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Wild Salmon Recovery Initiative (WSRI) Projects

The Wild Salmon Recovery Initiative is intended to influence federal, state, and local agencies to fully implement and comply with the Endangered Species Act, the Clean Water Act, and other local, state, and federal statutes.

Wild Fish Conservancy’s staff of professional advocates analyze and draft reviews of policy proposals, watch-dog public agencies, participate on recovery forums and technical-review teams, work directly with resource-management officials, establish and participate in coalitions with other regional and national conservation advocates, develop information/action campaigns, and where necessary, litigate to implement and defend the laws intended to protect our wild fish heritage.

Past and Ongoing WSRI Projects

Project summaries, reports, and other materials dated before February 2007 may reflect that from 1989 until February 2007, Wild Fish Conservancy operated under the name Washington Trout.

 

Atlantic Salmon Aquaculture

White River Supplementation Program

Washington Statewide Steelhead Management Plan

Upper Columbia River Spring Chinook, Steelhead, and Bull Trout Recovery Plan

Puget Sound Salmon Harvest Suit

Puget Sound Partnership

Puget Sound Steelhead Listing

Puget Sound Chinook Recovery Plan

NOAA Hatchery-Listing Policy

WDFW Hatchery Management Plans

Atlantic Salmon Aquaculture

(2007- ) In the public waters of Puget Sound, salmon have been raised commercially in open “net-pens” since the 1970s.  While early attempts raised coho salmon, commercial growers have achieved their greatest success raising exotic Atlantic salmon (Salmo salar).   Today in Washington, there are eight privately-owned facilities currently permitted by the Department of Ecology.  In comparison, there are over 85 open salmon net-pen farms in coastal British Columbia.  Conservation organizations there have documented numerous problems stemming from open salmon net-pens. In 2007, Wild Fish Conservancy commented to the Washington Department of Ecology on the renewal of state permits for for the eight aquaculture open net-pens in Puget Sound.

Comments to Washington Department of Ecology on eight draft renewal NPDES permits, American Gold Seafoods Marine Net Pens, June 15, 2007.

Reform of aquaculture practices in British Columbia is a priority of a number of conservation organizations.  Wild Fish Conservancy is engaged with some of these groups to share information, data, and ideas.

White River Supplementation Program

(2006 - ) In January 2007, Wild Fish Conservancy submitted comments to NOAA Fisheries regarding an ESA Section 10 direct-take permit application and an associated Environmental Assessment for a spring chinook hatchery-supplementation program for the White River, a tributary of Lake Wenatchee in east-central Washington. In August 2007 we submitted to the Priest Rapids Coordinating Committee (PRCC) Hatchery Subcommittee a review of a preliminary draft of the management plan for the supplementation program.

We focused both reviews on our belief that that the proposed program is ill considered, dominated by an inappropriate level of risk and uncertainty, and inconsistent with long standing and authoritative recommendations to develop a credible, region-wide evaluation of hatchery supplementation. We recommended the program be fundamentally reconsidered.
White River Summary; Section-10 Permit Comments; White River Draft-HGMP Comments.

Washington Statewide Steelhead Management Plan

(2006 - ) In 2006, the Washington Department of Fish and Wildlife began developing a revised statewide steelhead-management plan. To create a scientific foundation for revised steelhead management, WDFW first developed an "Assessment" of Washington's steelhead populations and current management programs.

Wild Fish Conservancy participated on WDFW's Steelhead Plan Advisory Group and submitted substantive reviews of the Assessment and a Draft Statewide Steelhead Management Plan. We expressed concern that both the Assessment and Management Plan lack sufficient detail, specific performance thresholds, timetables, and management triggers, that WDFW ’s estimate of historical steelhead abundance is too low, that WDFW needs to more adequately define proposed wild-only steelhead management zones, and that WDFW needs to drastically alter, reduce, or eliminate current steelhead hatchery programs and conduct scientifically credible tests of its proposed hatchery-reform measures.
Steelhead Management Plan Summary
Steelhead Management Plan Update 1Steelhead  Management  Plan  Update  2 Steelhead Management  Plan Comments; Steelhead Assessment Summary Steelhead Assessment Update; Steelhead Assessment Comments.

Upper Columbia River Spring Chinook, Steelhead, and Bull Trout Recovery Plan

In November 2006 Wild Fish Conservancy submitted comments to NOAA Fisheries regarding a public-review draft of the Proposed Upper Columbia Spring Chinook Salmon, Steelhead, and Bull Trout Recovery Plan. We found the proposed recovery plan lacked quantitative standards associated with specific recovery objectives for each of the listed species. We believe it is uncertain whether the proposed recovery plan can secure the recovery and de-listing of any of the listed species, and we recommended that NOAA fisheries resubmit the proposed recovery plan to its authors for revision.
UCR Recovery Plan Comments.

Puget Sound Salmon Harvest Suit

(2006 - ) In October 2006, Wild Fish Conservancy filed a complaint in Federal District Court against NOAA Fisheries Service and the U.S. Fish and Wildlife Service to stop current fishing management from illegally jeopardizing the recovery of Puget Sound chinook salmon, listed as threatened under the Endangered Species Act since 1999.

The Puget Sound Comprehensive Chinook Management Plan is intended to guide salmon harvest activities that impact PS chinook until 2010. NOAA Fisheries violated the ESA when it improperly granted ESA-approval of the management plan in 2005. We are asking the court to order NOAA to withdraw its approval of the harvest-management plan and develop more appropriate salmon-harvest regulations.
Harvest Suit Summary 1; Harvest Suit Summary 2; Harvest Suit Press Release; Harvest Complaint; Harvest Opening Brief; Harvest Management Plan Comments.

Puget Sound Partnership

(2006 - ) In late 2005, Washington Governor Christine Gregoire convened the Puget Sound Partnership “Puget Sound Partnership” to develop a plan to restore and protect Puget Sound by 2020. In 2006, Wild Fish Conservancy participated in a “caucus” organized to help develop a conservation agenda -- as well as strategies to achieve that agenda -- to present to the Partnership.  The caucus was led by People for Puget Sound, the “environmental representative” on the Partnership, and included other regional and national conservation organizations.  Wild Fish Conservancy advocated within the caucus and directly to the Partnership for greater use of Marine Protected Areas in the Sound, as well as stronger controls on stormwater and other measures to better protect rivers and other freshwater habitats associated with Puget Sound. As the Partnership was established as a new state agency in 2007, we are continuing our participation in the caucus.

Puget Sound Partnership Summary; Comments from Washington Trout to Puget Sound Partnership on draft plan, October 26, 2006; Comments from Puget Sound Environmental Caucus to Puget Sound Partnership on draft recommendations, October 26, 2006.

Puget Sound Steelhead Listing

(2006 -) In March 2006, NOAA Fisheries proposed listing Puget Sound steelhead as a threatened species under the Endangered Species Act; in May 2007, NOAA finalized the listing. Wild Fish Conservancy submitted comments supporting the proposed listing, and submitted a review of a proposed 4d Rule for regulations to protect threatened PS steelhead.

The loss of steelhead habitat and the adverse impacts from hatchery programs are limiting the viability of PS steelhead, and without a listing to protect them, they are likely to face extinction. However, Wild Fish Conservancy does not support the decision to include several hatchery-steelhead populations in the listing, and we are concerned that NOAA’s decision not to list PS resident rainbow trout populations will fail to adequately conserve resident populations that could be essential for the recovery of PS steelhead.
PS Steelhead Listing Summary
; PS Steelhead Listing Comments; PS Steelhead 4d Comments; PS Steelhead Press Statement.

Puget Sound Chinook Recovery Plan

(2005 - ) In 2006, NOAA Fisheries released a Recovery Plan for Puget Sound chinook, listed as threatened under the Endangered Species Act. The recovery plan, known as the Shared Strategy, was developed by a coalition of local, tribal, state, and federal jurisdictions working cooperatively since 2002.

Wild Fish Conservancy submitted a review of the recovery plan, expressing concern that the section on habitat protection lacked measurable criteria, timetables, and performance standards, and the sections on harvest, hatcheries, and “all-H integration” failed to acknowledge or reconcile uncertainties involved in harvest and hatchery management.
PS Chinook Recovery Plan Comments.

NOAA Hatchery-Listing Policy

(2003 - ) In May 2004, NOAA Fisheries proposed a new policy for considering hatchery salmon and steelhead in ESA-listing decisions. In 2005, NOAA adopted a Hatchery Listing Policy to count hatchery fish in determining the health of wild populations, something most scientists agree will impede wild-fish recovery.

Working with a broad coalition of conservation advocates, Wild Fish Conservancy contributed to the development of a coordinated response to the  policy,  participating in public hearings and media outreach, submitting a review of the proposal, and contributing technical advice to litigation challenging the policy.
Hatchery-Listing Policy Summary; Hatchery-Listing Policy Update 1; Hatchery-Listing Policy Update 2; Hatchery-Listing Policy Comments.

WDFW Hatchery Management Plans

(2002 - ) In 2002 and 2003, Wild Fish Conservancy filed lawsuits against the Washington Department of Fish & Wildlife, alleging that WDFW hatchery programs were jeopardizing the recovery of listed salmon and steelhead populations and violating the Endangered Species Act. In 2003, we negotiated a settlement agreement with WDFW that set a schedule for the submission of ESA-required Hatchery Genetic Management Plans, and expanded the public review of all the HGMPs. Under the agreement WDFW’s hatchery management plans were published for public review in 2003, 2004, and 2005. Wild Fish Conservancy has submitted substantive reviews of the HGMPS to help ensure that each is as biologically and legally credible as possible and to influence needed improvements in current hatchery practices.
Hatchery Management Plans Summary; Hatchery Management Plans Update 1; Hatchery Management Plans Update 2; Hatchery Management Plans Update 3; Puget Sound HGMP Comments; Columbia River HGMP Comments 1; CR HGMP Comments 2; CR HGMP Comments 3.

Further Reading on Hatchery Impacts and Implications:

An Overwhelming Body Of Evidence

Fitness Of Hatchery-reared Salmonids In The wild

Wild vs. Hatchery Salmonid  Interactions


Risks To Wild Populations From Hatchery Fish

The Salmon Hatchery Myth: When Bad Policy Happens To Good Science

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