Wild Stock Gene Banks for ESA-listed Puget Sound Steelhead

Washington State Fish and Wildlife Commission 600 Capitol Way N.

Olympia, WA 98501-1091

Subject: Wild Stock Gene Banks for ESA-listed Puget Sound steelhead

Dear Commissioners,

The undersigned, representatives of our respective conservation organizations, write to you to express our concern over the undue delay on the part of Washington Department of Fish and Wildlife (Department) in designating Wild Stock Gene Banks (WSGBs) for ESA- listed Puget Sound steelhead. More than eight years ago, the Commission (via the Statewide Steelhead Management Plan) directed WDFW to establish a network of WSGBs across the state. Seven years ago, Commission Policy C3619 reiterated the same. WDFW has recently made some progress on this front, but as yet has not selected at least one wild stock gene bank for each of the three Puget Sound steelhead population groups – North Puget Sound; Central-South Puget Sound; Hood Canal-Strait of Juan de Fuca.

WDFW’s public process for soliciting comments regarding the selection of Puget Sound steelhead WSGBs occurred during summer 2015. A year later, despite having received over 700 comments from the public, the Department still has not identified a single Puget Sound steelhead WSGB. We have fewer than 3% of the historical abundance of Puget Sound steelhead and 12 of 20 populations are at high risk of extinction. Data in NMFS’s 2015 Status Review demonstrate that the Department’s recovery efforts to-date are failing and the ESA- status of our state fish continues to edge toward Endangered.

Our immediate concern is for the Department to respect the overwhelming public comments and the sound science supporting the designation of the entire Skagit River basin as a WSGB (Table 1).

Table 1. Tally of public comments submitted to WDFW during summer 2015 comment period documenting overwhelming public support for WSGBs in the Skagit.

Watersheds designated as WSGBs should be the BEST wild steelhead watersheds in each major population group. The Skagit has largest wild steelhead run in Puget Sound (most recently 9,000+) and the wild steelhead population appears to be expanding rapidly as a result of 50-60% reduction in prior hatchery plant numbers beginning in 2008. Spring 2016 spawner surveys suggest this trend is still accelerating, with steelhead redd counts up over 200% in major middle/lower Skagit tributaries. The population is extremely diverse with multiple sub-populations of winter and summer run steelhead distributed throughout the anadromous reaches. The Skagit drains some of the highest land areas in the state insuring cold water refugia to buffer against climate change impacts. The Cascade, Sauk and Skagit are all federally designated Wild & Scenic Rivers limiting riparian development. Most of the watershed is in timberland, protected national forest, wilderness areas, North Cascade National Park, provincial forest and provincial park (in BC).

The Skagit watershed, in its entirety, meets the Department’s own criteria for selecting WSGBs. The overwhelming majority of public and technical comments submitted to the Department identify the entire Skagit as North Puget Sound’s most logical WSGB. The Skagit – in its entirety – is the best last hope for wild Puget Sound steelhead. If the entire Skagit watershed doesn’t qualify as a steelhead WSGB, it is hard to imagine what watershed would.

The Department has delayed bringing this public process to its long overdue conclusion and has prevaricated to us in several recent meetings regarding intentions to designate the entire Skagit as a WSGB, and the reasons for the delay. We believe that it is time for the Commission to direct the Department to immediately complete this process and, in particular, to designate the entire Skagit River basins as the keystone WSGB in Puget Sound.

Sincerely,

Kurt Beardslee Executive Director Wild Fish Conservancy

Rich Simms Honorary Director Wild Steelhead Coalition

Pete Soverel President The Conservation Angler

Gary Bergquist President Washington Fly Fishing Club

Bill Redman Member, IFFF Steelhead Committee

Tom Derry Executive Director Native Fish Society

Bill McMillan Independent Scientist

Cc. Jim Unsworth, Director

Jim Scott, Special Assistant to the Director