandate that managers resent,” he added.
This is an unusual appropriations year, observed facilitation team
member Dan Evans. This is a year when the decisions will be made
late, so there may be some “wiggle” room, he said. I wouldn’t
give up on the 2000 budget yet, Evans added.
Hillwig questioned the structure of the guidelines and performance
standards section. It starts out with the SRT concept, which “in
theory” is good, but in practice may not work, he said. Putting
this first may not be the best approach, Hillwig suggested.
Will we not include the guidelines from the SRT report in this report?
Bakke asked. The Council is intending to forward the SRT report as
an attachment, Waldo replied. The performance standards will use the
SRT guidelines, but they are not limited to them, he added. The
Council position is that there are a number of sources from which you can
draw for performance standards, Waldo stated.
This raises the question of why convene the SRT if staff treats its
report as one more among many reports, Gayeski said. My feeling is
that you should include the SRT recommendations as part of this report, he
stated. For some of us, that was not such a good report, Dompier
pointed out.
I think the Council staff is taking the SRT recommendations very
seriously, Waldo stated. But it is not the only thing that will be
considered, he said. The Council treats the SRT report as a very
serious document and one they intend to use as part of their
decisionmaking, Waldo reiterated.
It’s difficult to understand what the guidelines are supposed to
accomplish without stating the goals, Campton said. We are
developing performance standards for each purpose, Marsh said. There
are benefits and risk indices that will be addressed, he said. “I
think this works,” Marsh stated. One of the recommendations is to
develop natural rearing technology, Campton said. What is the
goal? Why are we doing that? he asked.
I agree that a goals column needs to be on the page 12 table, Gayeski
said. What hasn’t been mentioned is the desire to prevent
domestication of fish to the artificial environment, Campton said.
This is a report to Congress, Smith responded. There is room ahead
to put in the detail, he said.
Don is correct, Allee observed, but that is a level of detail that may
not be appropriate to this report. Postulating genetic effects is
something that may be dealt with in the performance review process, he
said. In my view, we are proceeding in ever-increasing levels of
detail, Allee stated. It is an appropriate issue, but it is in the
next step, he said.
Implementing the Artificial Production Policies
Smith said NMFS is looking for implementation that clearly demonstrates
the policies are achieving the goals of hatchery reform. We now have
six or seven processes that are reviewing hatcheries, he observed:
U.S. v. Oregon, ESA with its biological opinions (BiOps) and recovery
plans, the Council’s F&W program and BPA funding, the multi-species
framework, Congressional funding, and the federal caucus. I’m
interested in looking at this menu of choices and deciding where we can do
our work, Smith said.
He noted that NMFS put out a BiOp on hatcheries in March and is now
looking at developing hatchery and genetic management plans. We are
trying to get those lined up with what is going on in this process, Smith
said. My interest is how we can implement reform and find ways to
defer to existing processes, so “we do it once and do it right,” he
stated. Smith said NMFS has developed a draft template for the
hatchery and genetic management plans and is looking at how to do risk
assessments. He indicated that hatchery managers should only have to
do one, not multiple plans. We should have an aligned process to
show Congress, according to Smith.
Waldo asked where the Artificial Production Review fits in, and Smith
said it will lead to what hatchery objectives will be. Gayeski
suggested that the issues of wild population trending and how wild
populations will be impacted by the policies should be addressed.
Smith said people are frustrated by all the processes. If we keep
doing all of these processes, what value are we adding? he asked.
There is a big cost in terms of time, money, and distraction, Smith said,
and we need to make sure that all of the process is adding sufficient
value for the time and effort. The process is slowing down the pace
of reform, he stated.
We have people doing work in four processes, Hillwig observed.
Maybe we could develop an agreed-upon way for one piece of work to fit
into several processes, he said. Maybe you can’t get everything
into one process, but you can share among them, Smith said. The
performance standards we develop should be identical to what is in the ESA
process, he added.
“I was optimistic this morning about developing performance
standards, but I am losing my optimism,” Dompier said. ESA is not
the “end-all” process, he stated, adding that he did not think the
region has to ask NMFS “to bless our work with your BiOp.” ESA
is just another process – they write the BiOp to fit their needs,
Dompier said. They have to bring their process to the table to be
reviewed and looked at, he continued. None of these processes is
higher than another, Dompier said. “The ESA isn’t doing us any
good on this river,” he stated.
I’m not talking about authority, Smith responded. Everyone
keeps their authority -- I’m talking about documents and products that
feed into the decisions, so we don’t have to do these things repeatedly,
he said.
Waldo observed that agencies, like NMFS, can’t cede their
authorities, but can come together to make decisions that are
compatible. That’s better than being ignorant of one another, he
said. If something under the ESA covers the same subjects that are
being dealt with elsewhere, we can join them, Waldo said. Some
things will have to be “thrashed out,” but where there are not
disagreements, we can accelerate the pace of reform, he stated.
Whither Goest U.S. v. Oregon
For those of you involved in U.S. v. Oregon, how does it interact here?
Waldo asked. “I have heard that victory is not immediately around
the corner,” he said.
Our plan is that as we are negotiating, we try to resolve our ESA,
Treaty, and fisheries restoration obligations, Smith said. We are
trying to be sure we balance all three mandates, he added. What if
there is a conflict between Treaties and the ESA? Stearns asked. We
work it out there, Smith replied. Are you reliant on Council funding
to implement the outcome? Stearns asked. Would you expect the
Council to accept the outcome? he inquired. We want all plans to
align and pass muster with funding, Smith responded.
Where does the multi-species framework fit in? Stearns asked. We
are starting to engage the framework and the federal caucus, Smith
explained. Within the federal family, there has to be consistency in
where we are going in all of the processes, Hillwig commented. We
are not going in one direction in U.S. v. Oregon and another elsewhere, he
added.
For those of you in U.S. v. Oregon, is there a realistic expectation of
coming to grips with these issues? Waldo asked, adding that it has been
assumed that decisions out of those negotiations would point the way to
funding and policies. There is also a concern about how this marries
with the framework, he added. Maybe what we have to do is
acknowledge there is an existing process and get on with this hatchery
evaluating, Dompier responded. If the Council puts something out
signaling that its involvement will be through re-evaluation of
hatcheries, that might be just the thing needed to get people talking, he
continued. I don’t think we should stop because of anything else,
Dompier added.
I don’t see U.S. v. Oregon breaking down, Smith observed. A lot
has been done, but “a real time issue took precedence,” and in time,
the energy will go back into long-term negotiations, he said.
Getting the Timing Right
The report recommends re-evaluation of hatcheries over three years,
Waldo said. Is this the right period of time? he
asked. Three years may not be bad, if you figure the
first audit isn’t critical, Foster responded. With IHOT, it took
us four or five months to come up with the initial evaluation, he
said. My reaction is not unfavorable, Foster stated.
Three years is fine, Dompier said. With regard to who should
oversee the re-evaluation, we will need facilitation as we get started,
but it should be dropped after the first few meetings when the
difficulties are worked through, he observed. Dompier suggested
there be an evaluation team for resident fish and another for anadromous
fish, and that they should include a mix of members -- managers, tribes,
power-side representatives, and Council reps. “This should not be
secret,” he stated. I view this as very doable and it could
proceed immediately as the performance standards are finalized, Dompier
added.
IHOT involved a focused technical audit, Rogers said. This will
look at a lot more things, so it will take more time, he commented.
Funding will be a significant problem, Rogers added. Gayeski
suggested some “high-profile” facilities be selected to undergo a
prototype audit with costs, ecological impacts, interactions, and the IHOT
findings. We need a template for what the evaluations should look
like, he added.
Would there be value in a preliminary assessment to get an initial idea
of what is involved? asked Brian Walsh, NWPPC staff. Smith noted
that in the March BiOp, NMFS put the most problematic hatcheries first on
an evaluation list.
This will be a big job, and it will take a lot of time and funding,
Hillwig observed. We don’t have the staff to launch into it, he
said. It will take serious planning, and it will be important to get
with key people to come up with a proposal on how to proceed, according to
Hillwig.
Waldo agreed. We view this “as the start, not the end of the
conversation,” he said. Bob Lohn knows it will take money, and he
will try to find it, Waldo said. We need to think through the
planning, he continued. On the one hand, we need to pick a few
evaluations to do to try this out, and on the other, we need to do some
in-depth work, “understanding there are systemwide issues that will not
sit and wait,” Waldo explained. How do we address both of these?
he asked.
Is there merit in selecting hatcheries that represent each of the
purposes? Allee asked. He also suggested that the IHOT process might
be something the group could build on. The IHOT audits cost over
$500,000, and that’s got to be something valuable to build on – it’s
an essential data set, Allee stated. “We can reinvent an acronym
since IHOT was defunded,” but the process incorporated a comprehensive
group of folks from around the basin – the representation covered
everybody, including FERC-licensed projects, he said.
NMFS is talking about developing hatchery and genetic management plans,
Dompier observed. How about taking the first ones and using them as
our starting point, he said. That may be something to take into account,
depending on NMFS’ schedule, Waldo indicated. We set our schedule
based totally on the ESA schedule, so it may not work perfectly, Smith
said. If we have agreed-upon policies and performance standards, we
won’t need to do this as a committee – “if all the game rules are
laid out, an agency or tribe could bring in the first draft,” he said.
In the Yakima hatchery, we have implemented all of the SRT
recommendations, and we have been monitoring for genetics, survival,
reproduction, and harvest, David Fast of the Yakama Indian Nation
said. “I can say that BPA does not have enough money to do this at
100 hatcheries,” he stated. It’s going to take a long time and a
lot of money, Fast said.
Stearns drew an analogy between evaluating hatcheries and doing energy
audits. After spending a lot of time and money on individual audits,
it was clear that we put roughly the same amount of insulation in each
house, he explained. Stearns also indicated that with energy
conservation programs, a lot of data was gathered, 90 percent of which
didn’t matter. That’s why I’d propose doing prototypes that
could tell us what we need and what we don’t, he suggested. “Do
overkill on the first ones, but then figure out what is relevant,”
Stearns recommended. And first talk to the guys who went through
IHOT, he said. “Data for the sake of data isn’t worth it,”
Stearns added.
Just the sheer number of facilities means it will be an involved
process, Hillwig said. I don’t think we can resolve it at this
table, he said. My thought is that a smaller group will have to come
together to plan this, Hillwig suggested.
We have a lot of different kinds of “houses,” Rogers said in
response to Stearns’ analogy. We can’t compare upriver
hatcheries to the Yakima hatchery, for example, he stated. The
concept is to pick a number of facilities where you are looking for
certain activities, Waldo said. A smaller group can sit down to plan
how we do this, he added. Waldo summarized the comments and
acknowledged that the Council staff needs to think through how this is to
be integrated with the framework and Council processes.
We have three major initiatives being talked about here, Smith
observed: first, the report to Congress; second, Brian’s ad hoc
team on performance standards; and third, we are talking about another ad
hoc team to look at the process and implementation issues. How do we
take this to the next step? Waldo asked. We could have another work
team take a stab at it, he suggested.
Are your concerns being addressed as we proceed? Waldo asked Bakke.
I don’t feel any lack of opportunity to be involved, Bakke replied.
Is Self-Evaluation an Effective Approach?
What do you think about self-evaluation? Waldo asked. “When I
saw this, I thought this is something we should not do,” Dompier
responded. If someone wants funding, then we should evaluate what
they are doing, he said.
I disagree, Smith stated. I think the facilities are going
through a lot of changes now, and “we will see more after the next BiOp,”
he said. I think maybe we ought to focus here on performance
standards and have managers apply them to their own facilities to
determine where they stand, Smith said. Then let the entities
evaluate their own facilities based on the standards we’ve agreed to, he
recommended. If their performance is not adequate, get an
independent audit, but let the managers bring forward their review, Smith
urged.
A funding review is negative, Hillwig said. I think it should be
performance, he added. We also have PUDs and others operating on a
different time frame than the Council’s funding process, Foster
observed. Self-evaluation is the way to start, he said.
I’m not sure there is a conflict between a funding review for major
renovations and having a performance review, Gayeski said. In a
self-evaluation, there is a good reason not to have the connection with
funding be a big driver, he stated. Obviously you want to ask the
hatchery manager to be involved, but if sustained funding is the issue,
the public is entitled to an independent review, Gayeski stated.
Stearns suggested that an accreditation approach like that used at a
college could work. The school first does its own evaluation and
then a team of experts visits to see first hand what is going on, he
explained. It’s a pretty good model, Stearns added. After
this process, you determine whether a facility is in compliance or needs
improvement, he said. “I am nervous about putting this into the
funding cycle – managers will hate it,” Stearns stated.
After the accreditation review, an institution can decide whether to
commit resources to making needed improvements, Waldo pointed out.
“It’s not taking money away, it’s putting the institution in a
position of making choices,” he stated.
BPA spent a lot of money on the IHOT audits, Allee said. An
interdisciplinary team went out and visited the hatcheries, and those
audits have not been used much, he said, adding that the IHOT data could
be a departure point for the evaluations. I hope we are trying to
find key indices and planning to begin to apply those to hatcheries based
on their purpose, Allee indicated. It may be that for some
hatcheries, the recommendation is that they be closed because it would be
too expensive to bring them up to standard, he said.
This sounds like the discussions when we began – there was fear this
effort was to close hatcheries, Dompier observed. That’s “a bad
message” – it’s better to say we will modify, he added. We
want to get programs operating to improve things for fish, Dompier
continued. It’s not a good idea to self-evaluate, he reiterated.
Somewhere along the line, there has to be a way to say the failure may
not be due to hatcheries, Rogers commented. Smith said he could
envision a web site that had all of the information about a hatchery,
including performance, that could be used for making investment
decisions. If an entity in charge of a facility is not meeting the
standards, then you ship someone in there to look at the program, he
suggested.
It’s important to prioritize the remedial actions on a basinwide
scope, George Nandor of ODFW said. “I’m leery of an
accreditation system” for “the good hatchery seal of approval,” he
indicated. It’s more important to get improvement for the dollars
spent and not “blackball” hatcheries, Nandor said.
Hatcheries are in transition, Hillwig said. We need to get
hatcheries to where we want them to be, but not talk about shutting them
down, he said. Shutting hatcheries down and restarting them is an
expensive thing to do, he observed. We need to look at where we need
to make improvements without the threat, according to Hillwig.
If people feel threatened, you don’t get change, Waldo stated.
This is not a program to justify “everything that is going on” – it
is an opportunity for change, he said. We are trying to figure out
how to work through this transition time and take advantage of the
opportunity, Waldo said.
We are trying to create “a safe way” to reform this program,
Stearns agreed. I don’t want to shut down hatcheries, he
said. It’s important to keep moving in the spirit of getting
through the transition, Stearns added.
If I were CEO of a Fortune 500 company brought in to turn things
around, but I assured everyone that no one would lose a job and no
facility would be shut down, would you have confidence in me if I took
that off the table first thing? Gayeski asked. We are natural
resource agencies and are not about “making a buck,” Hillwig
responded. We have to base things on the risk to the resource,
he added. We are working in an area where the science is not always
clear, and we have a lot of constituencies to serve, Hillwig said.
He indicated that he was not saying “we should protect facilities
at all costs,” but that there are other factors involved.
People make these types of decisions in the corporate world, but they
do it with employee morale in mind, Gayeski said. The message should
be that decisions will be thought out and fair, but it’s not off the
table, he stated. We owe those in the basin who fund the programs
and who have an interest in the resource an assurance that hatcheries meet
performance standards and operations are well done, Gayeski urged. I
don’t think we can assure them of that if we take the option off the
table, he added.
Next Steps
Steve has recommended that a small group come up with recommendations
on implementation, and the performance standards group will continue to
meet, Waldo summed up. This committee will probably meet a couple of
times between now and September, he added.
Would the new subgroup create an array of choices? Stearns asked.
Not that you would have a joint body with the other processes, but a
common analytical base? he inquired. Some decisions cannot be
combined, but we may be able to combine some issues, Smith
responded. Consultants may need to be involved in that process, he
added. I would like to see this second group as the place we can
take ideas about funding, Waldo said.
As an issue of trust, neither subgroup should put anything out without
the approval of the whole committee, Smith suggested. Waldo agreed.
The PRC will meet again on July 12, and at that time, there will be a
redraft of the report and recommendations, with today’s comments and any
written comments we receive, Waldo said. That will be the final to
go before the Council in July, he added. Lohn pointed out that the
report would need to go to the Council’s Fish Four first.
The calendar is: June 22 for comment deadline on the draft report
and July 12 for a PRC meeting, with a report from the performance
standards and implementation work groups. Waldo said the revised
draft report will go out to committee members shortly before the July 12
meeting. Several people volunteered for the implementation work
group, and Waldo said others may be called upon to serve.
Adjourn
Production Review Committee
June 14, 1999 Meeting Attendees
Brian Allee, Columbia Basin Fish and Wildlife Authority
Bill Bakke, Native Fish Society
Barry Berejikian, National Marine Fisheries Service
Don Campton, U.S. Fish and Wildlife Service
Doug Dompier, Columbia River Inter-Tribal Fish Commission
Dan Evans, Gordon Thomas Honeywell
David Fast, Yakama Indian Nation
Tom Flagg, National Marine Fisheries Service
Bob Foster, Washington Dept. of Fish and Wildlife
Mark Fritsch, Northwest Power Planning Council Staff
Nick Gayeski, Washington Trout
Jeff Gislason, Bonneville Power Administration
Shari Hildreth, Senator Slade Gorton’s Office
Lee Hillwig, U.S. Fish and Wildlife Service
Stacy Horton, Northwest Power Planning Council Staff
Rayola Jacobsen, Northwest Power Planning Council Staff
Dave Johnson, Nez Perce Tribe
Bob Lohn, Northwest Power Planning Council Staff
Paul Lumley, Columbia River Inter-Tribal Fish Commission
Joe Maroney, Kalispel Tribe
John Marsh, Parametrix/Consultant to Northwest Power Planning Council
Desmond Maynard, National Marine Fisheries Service
Chip McConnaha, Northwest Power Planning Council Staff
Don McIsaac, Oregon Dept. of Fish and Wildlife
Bj Mirk, Gordon Thomas Honeywell
George Nandor, Oregon Dept. of Fish and Wildlife
Pat Oshie, Yakama Indian Nation
Tom Rogers, Idaho Dept. of Fish and Game
Stephen Smith, National Marine Fisheries Service
Tim Stearns, Save Our Wild Salmon
Kirk Truscott, Colville Tribe
Keith Underwood, Spokane Tribe
Jim Waldo, Gordon Thomas Honeywell
Brian Walsh, Northwest Power Planning Council Staff
David Wills, U.S. Fish and Wildlife Service
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