HON. THOMAS S. ZILLY

 

 

 

 

 

 

 

 

 

 

 

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

 

THREATENED PUGET SOUND CHINOOK; WASHINGTON TROUT; and NATIVE FISH SOCIETY,   Plaintiffs,   v.   JEFFREY P. KOENINGS; WASHINGTON DEPARTMENT OF FISH AND WILDLIFE; WASHINGTON FISH AND WILDLIFE COMMISSION; RUSS CAHILL; Will Roehl, Ron Ozment, Lisa Pelly, Dawn Reynolds, Fred Shiosaki, Bob Tuck, R.P. Van Gytenbeek, and Kelly White,   Defendants, ___________________________________

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No. CV03-0687Z   DECLARATION OF SAM WRIGHT SUPPORTING PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION

 

            I, Sam Wright, declare the following based on personal knowledge and my professional expertise, to which I am competent to testify:

            1.         I am a Certified Fisheries Professional (American Fisheries Society) with 42 years of professional-level experience in managing fish populations and fish habitat.  This experience encompasses approximately 32 years with Washington State fish management agencies, including a four-year period in the mid-1980s when I was responsible for game fish artificial production (hatchery) programs of the Washington Department of Game.  My previous experience also includes responsibility for development of a Wild Salmonid Policy for defendant Washington Department of Fish and Wildlife (WDFW) in 1997-1998.  From these experiences, I am familiar with aspects of the current WDFW coho salmon and steelhead trout hatchery programs at issue in this case.  Since 1998, I have been a self-employed consultant on fish resource management issues.  A true and correct copy of my curriculum vitae is attached as Exhibit A to this declaration.

            2.         This declaration explains my opinions concerning the probability that juvenile coho and steelhead released by WDFW as part of the hatchery programs subject to this lawsuit will imminently and actually harm juvenile threatened Puget Sound chinook by preying upon them; and how stopping these hatchery releases is necessary to prevent this imminent harm.  This declaration supports the plaintiffs’ request for preliminary injunctive relief.  In this declaration, following an initial explanation section, I examine scientific evidence demonstrating that yearling coho and steelhead prey on threatened Puget Sound chinook salmon juveniles and state my opinions.

            3.         In developing this declaration, I reviewed (1) the 2002 Future Brood Document for information on intended releases in 2003 of yearling hatchery coho salmon and steelhead trout by WDFW; (2) the Resource Management Plan (RMP) for Puget Sound Chinook Salmon Hatcheries, a component of the Comprehensive Chinook Salmon Management Plan developed by WDFW and the Puget Sound Treaty Indian Tribes; and (3) the 29 individual Hatchery and Genetic Management Plans (HGMPs) for chinook as provided to plaintiffs.  I also reviewed the draft Hatchery and Genetic Management Plans for WDFW yearling coho and yearling steelhead hatchery programs that were provided to plaintiffs in March of this year.  Primary additional technical references were

the final EIS for the Wild Salmonid Policy (WDFW.  1997.  Final environmental impact statement for the Wild Salmonid Policy.  WDFW, Olympia, WA.);

 

the NOAA Fisheries status review of chinook salmon (Myers et al. 1998.  Status review of chinook salmon from Washington, Idaho, Oregon, and California.  U.S. Dept. Commer., NOAA Tech. Memo.  NMFS-NWFSC-35, 443 p.);

 

a recent paper by a WDFW scientist on interspecies interactions (Pearsons, T. N.  2002.  Chronology of ecological interactions associated with the life-span of salmon supplementation programs.  Fisheries 27(12):10-15.);

 

a paper on sizes of chinook that can be consumed by juvenile coho (Pearsons, T. N., and A.L. Fritts.  1999.  Maximum size of chinook salmon consumed by juvenile coho salmon.  North American Journal of Fisheries Management 19:165-170.);

 

documentation of predation on wild chinook (Hawkins, S. W., and J. M. Tipping.  1999.  Predation by juvenile hatchery salmonids on wild fall chinook salmon fry in the Lewis River, Washington.  California Fish and Game 85(3):124-129.);

 

a report on the problem of residual hatchery steelhead (Viola, A.E., and M.L. Schuck.  1995.  A method to reduce the abundance of residual hatchery steelhead in rivers.  North American Journal of Fisheries Management 15:488-493.);

 

an estimate of predation in one area totaling 7.5 million wild chinook (Sholes, W.H., and R.J. Hallock.  1979.  An evaluation of rearing fall-run chinook, Oncorhynchus tshawytscha, to yearlings at Feather River Hatchery with a comparison of returns from hatchery and downstream releases.  California Fish and Game 65(4):239-255.);

 

and proceedings from a January 2003 Workshop on Lake Washington chinook (sponsored by the city of Seattle).

 

4.         All three species at issue (chinook, coho, and steelhead) are anadromous in that adults migrate from marine waters into freshwater streams where they spawn, juveniles rear in freshwater habitats for varying periods, and then juveniles migrate back to marine waters where most growth and maturation takes place.  For anadromous species, the net “benefits” of more protected adult spawning and juvenile rearing in freshwater (in conjunction with better marine area food resources) more than offset the “costs” of migration and making the transitions between fresh and marine waters.

            5.         Chinook salmon are the most complicated of the five Pacific salmon species because they have many different life history strategies.  Adults spawn in gravel nests called “redds” from August through November and surviving juveniles emerge from these nests during the following spring.  The time span of emergence, when chinook average about 30 mm (approximately 1.18 inches), is even more protracted than the time of spawning because egg development is a function of both time and water temperature.  There is substantial variation in survival rates in both the freshwater and saltwater life stages, and the time that fish spend at each life stage varies between fish.  The chinook with the most common life history strategy in Puget Sound, called “ocean-type”, have smolts that migrate to marine waters during their first year of life.  Some juveniles or “fry” migrate to the estuary shortly after emergence from the gravel but most rear in freshwater habitats for several months until they reach an average length of about 60 mm (approximately 2.36 inches) and are called “fingerlings”.  These fingerlings then move to rearing habitats in estuaries and near shore marine waters.  The transition from freshwater to saltwater is called “smolting”.

6.         Survivors from each ocean-type chinook spawning population or “brood year” will return as 2-year-old “jacks” (all males) and 3-, 4-, and 5-year-old adults.  This means that the adult return in any given year will come from the survivors of three different brood years.  A less common chinook group (in most systems) is the “stream-type” chinook which have smolts that do not migrate to marine waters until the spring of their second year – remaining in freshwater for a year or more until such time.  The mature returns come as 3-year-old jacks and 4-, and 5-year-old adults.  Most of the ocean-type smolts move to ocean rearing areas north of Puget Sound in their first year, although significant numbers rear in inside waters for one year before moving to the ocean or remain in inside waters throughout their marine rearing period.  The less numerous stream-type fish tend to do just the opposite.  Most rear in inside waters for at least one year and many spend their entire marine rearing period in these inside waters.  Thus, the fish called “resident chinook” come from a minority of the larger population of ocean-type fish and a majority of the smaller population of stream-type fish.  The tendency to remain in inside waters comes mainly from the type of smolts (yearlings), not from the origin of parents.  Mature adults leave saltwater and return to their natal streams anywhere from early spring to mid-fall.

            7.         Spawning coho salmon (wild and hatchery) are virtually all 3-year-old adults in the southern part of their range, with nearly all having migrated to marine waters in the spring of their second year (after a year of freshwater rearing).  Once in marine waters, there are three different life history strategies for coho smolts.  After they reach marine waters, most move immediately to the ocean and do all of their marine rearing in ocean waters to both the south and north of the Strait of Juan de Fuca entrance.  A smaller but significant group rears in inside marine waters for one year and then moves to the ocean at the beginning of their third year.  Their ocean rearing time is limited to a single summer.  A third group, also significant in proportion, spends their entire marine rearing period in inside waters and is referred to as “resident coho”.  Each of the three groups is progressively smaller in average size as mature adults due to the much better average foraging conditions that prevail in the ocean.

            8.         Steelhead trout are less abundant than any of the five species of Pacific salmon (both in the past and currently) but have a complex series of life history strategies, including repeat spawning by the same fish (unlike Pacific salmon that all die following their initial spawning).  Steelhead populations are commonly divided into summer-run and winter-run races based upon the time of year when adult returns enter freshwater.  Puget Sound has both types of adult populations but the winter-run are much more abundant.  Wild juvenile steelhead in Puget Sound migrate to marine waters in the spring of their second to fourth years after rearing in freshwater for one to three years, respectively.  The released hatchery fish are mainly yearlings from summer-runs and early returning winter-run adults.  By using these early steelhead, large hatchery smolts can be produced during a single year of greatly accelerated hatchery rearing (as compared to natural rearing).  Ocean feeding is mainly to the north and there are not significant numbers of resident fish in inside marine waters.

            9.         By examining the 2002 Future Brood report and the Puget Sound chinook RMP and HGMPs, I determined that there would be significant predation on threatened chinook juveniles by WDFW hatchery coho and/or steelhead releases in virtually every river system in Puget Sound.  This predation would occur mainly as a result of the significant differences in sizes between threatened chinook in their first year of life versus the much larger artificially produced yearlings of both species.  Yearling hatchery coho salmon released by WDFW would be consuming threatened chinook fry and fingerlings in the Lake Washington system and in the following river systems:  Nooksack, Baker, Skagit, Skykomish, Wallace, Snohomish, Skokomish, Green, Puyallup, and Dungeness.  Yearling hatchery steelhead trout released by WDFW would be consuming threatened chinook fry and fingerlings in the follow river systems:  Nooksack, Skagit, Stillaguamish, Snohomish, Snoqualmie, Wallace, Skykomish, Hamma Hamma, Dosewallips, Duckabush, Skokomish, Green, White, Puyallup, Dungeness and Elwha.    

            10.       WDFW’s own proposed RMP for hatchery chinook in Puget Sound states as follows on page 106:  “Hatchery-origin fish may prey upon juvenile wild chinook at several stages of their life history.  Newly released hatchery chinook smolts have the potential to prey on wild fry and fingerlings that are encountered in freshwater during downstream migration, or if the hatchery fish residualize prior to migrating.  Hatchery-origin smolts, sub-adults, and adults may also prey on wild chinook of susceptible sizes and life stages (smolt through sub-adult) in estuarine and marine areas where they commingle.  Hatchery chinook planted as non-migrant fry or fingerlings, and progeny of naturally spawning hatchery fish also have the potential to prey upon wild-origin chinook in freshwater and marine areas where they occur.”  A true and correct copy is attached as Exhibit B.

            11.       All of the processes described above for hatchery chinook also apply to interspecies interactions with hatchery coho salmon and steelhead trout.  Todd N. Pearsons, the leader of defendant Washington Department of Fish and Wildlife’s Hatchery/Wild Interactions Unit and Ecological Interactions Team, has written as much in peer-reviewed scientific literature.  Pearsons (2002:10) states that:  “Hatchery produced fish may compete with, prey upon, increase disease to, alter predator consumption of, and alter behavior of wild conspecifics and NTT.” “NTT” stands for “non target taxa”, such as threatened chinook are when considering coho and steelhead hatchery programs.  “Target fish” or “conspecifics” refers to the species of the hatchery fish.  Pearsons also explains: “Greater numbers of hatchery target smolts increases interaction potentials between hatchery target fish and NTT in the freshwater migration corridor (e.g., if hatchery target fish residualize), estuary, and ocean.  …  [These] interactions are non-natural because humans artifically rear and release the target fish.  Hatchery fish are typically more numerous, more concentrated, larger, and in some instances more aggressive than wild fish ….  These differences can confer dominance status to hatchery fish …, decrease the size refuge of NTT to predation by target hatchery fish …, and change the functional and numerical response of predators to mixed groups of target hatchery and NTT ….”  This scientific paper is attached as Exhibit C.

            13.       Coho salmon and steelhead trout yearlings are both opportunistic feeders and highly successful predators on smaller fish.  The relatively large size of hatchery fish - as compared to wild fish - further compounds the predation problem by increasing the maximum size of juvenile threatened chinook that may be taken as prey.  The potential for predation on chinook by hatchery coho is exacerbated by the average size of yearling coho salmon smolts (17 to 15 fish per pound in planned Puget Sound releases) being significantly larger than wild smolts from the same species (Pearsons and Fritts 1999).  The average lengths of the hatchery coho at release would range from 123 mm (approx. 4.8 in.) to 129 mm (approx. 5.1 in.).  The average size of most wild coho salmon smolts is between 90 and 130 mm (Sandercock 1991 cited in Pearsons and Fritts 1999).  The hatchery coho tested by Pearsons and Fritts (1999) ranged from 129 to 174 mm.  For steelhead trout yearlings (typically released at 7 to 4 fish per pound or average lengths of 166 mm (approx. 6.5 in.) to 200 mm (approx. 7.9 in.)), the potential for predation is even greater on a per fish basis and is further increased by their tendency to residualize in freshwater habitats (extending the period for predation).  “Residualize” and “residualization” of hatchery steelhead refers to the tendency of a proportion of these fish to remain in freshwater habitats instead of smolting and migrating to saltwater.  Residualized steelhead essentially become resident trout, either for some time until they smolt, or permanently, rearing and growing in freshwater.

            14.       The sizes of chinook that juvenile coho salmon can consume was studied by Pearsons and Fritts (1999).  In one experiment, coho consumed chinook that were up to 40-46% of their length.  In a second experiment, coho ate chinook that were up to 41-47% of their length.  In a third experiment, coho attacked imitation chinook lures ranging in size from 35 to 115 mm at rates that decreased with increasing lure size.  Even though coho may not consume fish greater than about 46% of their length, Pearsons and Fritts (1999) found that they did attempt to eat larger fish - often killing them in the process.  Chinook up to 51-58% of the coho’s length were killed when coho tried unsuccessfully to eat them.  The chinook that were eaten by hatchery coho smolts ranged in size from 40 to 74 mm while the chinook that were killed by hatchery coho smolts ranged in size from 56 to 76 mm.  A true and correct copy of Pearsons and Fritts (1999) is attached as Exhibit D.

15.       Hawkins and Tipping (1999) conducted field studies of salmonid predation and found that “All identified salmonid remains were juvenile wild chinook salmon.” (Hawkins and Tipping 1999:127).  The hatchery coho yearlings containing salmonid prey (wild chinook) ranged from 89 to 176 mm in 1997 and from 105 to 177 mm in 1998.  For hatchery steelhead, Pearsons and Fritts (1999) cited an unpublished study in Oregon where residual hatchery steelhead ate juvenile salmonids up to 44% of their body length in controlled predation trials.  In Washington’s Tucannon River, hatchery steelhead consumed salmonids up to 42% of their body length (Martin et al. 1993 cited in Pearsons and Fritts 1999).  During the studies by Hawkins and Tipping (1999), the average size at release of hatchery steelhead yearlings was near to the upper range in Puget Sound, with the steelhead averaging 195 mm in 1997 and 198 mm in 1998.  The steelhead containing salmonid prey (wild chinook) ranged from 183 to 193 mm in 1997 and from 175 to 259 mm in 1998.   The HGMPs for Puget Sound chinook clearly demonstrate that large numbers of juvenile wild chinook will be available as potential forage at the times and places when hatchery coho salmon and steelhead trout smolts are currently scheduled for release in many Puget Sound streams.  A true and correct copy of Hawkins and Tipping (1999) is attached as Exhibit E.

            16.       As noted above, the studies by Hawkins and Tipping (1999) documented predation on juvenile wild chinook by hatchery-origin coho salmon and steelhead trout smolts.  The losses of chinook were significant for both species.  The average number of chinook consumed per steelhead was higher than that observed for coho.  However, total losses to coho were higher since the numbers released were much higher than steelhead.  Comparable sized fish of all three species are available at comparable times in many Puget Sound streams.  Scientists are generally reluctant to estimate total impacts of predation since it depends upon making some rather tenuous assumptions concerning the relative sizes of the prey and predator fish populations plus the time which they are exposed to each other.  However, Sholes and Hallock (1979) reported that 532,000 chinook salmon hatchery yearlings consumed an estimated 7.5 million wild chinook fry and fingerlings in California’s Feather River.

            17.       While it is not my opinion that predation losses of threatened Puget Sound chinook (due to hatchery releases of coho and steelhead yearlings) would be the same as the rate estimated for California - over 14 juvenile wild chinook per hatchery yearling, even with a nominal assumption of just one chinook lost per hatchery yearling released, the losses of threatened chinook due to WDFW hatchery programs being challenged by plaintiffs would total about 5.7 million fish.  Even with a minimal assumption of only one threatened chinook being lost per each ten yearling hatchery fish released, the losses would still exceed one half million threatened Puget Sound chinook.

            18.       The planned 2003 releases of hatchery-reared coho salmon yearlings and steelhead trout yearlings would severely imperil the recovery of indigenous populations of threatened chinook salmon in the Puget Sound region.  This opinion is based on (1) the sheer magnitude of the pounds of coho and steelhead predators that would be dumped on top of threatened chinook fry and fingerling populations; (2) the sizes of the predator populations relative to the sizes of the indigenous chinook populations; (3) the fact that both the coho and steelhead hatchery yearlings are physically much larger than their counterparts of the same species in wild populations that the chinook evolved with; and (4) the common habit of hatchery steelhead to become residents in freshwater streams and thus greatly increase their time of exposure to threatened chinook fry and fingerlings.

            19.       Based on the facts cited above, it is my opinion that, if WDFW is allowed to proceed with coho and steelhead hatchery releases at issue as planned in 2003, there would be significant river basin specific impacts on threatened Puget Sound chinook salmon in many areas.  Most of the draft HGMPs for WDFW yearling coho and yearling steelhead hatchery programs in the Puget Sound region contain language stating that “Hatchery coho and steelhead are both released at a large enough size (coho 17-12 fpp, steelhead 8-5 fpp) that predation on smaller listed chinook … may be a problem.”  The draft HGMPs also consistently state under “Unintentional lethal take” that the numbers killed by  “Juvenile/Smolt” are “Unknown”.  Attached as Exhibit F are a couple of examples of these.

20.       The draft HGMPs for the coho and steelhead hatchery programs indicate that WDFW asserts that it will minimize or avoid predation by these hatchery fish on juvenile threatened chinook by timing hatchery steelhead and coho releases so that they do not coincide with the time that juvenile threatened chinook are out-migrating.  However, juvenile chinook are rearing and present in these freshwater habitats for a period of several months and their out-migration lasts for several months.  In addition, examination of the draft HGMPs and the future brood document reveals that in many cases hatchery coho and steelhead releases will overlap with both the rearing and out-migration times estimated by WDFW itself.  In short, WDFW’s assertion that predation will be minimized and avoided is contradicted by its own documents.

21.       My concerns specific to the particular river systems and the coho and steelhead hatchery releases at issue are described in the following paragraphs.

22.       Nooksack River basin:  There are at least two and probably three indigenous chinook populations in this system (North Fork, South Fork, mainstem), including one listed hatchery population (North Fork).  Chinook fry and fingerlings would be preyed upon by planned 2003 WDFW releases of 300,000 yearling hatchery coho and 150,000 yearling hatchery steelhead.  The current South Fork chinook population is severely depressed and would probably benefit most from the elimination of thousands of pounds of artificially produced predators.  The draft HGMP for the coho program states that the program has recently been reduced from a 2,000,000 fish release (including one million as fry plants) to the present 300,000 yearling release.  Suspiciously, no reason is given for this major reduction.  In addition, a side-by-side comparison of the coho and steelhead draft HGMPs shows a conflict.  For steelhead, it is claimed that an early May release will avoid a mid/late May out-migration of listed chinook.  The coho HGMP claims that a planned mid-May release will avoid out-migrations of chinook in April and June.  It appears that the latter claim refers to separate releases of threatened chinook from the Kendall Creek hatchery, which are protected because they have been deemed essential for recovery.

23.       Skagit River basin:  This is the largest producer of threatened chinook salmon in the entire Puget Sound region and there are at least six indigenous populations that require protection.  In spite of this, WDFW plans (in 2003) to release 275,000 yearling hatchery coho into the system (including 25,000 in the Baker River) that will prey upon threatened chinook fry and fingerlings.  They also plan a huge release of from 480,000 to 600,000 yearling hatchery steelhead into the Skagit River system which will also prey upon threatened chinook fry and fingerlings.  The draft HGMPs for both coho and steelhead claim that the out-migration of listed chinook is in early May and that late May/June coho releases or May steelhead releases will avoid any problems.  However, WDFW data on juvenile wild chinook trapping that was provided to plaintiffs show that large numbers of threatened fish would still be present at the time of planned hatchery fish releases.

24.       Stillaguamish River basin:  There are two indigenous threatened chinook populations (North Fork, South Fork) in this system, including one listed hatchery population (North Fork).  WDFW plans to release 220,000 yearling hatchery steelhead into this system in 2003, including 70,000 summer-run fish.  If the releases are allowed, these steelhead will be consuming significant numbers of threatened chinook fry and fingerlings.  Both of the indigenous chinook populations are severely depressed at the present time and would benefit from the elimination of artificially-produced yearling steelhead predators in this river system.

25.       Snohomish River basin:  There are at least two indigenous threatened chinook populations in this system (Skykomish, Snoqualmie) and WDFW plans to release 204,000 yearling hatchery coho in 2003 (including 54,000 in an unnamed Skykomish tributary).  These would prey upon threatened chinook fry and fingerlings.  WDFW also plans to release a huge quantity of 705,000 yearling hatchery steelhead predators into the Snohomish system in 2003, including 250,000 summer run fish.  The draft HGMP for coho states that “Yearling coho production at Wallace River has been reduced from 300,000 to 150,000 recently.  This reduction may help to minimize competition and predation interactions between hatchery coho and naturally produced chinook.  Hatchery coho are released in May while the hatchery summer chinook are released in June.  The wild component (chinook) seems to out-migrate in April/May.”  The three draft HGMPs for steelhead programs in the Snohomish basin all share a common justification statement:  “1. Hatchery fish will be released as smolts at a time to minimize or eliminate adverse interactions with listed fish.”  However, they also share a common conflict:  “Out-migration timing of listed fish/hatchery fish - April-May (chinook)/May”.  This means that wild chinook and hatchery steelhead from three different programs would all be present during May.

26.       Lake Washington basin:  There are at least two indigenous threatened chinook populations in this system (northern Lake Washington tributaries, Cedar River) and WDFW plans to release 450,000 yearling hatchery coho in 2003 that would prey upon threatened chinook fry and fingerlings.  The draft HGMP for coho gives one of its justification statements as follows:  “Time of release not to coincide with out-migration of listed fish.”  This is followed by “Out-migration timing of listed fish/hatchery fish - May (chinook)/April.”  The information is not correct.  WDFW migrant trapping in the Cedar River and Bear Creek has conclusively demonstrated that thousands of chinook fry move out of the streams before April and rear for extended periods in lake habitats.  Hatchery coho released in April would have to pass through these populations of rearing chinook to reach marine waters.

27.       Green River basin:  There is a major indigenous population of threatened chinook in this system.  In 2003, WDFW plans to release 600,000 yearling hatchery coho and 185,000 yearling hatchery steelhead (including 70,000 summer-run fish).  All of these would prey upon threatened chinook fry and fingerlings.  The draft HGMPs for both the summer-run and winter-run steelhead programs state the following as one of their justification statements:  “Time of release not to coincide with out-migration of listed fish.”  However, this is soon followed by:  “Out-migration timing of listed fish/hatchery fish - May/May”.  Both plans also state that predation on listed chinook by hatchery steelhead smolts “undoubtedly occurs”.  Attached as Exhibit G is an example of these.

28.       Puyallup River/White River basin:  There are at least two indigenous threatened chinook populations in this system (Puyallup,White) that would be significantly impacted by planned WDFW releases in 2003, including a listed hatchery chinook population (White River).  A huge release of 780,000 yearling hatchery coho predators is planned by WDFW.  It also plans to release 200,000 yearling hatchery steelhead, including 20,000 in the White River.  All of these yearlings would prey upon threatened chinook fry and fingerlings.  The earlier draft HGMPs for coho and steelhead that were provided to plaintiffs (dated April 2001) state that planned hatchery releases would not avoid out-migrating White River or Puyallup chinook smolts and that both species would likely exercise some unquantified predation mortality on chinook fingerlings.  The plans also state that hatchery coho and steelhead would probably impose some competitive effects on yearling chinook smolts that would be coincidentally migrating downstream and that potential additional predation mortalities could be imposed on chinook fingerlings during estuarine migration.  (Note:  In a December 2002 steelhead HGMP, the same comments appear but words such as “would likely” have been replaced by “may”.  By the time the latest steelhead HGMP was produced (January 2003), the comments were entirely deleted.)

29.       Skokomish River basin:  There is an indigenous population of threatened chinook in this system that would be impacted as fry and fingerlings by releases of 500,000 yearling hatchery coho and 50,000 yearling hatchery steelhead that are planned by WDFW for 2003.  The draft HGMP for coho, which attempts to justify the release of a half million potential predators on chinook, concedes that “We do not know to what extent the George Adams hatchery-origin yearling coho interact with wild Hood Canal chinook.”  The draft HGMP for steelhead admits that “We do not know to what extent the Eells Springs hatchery-origin steelhead interact with wild Hood Canal chinook.”  

30.       Hamma Hamma, Duckabush, and Dosewallips river basins:  These relatively small river systems have a severely depressed indigenous chinook population that would be impacted as fry and fingerlings by planned 2003 WDFW releases of 3,700, 10,000, and 12,500 yearling hatchery steelhead in the Hamma Hamma, Duckabush, and Dosewallips Rivers, respectively.

31.       Dungeness River basin:  This system has an indigenous threatened chinook population, including listed hatchery chinook, that would be impacted by planned 2003 WDFW hatchery programs.  Fry and fingerlings from this threatened chinook population would be preyed upon by both yearling hatchery coho (500,000 fish) and, to a lesser extent, yearling hatchery steelhead (10,000 fish).  The wild chinook population in the Dungeness is probably the smallest remaining indigenous population in the Puget Sound region and would benefit from the elimination of one-half million artificially produced yearling coho predators.

32.       Elwha River basin:  This system has an indigenous population of threatened chinook (including listed hatchery chinook) that would be impacted as fry and fingerlings by a planned 2003 WDFW release of 60,000 yearling hatchery steelhead predators.  The Elwha system will soon be reopened for wild anadromous fish restoration (including listed chinook) and the continued planting of thousands of pounds of artificially produced salmonid predators is inconsistent with this objective. 

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Dated this __ day of March, 2003.

                                                                        _________________________

                                                                        Sam Wright