In the introductory description of the project in the preliminary review the ISRP stated, “More detailed review and evaluation would be encompassed in a Three-Step process, which the ISRP supports.” Apparently the sponsors took this statement to indicate endorsement of progressing to a Three-Step Review. They comment in their response that this statement is inconsistent with the Not Fundable recommendation in the preliminary review. The ISRP regrets the choice of words. The ISRP intent was to communicate their general support for the Three-Step Review, not that this proposal was sufficient to progress to that point. The ISRP regrets having confused the project sponsor.

The response leaves the clear impression that the sponsors thought the ISRP would at least look through the Walla Walla Hatchery Master Plan during this proposal review to find important elements indicating initiating Three-Step Review was justified. In several instances in the response, the sponsors point out that the information requested is in a Master Plan. The ISRP did not have access to the draft Walla Walla Master Plan. Nonetheless, in this review cycle all the information to support a project needed to reside in the proposal or narrative. This misunderstanding is unfortunate.

The ISRP remain unconvinced of the rationale for the hatchery as the appropriate rebuilding tool for spring Chinook in the Walla Walla River, based on the material contained in the proposal. From the proposal it is confusing to determine what mix of harvest augmentation and natural production restoration is the real purpose of the hatchery production. From the proposal it is not possible for the ISRP to conclude that the habitat conditions are actually sufficient to support the hatchery production in addition to the fish that are currently returning to the watershed, even though those numbers are only in the tens to hundreds annually.

From the response the question of the rationale for hatchery production becomes even more of an issue. Sponsors state: “[T]he demographics of spring Chinook remain ‘upside down’, such that recently reintroduced natural production in the Walla Walla is not likely to sustain itself to any great extent without increased human intervention, and c) there is capacity in the system for the use of artificial production to re-establish and sustain both natural and artificial production in the system.”

The observation that recent reintroductions are not likely to sustain themselves argues to delay artificial production, not a rationale to undertake a Three-Step Review to develop a hatchery program that includes a goal of restoring a self-sustaining population. It is not clear to the ISRP what this capacity might be, but it seems mutually exclusive to have natural production sustained by artificial production. In an integrate hatchery program, with both natural and hatchery subcomponents, the natural component needs to be self-sustaining. The ISRP expects that a moderately fecund species like spring Chinook should be able to rebuild from low abundance if habitat conditions are suitably improved.

If a future proposal is developed justification is needed that addresses expected carrying capacity or other information from EDT or similar analyses, and anticipated productivity and abundance of the hatchery and natural population components. There remains a concern for impacts to non-focal or other species (e.g., steelhead), for which there was insufficient consideration in the proposal. This topic also needs to be fully addressed.

In brief, a major concern of the ISRP arising from the proposal was the immediate use of the Carson Stock. In the past, the ISRP commented that a scientifically sound justification was not given for construction of this facility to increase hatchery fish production with Carson stock. These comments still apply. It is a proposal to produce, as soon as possible, adult fish for harvest. Waters of the Walla Walla Basin are viewed, by the sponsors, as a production area that cannot produce the desired harvest, so a hatchery is needed to meet that harvest. Hatcheries can be useful tools in the production of fish for harvest, in general.

As stated previously, if the Walla Walla Basin and the hatchery is to be viewed as a fish-farming operation, there are few technical questions concerning the proposal. If, however, native stocks of Walla Walla salmonids are to be restored and protected, this proposal is not fundable. See programmatic comments related to supplementation as an experiment.

General comments:

No justification is included that addresses expected carrying capacity or other information from EDT or similar analyses.

The hatchery can be justified as mitigation for dams on the Columbia, to produce fish for harvest (this still requires a harvest plan that does not impact wild fish), but it does not fit well as a supplementation project or for re-building wild runs, and does not flow from the subbasin plan. The subbasin plan states that WDFW has no established goal for spring chinook in the basin, and it is difficult to assess status from EDT reports: "Managers will need to continue to refine the EDT outputs to clarify the balance between natural production and artificial production that will meet subbasin adult return expectations and needs."

Artificial propagation (out-of-system Carson stock) is recommended by the proponent to increase the parental base from which to build returns for natural production and harvest. What evidence is there that this would work? Wild production should be able to rebuild naturally. If not, why not, and why would (domestic brood) hatchery fish do any better? They very likely would not.

Artificial propagation is stated as a key element in the Walla Walla fisheries restoration program and required in order to achieve spring Chinook natural production, broodstock, and harvest objectives in the Walla Walla Subbasin. It is not clear that natural production will arise from the artificial production, but there could be hatchery broodstock and harvest products realized by the project. If natural production were to recruit from hatchery spawners, the natural production shall quickly copy the hatchery fish in character (genetic and otherwise), and eventually may eliminate wild fish. Replacement of wild fish by hatchery fish is the likely outcome of this proposed action – a result that is contrary to subbasin goals.

There remains a concern for impacts to non-focal or other species (e.g., steelhead), for which there is insufficient consideration in the proposal.