Questions from the Mid Coast Watershed Council

As the Port of Newport Oregon was considering a proposal from Salmon For Oregon Association for an endorsement of our proposed project, the Mid Coast Watershed Council addressed a letter to the Port addressing their concerns for the project.  The letter was forwared to us  and we have included our responces along with the questions here.  There are good questions, and we believe good answers to their concerns.


Mid-Coast Watersheds Council
23 North Coast Highway 
Newport, Oregon 97365

17 July 2012

Port Commission Port of Newport 
600 SE Bay Boulevard Newport, OR 97365 

Dear President Barton and Port Commissioners: 

We are writing in response to the Port's consideration of the recently proposed Salmon for Oregon Inc. plan to raise Spring Chinook salmon smolts on Port facilities in Yaquina Bay. We have serious concerns over this proposal. We appreciate your action in choosing to defer a decision on support for a month to gather more information. While we do not have enough knowledge of the details of the proposal to fully comment, we believe several concerns need to be addressed before any decision to provide support is made. Artificial propagation programs for salmon (and trout) often, but not always, cause problems for naturally—rearing populations in the same waters, and for the environment surrounding the rearing facility, and any proposals for new propagation programs need to adequately address these risks. Here is our list of concerns: 

Question:
When out-of-basin fish stocks are used, they may negatively affect local stocks through hybridization and/or through ecological competition. While the Yaquina River does not have native Spring Chinook, both the Alsea and Siletz basins do, and straying into those basins is likely. How will these risks be addressed? 

Answer:
Based on the experience of other estuary net pen acclimation op- erations, it is unlikely that straying to either the Alsea or Siletz  watershed will occur, however, the project will cooperate with ODFW staff in monitoring for straying. Salmon for Oregon is cur rently discussing a research project with Dr. Michael Banks (Fish Geneticists OSU – Hatfield) and Dr. David Noakes (Senior Scientist OHRC - Alsea) to determine where the fish are harvested and where unharvested fish die.

NOAA fisheries allows for a 10% incidence of non-wild fish on the spawning grounds in streams adjacent to other net pen operations such as Youngs Bay near Astoria, Oregon. Adult fish not harvested will likely migrate up the Yaquina rather than to other systems. They will likely expire prior to spawning as temperature regimes in the Yaquina are above that for sustainable spawning and gamete development. Local genetic stocks would be preferable for the project, however, several coastal stocks are already extinct and the Alsea run virtually so. Siletz does have a stable run of Spring Chinook, however, the numbers (less than 300 per year) will not
allow for removing any for a harvest project.


Question:
Out-of-basin transfers of fish sometimes import pathogens that affect local stocks. What is the health assurance plan to prevent such introductions of pathogens? 

Answer:
This project will comply with all ODFW pathology protocols, which disallows the transfer and release of diseased fish. Much like the spring Chinook project in Youngs Bay, Blind Slough and Tongue Point, which receive their pre-smolts from the Gnat Creek Fish Hatchery, the springers used in this project will be vaccinated for Vibriosis, a marine pathogen and will be monitored by ODFW Fish Pathology staff prior to transfer to the net pens. Standard hatchery practices, which isolate and remove diseased fish will be followed and in the event of an epizootic morts will be removed and disposed of in a manner consistent with ODFW Fish Pathology practices.


Question:
In other areas, net-pen facilities have a history of being sources of excess nutrient deposition through uneaten food and through fecal material from the fish being raised. How will this be addressed in facility siting and operation?

Answer:
Permits for net pen fish rearing operations from EPA and DEQ are required whenever total biomass of fish increases by 20,000 pounds at any given site. Net pen problems come from fish farm ing that requires pens to sit in the water for up to a year and a half in the same location. Because the duration of imprinting of our fish is limited to six weeks or less, total biomass gain will be well below these thresholds. These standards have been established in Oregon waters and have been in place for many years in other locations.


Question:
In the unfortunate event of a large mortality event in the facility, how wold cleanup, disposal, and decontamination be accomplished?


Answer:

Although highly unlikely to occur due to low density loading of net pens, (i.e. less than .75 lb/cu/ft) in the event a major epizootic even occurs, mortalities will be collected and disposed of in accordance with ODFW Fish Pathology protocols, which allow for disposal at landfills, burial
and/or incineration. Any nets or gear used to handle diseased organisms will be disinfected with
chlorination bath in accordance with ODFW Fish Pathology protocols.


Question:
In the event the program is not successful, how will facilities be decommissioned and removed? Will the Port be saddled with these costs?

Answer:
In the event the facility is in need of decommission, that will be accomplished and paid for by
Salmon For Oregon. A written agreement to codify this would be made with the Port.


Question:
We do not know where the facility is proposed to be located. The newspaper reports a "Toledo location". We have been involved in habitat conservation and restoration projects in the Yaquina estuary and river, and are concerned with impacts on conservation goals, including downstream and in the vicinity of Mill Creek, a FEMAT key watershed. Competition for food and limitations of water quality could have a negative impact on threatened Coho and other species.

Answer:
The location has not yet been determined, but the suggestion of Toledo was misreported. Although that location was discussed originally, it was only hypothetical. The areas most
desirable for this project are those closest to the tide water and still able to get the fresh water imprint required for the salmon.


Final site location decisions will be made by ODFW and cooperating agencies.

Chinook smolts at 10/lb or larger will not compete with coho fingerlings in the estuary. Their size differential and other species specific factors make their behavior noncompetitive. Chinook
releases will likely mimic those of the Youngs Bay releases that acoustical studies conducted by independent investigators showed that 99.9% of releases left on the first out-going tide and all were gone by the second such tidal event. This is very likely to be the case in Yaquina Bay with no ecological impact on resident salmonids.

Question:
There are also two additional issues the Port should consider. First, it is our understanding that the Port was involved and for a while had ownership of some or all of the OreAqua facilities and programs, and found that to be economically unfeasible at that time. We respectfully suggest the Port review records and institutional memory of the period for any relevant lessons to guide your decision-making. 

Answer:
This project has nothing whatsoever to do with Ore Aqua, or it’s business model.  It is directly comparable to current net pen fforts at Youngs’ Bay, and Winchester Bay and a few others are
currently operated under the guidance of ODFW.  This effort is a not for profit venture.   Salmon For Oregon Association Inc. is a 501(c)(3).  As such there is no financial interest for any of the members of the board whatsoever. Returning salmon are a public resource and a benefit to commercial and sports fishermen and a boost to the local economy. We advocate this project for the public benefit and nothing else.


Question:
Second, we understand that Oregon Department of Fish and Wildlife is well-along in its process of developing a multi-species Native Fish Conservation Plan for Oregon Coastal Salmonids, including Chinook Salmon, and that this plan will set policy for propagation programs and also harvest goals and processes for managing annual harvests. It is our understanding that a drat plan will become available for public input and involvement in August 2012, with a goal of final adoption early in 2013. We believe that the public process of refining and adopting this plan will provide the proper venue for consideration of the Salmon for Oregon Inc. plan and any other new salmonid propagation proposals, and for addressing the concerns we have listed above. 

We therefore recommend that the Port defer any action on this proposal until the Native Fish Conservation Plan is adopted, and then follow the lead of that Plan in addressing the advisability of bringing this program to Yaquina Bay. 

Answer:
This project is designed specifically to be in compliance with the existing Oregon Native Fish Plan, and would not be allowed if it was a threat to any native fish stocks whether listed or unlisted.  We are working with the Director’s office of ODFW and staff to in sure compliance and do not anticipate that the Conservation Plan will identify any constraints not already identified in the existing Native Fish Plan.