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NWF.048/Dec.02.1997
[1] Fiscal, Biological Value of NMFS Flow Proposals Questioned
[2] Tribes Sue Council Over Halt In Salmon Funding
[3] Groups File Petition on Middle Snake Dams
[4] Mid Columbia PUDs Close to Agreement on Habitat Plan
[5] Council Reopens F&W Program, Citing "New" Science
[6] Hatchery Funding Restored
[7] NW Govs Meet With Canadians Over Salmon
[8] Consultant Says Barging Has Helped Idaho Runs
[9] Washington Trout Finds Lost Salmon Habitat



[1] FISCAL, BIOLOGICAL VALUE OF NMFS FLOW PROPOSALS QUESTIONED

Consultant Darryll Olsen last week told a roomful of water users in Olympia that there isn't enough water in the Northwest to meet flow targets proposed by the federal government for salmon recovery in the Columbia Basin. He said the proposed water policy should be rejected because it represents a total disconnect from the biology of the system. Olsen said NMFS' plan for flow augmentation should be completely restructured to allow more flow for fall migrants.

At a Nov. 25 meeting of the Washington Water Power Alliance, Olsen said the bottom line benefit to fish from added spring flows would be on the order of only two percent. "For all practical purposes, we can't measure it." He said that about 60 percent of the juvenile fish survive from Lower Granite to the estuary in low-water years, with a combination of barging and inriver migration.

Olsen said the issue probably won't be settled until it reaches the Congressional hearing stage. He said a lawsuit is "inevitable" to determine whether NMFS has the legal right to usurp water rights granted by the state.

One big problem with the federal proposal, he continued, is that there's usually not enough water in the basin to meet the targets anyway. "As the system is now operated, flow targets could not be met," he said. "Even operating at natural river level, it could not be met, with or without irrigation."

Olsen was reading from a white paper being developed for irrigators in Washington, Oregon, and Idaho by his firm, Pacific Northwest Project, with help from Harza Northwest and Columbia Basin Research at the University of Washington. The document, which will be available later this month, takes issue with the proposed NMFS flow strategy, a program that calls for no new withdrawals of water from Columbia or Snake basins, tributaries, or groundwater. According to Olsen, the proposed policy calls for a moratorium on new water permits and requests federal and state agencies rank existing water withdrawals for their importance to salmon habitat.

Olsen said the NMFS proposal calls for 13 MAF to 16 MAF in added flows annually, which is more than all the water used for irrigation in western Montana, BC, Oregon, Idaho and eastern Washington. But an analysis of the past 50 years' worth of flows shows that natural variations from year to year completely overshadow irrigation withdrawals, he said.

What Water is Worth

Olsen gave the audience his estimate of the economic benefits of water use, which valued one MAF at $40 million to $70 million if it went to irrigated agriculture; $8 million to $12 million if it was used to create power; up to $2 million in net benefits to sports and commercial fishermen if it was used to augment flows for fish, or $4.25 million in use and "existence" values if used to augment flows for fish. Olsen said these last two estimates were "very liberal."

He told the water users that if the region pursues the full transportation option, which means barging 80 percent to 90 percent of juveniles in the Snake past the dams, "it makes no sense to have a flow augmentation program." Without it, BPA could save $40 million to $60 million annually.

Olsen didn't go into the specifics of the savings, as he did earlier last month, when he presented the BPA low-cost option at a Spokane meeting that dealt with future fish and wildlife costs. Using NMFS evaluations for fish transport and flow survival data from 1993-1997, plus several other recent studies, Olsen told the Spokane group that a full transport option that collected 80-90 percent of the Snake River juveniles, and 50-70 percent of the fish at McNary, would keep future fish and wildlife costs in the $400 million to 500 million annual range during the time frame of the next MOA from 2002 to 2006. Capital costs would be reduced by penciling out some dam improvements slated for the future, which included extended length screens at John Day, The Dalles, and Bonneville.

With a full transport option, Olsen said average water years would have no augmented flows in the spring, but summer flows would be boosted 1 MAF in the Snake and 1 MAF to 4 MAF in the Columbia. In low water years, he said spring flows in the Snake could be augmented by .3 MAF for pulsing and experimentation, and summer flows would be increased by the same amount as in average water years.

The capital cost savings from such a plan would be $270 million to $500 million or $20 million to $40 million in annual savings, with another $40 million to $60 million saved yearly from the restructured flow augmentation program.

Water users also heard from Curt Smitch, an assistant to Washington Gov. Gary Locke on natural resource issues. Smitch heads up the Joint Natural Resource Cabinet of state agency heads, where he said all efforts are focused on the potential steelhead listing in the lower Columbia, and soon on the Puget Sound chinook. "If NMFS sees we have a process," said Smitch, "we'll get some time. If not, they'll step in and do the best they can do."

Smitch said Gov. Locke is "in close contact" with Oregon Gov. Kitzhaber over the steelhead issue, and hopes to head off a listing, but they are getting a plan ready just
The fruits of irrigation - apple country near Yakima
in case. He said many folks were still in a state of denial over the potential ESA listings, but a new focus on agricultural and municipal water use is coming. He noted that 65 percent of the state's population resides within the range of the Puget Sound chinook, which will probably be listed next January.

Bern Shanks, director of Washington's Fish and Wildlife Department, said Washington's wild salmonid policy would be enacted within a few days and would lead to a comprehensive review and assessment of the hatchery system. With over 100 fish production facilities, Shanks said the state has more hatcheries than "any other government in the world."

He told the water users that a "rational" approach would produce more fish for sportsmen rather than commercial fisheries because such a strategy made more sense from an economic viewpoint. He acknowledged the unpopularity of some of his views when he said his associates had reminded him that the tenure of a WDFW director is shorter than the lifespan of a coho.

NMFS policy lead for habitat planning Bob Turner said his agency is not trying to be "Public Enemy Number One." He said NMFS will try to work with water users over withdrawal issues, but he said third party lawsuits tended to "break that up." He cautioned the group that the sooner they got over the "sticker shock" of dealing with federal listings, the better for all, "because it will be expensive."

Bill Wilkerson, director of the Washington Forest Protection Association, said water users shouldn't be afraid of NMFS. "They don't really want to come in and 'do it to you.' They don't really know what to do." He said the federal courts, on the other hand, really were something to be afraid of. "Nobody thought a federal judge would give half the fish to the tribes," said Wilkerson. He said the spotted owl controversy taught his industry that litigation was not the way to go. "The public is sick of our economic argument. They want us to rebuild these stocks."

State legislators Dan Swecker and Dave Mastin described the 25-member task force that is beginning to deal with salmon recovery issues. Swecker said watershed planning is a 10-year process, but he didn't think NMFS was going to give them that much time. "The ideal way of restoring wild stocks is sheer baloney," said Swecker, "because the tribes won't allow it." -Bill Rudolph



[2] TRIBES SUE OVER HALT IN SALMON FUNDING

The four tribes that make up the Columbia River Inter-Tribal Fish Commission have made good on their threat on Nov. 13 and have taken the Power Council to court over next year's salmon recovery funding. They filed a petition with the Ninth Circuit Court that asks for a review of the Power Planning Council's 1998 annual work plan. The Council has held up over $45 million in funding for tribal hatchery projects and other salmon recovery proposals, pending further scientific review.

But Council chair John Etchart said the lawsuit would not stop efforts to bring greater scientific and fiscal accountability to fish and wildlife recovery efforts. "This isn't about who did what to whom," said Etchart. "It's about the best way to bring back salmon." Both Congress and Northwest citizens have asked for greater accountability, he added.

In September, the Council recommended $94 million in fish and wildlife funding, mostly for tribal projects. Most deferred proposals include new fish production facilities and habitat improvement projects. The Council acted on recommendations from a panel of independent scientists, who called for more scrutiny of basin-wide hatchery practices and habitat actions.

"The tribes say we cut their hatchery and habitat projects. We didn't," said Etchart. "We deferred spending on new hatchery and habitat projects only until the appropriate scientific reviews are complete. Ongoing projects receive continued support because they've already received adequate review."

But Bill Yallup, chairman of the Yakama Indian Nation Fish and Wildlife Committee, said the tribes have already gone the "extra mile" on scientific review of their projects. "Now is the time for action," he said. Yallup said the delay is the antithesis of the Council's adaptive management strategy, a policy put in place almost 10 years ago.

In a Nov. 13 press release, CRITFC director Ted Strong said the Council program was criticized by its own group of independent scientists, who said it lacked a coherent vision. He said the Council was now using that lack of vision to keep the tribes from implementing the vision articulated in the tribal fish plan.

"The Council has not convinced me that cutting funding for tribal projects is anything other than discrimination against the tribes," said Strong. "There is no science here. I have yet to see an explanation of how the tribal projects are inconsistent with the existing Fish and Wildlife Program."

Power Council chair Etchart said tribal projects have not been unfairly singled out for review. "Most of the hatchery and habitat projects we fund are sponsored or co-sponsored by the tribes," he said. "And because the tribes are involved in most of the projects, it makes sense they would be heavily affected by the deferrals." -B.R.



[3] GROUPS FILE PETITION ON MIDDLE SNAKE DAMS

American Rivers, the Earthjustice Legal Defense Fund and six other environmental and fishing groups have filed a petition with the Federal Energy Regulatory Commission, asking them to begin formal ESA consultation on Idaho Power's Snake River projects. The groups--which also include the NW Environmental Defense Center and Trout Unlimited--claim Idaho Power's middle Snake River hydro projects threaten the survival and recovery of salmon and steelhead. They want the utility to change the way it operates the eight dams, including the Hells Canyon complex, that produce over 1300 MW of generation.

"Idaho Power has projects that have a far greater impact on salmon than the mid-Columbia dams," said Lorri Bodi of American Rivers. "The best fall chinook habitat was above the Hells Canyon complex." The utility should contribute to "achieving flow targets on a more consistent basis," she added.

Formal ESA consultation is the way to do that, the groups contend; and the National Marine Fisheries Service seems to agree with them. Both NMFS and American Rivers are already involved in the collaborative process started by Idaho Power in preparation for relicensing of its middle Snake projects, but the groups say that's not the forum for a discussion of how current operations affect endangered fish stocks.

"This is an issue of what immediate mitigation [Idaho Power] is going to provide between now and relicensing," Bodi said. The projects in question aren't close to final relicensing, she said; and the groups' attention to "the needs of fish now" is not inconsistent with their involvement in the collaborative relicensing process.

FERC won't comment on the petition, which was filed Nov. 17. But the agency has responded negatively to both NMFS' and the environmental groups' earlier suggestions for formal consultation. In a May 13 letter to Earthjustice and the NW Environmental Defense Center, Elizabeth Moler, then chair of FERC, expressed disappointment that the groups had "chosen this forum rather than the ongoing Snake River Collaborative Team to address this issue." She also disagreed with the groups' implication that FERC has ignored the needs of endangered Snake River salmon by not formally consulting with NMFS. "I believe that FERC would not hesitate to request formal consultation...if Idaho Power were not cooperating or if such consultation appeared necessary to avoid adverse effects on Snake River salmon," Moler said.

NMFS Requests Biological Assessment

Since Moler's May 13 response, NMFS has sent two letters to FERC requesting a formal consultation process. In the most recent letter, NMFS regional administrator Will Stelle disagreed with FERC's view that participation in the collaborative process makes formal consultation unnecessary. Stelle told FERC chair James Hoecker that such informal discussions do not replace FERC's responsibility to determine if current Snake River operations are "not likely to adversely affect" endangered species--and to get NMFS' concurrence on that point. "The burden is still on the Commission to show the absence of likely, adverse affects on listed salmon from the licensed operation of the Hells Canyon Project to be excepted from the formal consultation," Stelle wrote, and requested FERC prepare a "biological assessment to evaluate the current likely impacts of the Hells Canyon project on listed salmon and their critical habitat."

Idaho Power spokesman Russ Jones said the utility is not opposed to conducting a biological assessment. He added, however, that as recently as an April 10 Snake River operations meeting, NMFS indicated the utility is in compliance with the biological opinion on Hells Canyon operations. "Everybody at that meeting agreed the company was in compliance, except the Oregon Department of Fish and Wildlife," Jones said.

He also pointed out that Idaho Power doesn't operate its projects just to meet the needs of anadromous fish. "The proposals these groups are making would take all of the water in Idaho."

The ultimate goal is to achieve more natural river conditions for salmon runs on the Snake, according to American Rivers' Bodi. There are two ways to do that, said Dan Rohlf of the Pacific Environmental Advocacy Center: one is "retiring" the lower Snake River projects; the other is moving as much water as possible down the river to help the fish get through. And that would affect Idaho Power's Snake River projects. If there were a plan in place to breach the lower Snake River dams, Bodi said, the groups "might be taking a different path;" but for now, the only alternative is to get more water out of Idaho reservoirs.

But according to Idaho Power, the federal dams on the lower Snake and Columbia Rivers, along with overfishing by commercial fishing interests, are the real problem. The utility said the fall chinook run had dropped from about one million fish in 1890 to about 50,000 fish in 1955--before the Hells Canyon complex was built. "It's doubtful at that time the habitat was fully used," states an Idaho Power fact sheet. The utility also points out that in 1950 the US Department of the Interior recommended development of the Hells Canyon dam sites instead of the four lower Snake projects. But after Idaho Power had developed its Hells Canyon complex, the federal government proceeded with the lower Snake projects "even though it still had not solved the problem of how to get anadromous fish past them."

Earthjustice attorney Todd True said if the company genuinely believes the lower Snake projects are the problem, it should support efforts to breach those dams. "A solution that involves bypassing the Lower Snake would require less water" from Idaho Power projects, True said. But even if the utility were to come out with a letter of support for that approach, he said the groups won't drop their petition to FERC.

Pacific Environmental Advocacy Center's Rohlf said the federal agency has thirty days to respond to the groups' petition, after which the groups can file a petition for a rehearing. After that, the groups have the option of asking the Ninth Circuit Court to force FERC to initiate consultation. -Jude Noland



[4] MID COLUMBIA PUDS CLOSE TO AGREEMENT ON HABITAT PLAN

Mid-Columbia PUDs are closer than ever to signing off on a habitat conservation plan being developed to aid fish. But before Grant County PUD officials OK the package, they want to make sure the expensive program will produce results. Details are sparse, but the plan will include a mix of habitat restoration and hatchery supplementation of wild runs, as well as passage improvements for juvenile fish.

Improvements in the mid-Columbia may help, but questions remain over the uncertainty of ocean effects on fish populations. A 1992 study by the Washington Department of Wildlife concluded that although dams could have an effect on regional populations, similarities in steelhead abundance and declines throughout the West Coast indicated that ocean conditions were primarily responsible for survival trends.

The ante has gone up considerably since 1994, when planning for the HCP began in an effort to head off an ESA listing for the region's wild steelhead. NMFS listed the fish as endangered last August, and since then, the federal fish agency has worked with the PUDs, FERC, state agencies and tribes to craft a mutually agreeable plan to help improve the wild stocks.

But Grant County PUD officials complained in September that the cost may be too high. PUD manager Don Godard said spending on tributaries was proposed to go from $60 million to $100 million over the 40-year life of the agreement. He said it was unfair to his county and that the expenditures were not likely to help fish runs directly.

Last week Godard said his utility is willing to devote all its resources to aid fish. Before they commit to the HCP, however, they want to be sure it's more than "just another bite out of the apple."

Godard said it would cost the utility even more because it may take additional spill at Grant PUD dams to meet proposed standards that call for 95 percent survival past the concrete and 91 percent survival through reservoirs. He said the cost to Grant will be much more than other mid-Columbias because Douglas PUD can already meet the new fish survival standards and Chelan PUD believes it can meet them without spending much more.

Routing fish around turbines is a big problem at Grant PUD dams. PUD director of natural resources Don Zeigler said a prototype surface collector at Wanapum Dam has not worked very well because most of the fish are choosing different passage routes that lead them through other turbines. He said the number of fish using the collector properly was "in the single digits." With the 95 percent survival goal in mind, Zeigler said the PUD must focus on more spill to achieve it, which means the utility will have less surplus power available for the spot market. Last year, Grant gave up $10 million in foregone power revenues for water spilled to aid fish migration.

Zeigler said Grant is in a tough spot. Since it owns the two lowest dams in the mid-Columbia, they impact more fish than dams higher in the system, and have a greater obligation to support hatchery programs and habitat restoration in the region. The proposal called for Grant to spend $13 million during the first year and $1 million each year after that for habitat improvements. For hatcheries, Grant is slated to pay $20 million up front and $2 million a year after that.

The PUD is planning rate increases of 9.5 percent annually over the next two years. Its 10-year forecast includes $139.5 million in salmon-related costs, along with $123 million to replace turbines at its two dams with more "fish-friendly" ones.

Meanwhile, Chelan PUD officials were optimistic about the HCP, said Steve Hays, who noted the hard work it took among the participants to integrate habitat improvement strategies with hatchery production. Chelan spent $6.8 million in 1996 on bypass systems at its two Columbia River dams and expects to spend nearly $12 million next year on salmon programs.

NMFS consultant Bob Turner, who has worked with all the parties to help put the deal together, said the package isn't quite ready, but there is a push for signing off on it by early December. He was short on specifics, but he did say that fish supplementation was going to play a part, noting that some of NMFS' own geneticists have reassessed the value of using hatcheries to improve numbers of wild fish. Turner said once the plan is signed, it will go through the NEPA process for the better part of next year. -Bill Rudolph



[5] COUNCIL RE-OPENS F&W AMENDMENT PROCESS

Citing the development of new scientific information, the Power Planning Council has re-opened its 1994 fish and wildlife program for amendment. Council chair John Etchart said other factors led to the decision as well, including ESA developments, BPA funding prioritization, and changes in the energy industry that affect Bonneville. The decision was made at last week's work session in Spokane.

"We want this amendment process to start with an ecosystem focus," said Etchart. "We think an integrated description of how the scientists think this ecosystem works will help interested people in the region see how their individual recommendations may fit together."

Recommendations may be submitted by July 31, 1998, while the Council continues to draft a scientific foundation for the F&W program, which is scheduled to be distributed to the public next March. By November 1998, the Council expects to have completed a draft program, with the amendment process to begin in February 1999 and a final decision made by that summer. -B.R.



[6] LOWER COLUMBIA HATCHERY FUNDING RESTORED

Three lower Columbia River hatcheries will remain open now that Congressional negotiators have agreed to restore $1.1 million in operating funds. Washington's delegation, led by Republican Sen. Slade Gorton, intervened to keep the hatcheries open.

In September, it was announced that federal funding cuts would close Grays River, Elochoman and Fallert Creek hatcheries, all funded by the Mitchell Act.

WDFW director Bern Shanks said fishers off the Washington coast, at the mouth of the Columbia and along its tributaries will all benefit from the hatcheries. "We are thankful that Congress provided funding that will allow us to move forward not only for continued future fisheries but also to rebuild natural spawning fish populations in southwest Washington." -B.R.



[7] GOVS MEET WITH CANADIANS OVER SALMON

The governors of Alaska, Washington and Oregon met with Canadian fisheries minister David Anderson recently and recommitted themselves to the stakeholder process to settle disagreements over the Pacific Salmon Treaty. But after the four-hour Nov. 14 meeting, participants didn't offer details of how the process would improve on last year's failed stakeholder talks. Special envoys representing the two countries, David Strangway and William Ruckelshaus, are expected to finish an interim report on status of the treaty talks soon.

Meanwhile, US salmon negotiator James Pipkin told Canadians they were harming their own national interest by refusing to recognize a different point of view. The "equity principle" in the salmon treaty is cited by Canada as the basis for its position.

But Pipkin's view received support from University of Victoria law professor Ted McDorman, who told the Vancouver Sun that US fishermen harvesting Canadian fish in their own waters was not a breach "of the letter of either international fisheries law or the 1985 Pacific Salmon Treaty." McDorman said the treaty never really says fish that come from Canada are Canadian fish. -B.R.



[8] CONSULTANT SAYS BARGING HAS HELPED IDAHO RUNS

Both Idaho and Washington state officials have taken issue with well-known fisheries consultant Don Chapman, who sent a recent letter to regional policymakers, scientists and politicians calling for more salmon barging past dams. Boise-based Chapman took issue with the notion that barging should be scrapped because of continued run declines. Rather, he said, "... the runs would be in even worse state in the Snake River in absence of transportation."

Chapman said the data on transport versus inriver migration "speak loudly and clearly in themselves," and "to deliberately send smolts through a system to make a political point in support of dam breaching is, at worst, irresponsible, hypocritical, and criminal, for it clearly constitutes a 'taking' under the ESA, whether the Biological Opinion permits it or not."

No Support From IDFG

But Idaho Fish and Game director Stephen Mealey said in a written response that his state could find no basis for supporting smolt transportation as a long-term recovery tool.

"We recognize that some scientists from the National Marine Fisheries Service (NMFS) believe the smolt transportation program has fully mitigated for hydrosystem impacts, and that poor ocean condition is the primary reason we are not currently flush with wild fish.
Spring chinook jawtagged at Lower Granite
to check homing ability
As you probably know, that perspective has been relegated to the fringe of scientific thought by the PATH scientists."

But others involved in the PATH process say Mealey's conclusions do not reflect the preliminary conclusions that PATH scientists made public last December.

Mealey said Idaho officials are aware of the ocean's role in regulating abundance, "but ocean productivity cycles are not the primary cause of the decline and continued suppression of wild Snake river salmon and steelhead stocks."

Mealey pointed to uncertainty in the transportation studies that related to questions of how much the control fish reflected true "run-of-the river" smolts "that are allowed to migrate without being bypassed, collected, and marked at the dam."

But an August memo from NMFS that reported on preliminary results of the latest transportation study said that return rates were lower for fish never detected passing through a smolt bypass system than for those detected passing through one or more of them. The NMFS memo also rebutted Idaho's concern about the "potential stress" of marking fish at the dam. NMFS researchers found "virtually no difference" between PIT-tagged fish marked at hatcheries and those collected and marked at Lower Granite Dam.

Idaho also expressed concern that data for transport studies is "very weak" for years with higher flows. Chapman had pointed out in his own letter that the 1995 migration year, upon which this year's adult returns are based, was an above average flow year. More than 700 marked fish returned, with transported chinook returning at twice the rate of inriver migrants.

The Idaho letter says its starting premise is exactly opposite to Chapman's. They feel "fish should be allowed to migrate in-river unless there is proof they are better off collected and barged. That proof is not conclusive; hence our support for an interim 'spread-the-risk' policy based on annual river conditions."

Mealey said Idaho supported "erring on the side of in-river migration" under relatively good flow and spill conditions, and "err on the side of transportation" under poor flow and spill conditions. "We believe maximizing transportation at the expense of smolts left in the river is poor management and runs counter to the normative approach."

Mealey said Chapman's implication that Idaho's interim policy was a political move that supported dam breaching is a "misconception," though he did say that Idaho is "confident" that breaching is the long-term option most likely to restore their runs.

Washington state's response to Chapman's pro-barging plea is more measured. In a letter from James Hoff, WDFW staff director of Intergovernmental Fisheries, the state said the region should wait to see what next year's returns bring, since the outmigration in 1996 occurred when flows were above average. "With this information, we believe the region will be in a better position to assess the role of transportation in the recovery process."

Over 119,000 fish were tagged for transport studies in 1996, and jacks returning this year are so few in number that federal fish counters are not speculating much. About all they say is that it looks like next year's fish may come back at only one-third the 1995 rate. So far, other research is showing that inriver survivals didn't seem to go up with greater flow. A BPA draft report of PIT-tag survival studies has found that juvenile survival in the Snake was less in 1996 than 1995. -B.R.



[9] WASHINGTON TROUT FINDS LOST SALMON HABITAT

Sometimes habitat is lost after it has become too degraded to support native fish. In other cases, it may have simply disappeared by falling through cracks in the counting system used to keep track of it. This has been true in Washington state, where hundreds of miles of spawning and rearing grounds for salmon and trout has been improperly classified as fishless habitat.

In the early 1970s, the Department of Natural Resources (DNR) began classifying each of the state's streams in one of five categories. Categories 1,2, and 3 meant that streams could support fish. Category 4 and 5 streams were non-fish bearing and generally constituted headwaters areas. In addition, each category had to display minimum physical characteristics such as bankful width, reach gradient, and minimum flows. A stream with physical characteristics that placed it a type 4 would be upgraded to a type 3 stream if it contained fish at any life cycle stage.

This method of classifying streams determines the extent of legal protection from activities such as logging and farming. For example, riparian buffer zones are required along type 3 streams during logging operations. They may be required for type 4 streams or left to voluntary protection, but such zones are not required on type 5 streams. Therefore, accurate stream typing is essential to provide even minimal protection for fish habitat.

The DNR began statewide stream typing with both limited funds and a short time frame. Personnel made do with topographic maps and aerial photos to estimate the physical features of streams for typing. Some basic assumptions were made to expedite the process--including the notion that fish would not be found in streams with a gradient of 12% or greater, or above falls of 10 feet or more. It was also assumed, unless otherwise documented, trout would not be found in streams less than 10 feet wide and no anadromous fish would inhabit a stream less than five feet wide

The DNR consulted with the Washington Department of Fish and Wildlife (WDFW) regarding reaches of fish-bearing streams, but the fish agency often not have data about fish distribution in small headwater streams. They did have more information on salmon and steelhead stocks than for resident trout.

Unfortunately, the agency did little ground truthing to verify their assumptions. As a result, many errors were made in stream typing. because they did not meet DNR's standards for fish bearing water and agency assumptions about fish distribution. By simply failing to detect and accurately map them, many fish bearing streams were not even identified.

By the mid-1980s biologists began to question the accuracy of DNR's water typing process and began to ground truth many streams around the Olympic Peninsula. Studies by tribal biologists showed that DNR fish distribution maps had underestimated fish bearing stream miles by almost 50 percent.

Washington Trout, a statewide conservation group, investigated the Tolt River, east of Seattle, and found many miles of fish-bearing streams that had not been identified by DNR. Fearing that these stream typing errors were a major contributing factor in native salmonid decline across the state, the group obtained a grant from the U.S. Fish and Wildlife Service to conduct stream type verification projects in western Washington.

With a team of six displaced forest workers, they investigated the stream typing accuracy of the Mashel drainage, a tributary of the Nisqually River; Tokul and Griffin creeks in the Snoqualmie watershed; Deer Creek, a tributary of the Stillaquamish River, and Hutchinson Creek in the Nooksack drainage.

So far, Washington Trout's trained stream surveyors have identified 150 miles of streams that were incorrectly typed or not represented on DNR's Forest Practice Applications base maps. Almost 60 percent of these streams were found to be fish-bearing type 3 streams. Most contained resident trout, but many also had coho. Many of these streams were less than three feet wide.

In the Snoqualmie drainage, over 40 percent of the new fish-bearing streams found by Washington Trout were not on DNR maps. Due to inaccurate mapping and classification, over 20 miles worth of streams were not being given mandated legal protection.

In the Mashel drainage there is now 50 percent more type 3 water (20 miles) than was present prior to Washington Trout's study. On Deer Creek, Washington Trout crews found 21 miles of incorrectly typed streams. Most of these streams were revised to type 4 streams, and 87% of these stream miles were not on DNR maps.

In addition, Washington Trout and tribal biologists found the criteria used by DNR to classify stream type as fish-bearing was inadequate because both resident and anadromous salmonids were found in two to three-foot-wide streams. Fish were seen in stream gradients up to 16 percent and in steeper habitat where gradients were as high as 31 percent if a pool step cascade habitat was present.

As a result of this ground truthing by the tribes and Washington Trout, state agencies are now becoming aware that small streams, even those that go dry during the summer or have very steep gradients, are fish-bearing, and can constitute critical spawning and rearing habitat for cutthroat and coho salmon.

Washington Trout is recommending that state officials ground truth their stream typing method so trout, steelhead and salmon can be given the kind of protection the citizens of Washington have long supported. -Bill Bakke

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