River Steward says "No" to Proposed Pioneer Park Hatchery.

River Steward Bradley Bobbitt was concerned when he heard that the Washington Department of Fish and Wildlife had submitted an application to permit a new fish hatchery through the Washington State Environmental Policy Act (SEPA). The proposed project was in the active river channel migration zone, and was sure to further degrade the habitat of the Deschutes River near Olympia. Set up to ensure that citizens of the state have a way to protect their environment, Bradley submitted the following comments through the SEPA forum in order to protect his home waters:

Pioneer Park Hatchery Complex Creek SEPA MDNS 17-009, May 2017

Dear Ms. Wood,

The Native Fish Society appreciates the opportunity to provide comments on the Washington State Department of Fish and Wildlife’s Mitigated Determination of Non-significance (MDNS) for the proposed Pioneer Park Hatchery and complex in Thurston County. The project would construct a hatchery building and supporting facilities including a surface water intake, pollution abatement pond, a pipe outfall at the river bank to return process water to the stream, and paving. We believe that the MDNS is not supported by the information provided and, furthermore, that investment in this new hatchery facility would undermine agency goals for fisheries and fish recovery in Puget Sound in light of the recommendations of the Hatchery Scientific Review Group. Native Fish Society recommends instead that the Department invest these funds in improving water quality and habitat in the watershed, which would increase the long-term abundance and health of native fish in the Deschutes. At a minimum, Native Fish Society would like to see a full Environmental Impact Statement conducted if the Department wishes to pursue this hatchery project further.

Overall there are three main issues with the Department’s Mitigated Determination of Non-signifance finding:

• While the MDNS states that “State of Washington water quality standards must be met during construction of the {project’s} swale” it does not address how the facility’s operation will impact water quality on the Deschutes River. The Washington State Department of Ecology’s website states that “Portions of the Deschutes River, Percival Creek, other creeks in the area, Capitol Lake, and the marine waters of Budd Inlet do not meet water quality standards for temperature, fecal coliform bacteria, dissolved oxygen, pH, phosphorus, and fine sediment. These waterbodies have low dissolved oxygen levels, high water temperatures, excess sediment, too much phosphorus, and high bacteria levels.” http://www.ecy.wa.gov/programs/wq/tmdl/deschutes/. Operations of a hatchery raising 3.8 million chinook smolts on average each year are certain to add to the water quality issues facing this river system.

• The MDNS only addresses the on-site impacts of constructing the facility and does not address how producing and releasing 3.8 million chinook smolts will impact other species in the Deschutes River and Puget Sound. The impact of these hatchery-reared chinook to wild and native fish in the area is of particular concern. While the Hatchery Science Review Group recommended developing plans for rearing and release facilities that eliminate the need for transferring fish from out-of-basin, the group also stated that “A general concern exists across all species regarding the current South Sound carrying capacity and its effect on current survival rates of all species with the yearling life history strategy, including natural and hatchery chinook, coho and steelhead”. While the intention of the program is to bolster harvest opportunities in marine fisheries, it would seem that continuing to release large amounts of hatchery chinook into south Puget Sound would have a negative impact on the opportunity to fish at all by way of competition with wild populations of coho, cutthroat trout, and steelhead.

• There are several inaccurate statements in the MDNS. First, the report states that there are no fish in the Deschutes River system listed as threatened or endangered. Puget Sound Steelhead are listed as threatened under the Endangered Species Act. Second, the report states that there are no invasive species in the vicinity of the project, failing to identify invasive New Zealand Mudsnails which are present in Capitol Lake.

Native Fish Society and its members are concerned that the Departments MDNS does not adequately address the impacts of this proposed hatchery on water quality in the Deschutes River and fisheries in Puget Sound. Native Fish Society requests that the Department redirect these funds toward habitat protection and water quality improvements in south Puget Sound or at minimum conduct an EIS for this project if the state insists on continuing forward. Native Fish Society appreciates the opportunity to comment on this project and looks forward to working with the Department on projects to benefit south Puget Sound fisheries.

Bradley Bobbitt

South Puget Sound Tributaries

Native Fish Society River Steward