Four conservation groups have filed a 60-day notice letter to three federal agencies as well as officials of the Lower Elwha Klallam Tribe’s salmon hatchery alleging violations of the Endangered Species Act. Wild Fish Conservancy, The Conservation Angler, the Federation of Fly Fishers Steelhead Committee, and the Wild Steelhead Coalition issued the letter to the Tribe’s hatchery manager and natural resources director (in their official capacities) for their activities implementing hatchery programs, and the National Marine Fisheries Service, the National Park Service, and the US Fish and Wildlife Service for approving and funding those hatchery programs. Although the hatchery programs in question had received ESA approval, the approval relied on a functioning Elwha River mainstem “weir” as an essential component. The weir would have provided critical functions for monitoring, evaluation, and adaptive management of the programs’ effects on ESA-listed Chinook salmon, steelhead, and bull trout. Unfortunately, the Elwha River mainstem weir is not currently functioning, and therefore the hatchery programs cannot comply with the requisite conditions of the ESA approval.
“The approval of these programs was contingent on monitoring and adaptive management, and the weir was deemed absolutely essential for those to occur,” said Kurt Beardslee, executive director of Wild Fish Conservancy. “Without adaptive management, the Elwha River gets flooded with 7.5 million maladapted hatchery fish per year with no way to determine the effects on threatened salmon, steelhead, and bull trout. It’s a recipe for disaster.”
The federal government is spending nearly $325 million for the removal of the Elwha and Glines Canyon dams, which will open nearly seventy miles of pristine riverine habitat in Olympic National Park, much of which is designated a wilderness area. Instead of natural colonization by wild salmonids, however, the agencies and the Tribal officials are going ahead with a plan that will eventually allow the release of more than seven million juvenile hatchery salmonids annually. Expenditures for hatchery facilities and operations have contributed to inadequate funding for the research and monitoring activities that are necessary to evaluate whether restoration is succeeding and whether hatchery activities are harming restoration and resulting in take of listed fish.
The four conservation groups agree with a recent review by the Hatchery Scientific Review Group (HSRG) that restoration of the lower Elwha River and re-colonization of the pristine upper Elwha River should prioritize recovery of wild fish. The proposed reliance on large-scale hatchery releases undermines ecosystem recovery and violates the ESA, and threatens recovery of bull trout and Puget Sound Chinook salmon and steelhead, all listed as threatened species under the ESA. While the groups support the right of the Lower Elwha Klallam Tribe to harvest salmon and steelhead, spending $325 million to open a wilderness watershed but then stocking it with hatchery fish is poor public policy and will likely lead to skepticism over future salmon recovery efforts, especially dam removal projects.
This is latest effort by the four groups to ensure that the hatchery programs comply with the ESA; a federal lawsuit over the hatcheries was first filed in February 2012.
The groups are represented by Smith and Lowney, PLLC, of Seattle.