Council Document ISRP 2000-7

Independent Scientific Review Panel

for the Northwest Power Planning Council

Review of the

MASTER PLAN FOR FEASIBILITY ASSESSMENT OF A WHITE

STURGEON ‘PUT AND TAKE’ CONSUMPTIVE FISHERIES IN OXBOW AND

HELLS CANYON RESERVOIRS, SNAKE RIVER

Partial Step One of the Northwest Power Planning Council’s

Three-Step Review Process

Charles C. Coutant

Daniel Goodman

Susan S. Hanna

Nancy Huntly

Dennis Lettenmaier

Lyman McDonald

Brian Riddell

William Smoker

Richard R. Whitney

Richard N. Williams

ISRP 2000-6

July 31, 2000
ISRP 2000-7 Sturgeon 3-Step

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ISRP Partial Step One Review of the Master Plan for Feasibility

Assessment of a White Sturgeon ‘Put and Take’ Consumptive Fisheries

in Oxbow and Hells Canyon Reservoirs, Snake River

Review Process

On June 30, 2000, the Northwest Power Planning Council requested that the ISRP

review the master plan for the “Consumptive Sturgeon Fishery - Hells Canyon and

Oxbow Reservoirs” project. The goal of the project is to provide fishery opportunities for

white sturgeon in Oxbow and Hells Canyon reservoirs to mitigate for loss of white

sturgeon fisheries in Columbia and Snake River basins due to hydropower development

and operations. This review is a partial Step One review under the Council’s Three-Step

Review Process. The ISRP’s review is provided below in two sections: 1)

Recommendations and Findings, 2) Specific ISRP Reviewer Comments. The Specific

Reviewer Comments are incorporated in the three-step review template submitted by the

Nez Perce Tribe.

Section 1. ISRP Recommendations and Findings

Overall Recommendation

The submittal is not adequate to pass this Partial Step One Review. The plan does not

provide a logical research design that is likely to answer uncertainties about the project’s

feasibility (Questions 1.1 – 1.3, 1.14, 1.20, and 3.1-3.3). The project sponsors need to

reevaluate their basic plan and develop a more disciplined approach that first identifies

and then designs a plan to measure the critical elements necessary to determine feasibility

of the proposed put-and-take sturgeon fishery. The plan needs to be bolstered particularly

in terms of assessment of carrying capacity, emigration, survival, and growth rates

(Questions 1.3, 1.7 1.14, 1.19, 1.20, and 3.1-3.3).

General Findings

The concept described in this plan is a “put, grow and take” procedure such as those that

often have been used with good result in trout and other fisheries. The proposal described

in the Management Plan is identified as a feasibility study. In brief, the project proposes

the following, as described on pages 34-39:

Phase 1 covers two years. In 2000-2001, 50 sturgeon will be released that are equipped

with sonic tags and PIT tags and marked by removal of a scute. A procedure is described

for following sonic tagged fish at intervals during the expected lifetime of the tag. There

is no description of how the PIT tags would be recovered or how the information would

be used. In 2001-2002, 500 sturgeon will be released, again with 50 marked with sonic

tags. There is no mention of PIT tags or of scute removal in the second year releases.

Assessment of feasibility of the proposed sturgeon fishery would occur in 2002-2003

(page 38). The emphasis in the assessment process is upon a proposed Monte-Carlo
ISRP 2000-7 Sturgeon 3-Step

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simulation modeling exercise. The project would then move to Phase 2, which would

include full initiation (planting of sturgeon) and monitoring.

A key element that is missing in the Partial Step One Plan is specification of criteria that

will be used for deciding whether or not the concept is feasible and thus determining

whether it is appropriate to proceed on to Phase 2 in the overall Plan (Questions 1.20 and

2.1). Specification of these criteria will identify the elements that need close monitoring

during Phase 1. This logically will lead to specification of an evaluation procedure that

will be used before moving to Phase 2. Similarly, criteria specified for moving from

Phase 2 to Phase 3 should be defined. In other words, there is a need to more sharply

define a plan for monitoring and evaluation throughout all steps of the proposed project

(Question 2.1). This is a comment previously made by the ISRP during the review

process in FY2000. While the modeling exercise employed crucial factors that will

determine feasibility, i.e. rate of survival of planted sturgeon, rate of emigration, and

fishing rate, there is a need to explain how the Phase 1 studies would produce useful

estimates of these parameters. By useful, we mean estimates made with a degree of

precision that will satisfy the managers during the assessment process in 2002-2003. The

proposers might seek additional outside expertise in development, parameterization, and

evaluation of the models they intend to use.

Subjects of Special Interest

Need for Baseline Data: There is no question that more data are needed on sturgeon in

the reservoirs, but as presented this is not the project that will collect those data (Question

1.8 and 3.3). Project sponsors need a more general perspective and reasonable analytical

model. Perhaps they should solicit advice from CRITFC or others on the NPT staff who

have recently developed monitoring and evaluation plans.

It is not clear what kind of interactions proposed releases under this project would have

with those through Idaho Power and IDFG efforts. Moreover, it is not clear what results

other sturgeon projects in the reservoir have generated to date, e.g. have the Idaho Power

efforts produced information that might apply here?

Alternative Approaches: An alternative approach, such as seining fish from the large

populations above or below the reservoirs should be considered. Removal of the numbers

of fish intended for planting into the study area reservoirs (50 the first year and 550 the

second) is unlikely to adversely effect the populations in the Hells Canyon and the BlissC.J. Strike areas, which each have population estimates of 2500 or more sturgeon.

Introducing wild naturally spawned sturgeon will also make the genetic concerns

expressed in the proposal nearly moot. This alternative approach deserves more

consideration and discussion within the proposal itself (Question 1.5).

Genetic: Considering the normal life history of Columbia River white sturgeon, one

would expect river-wide homogeneity with respect to their genetic composition. Adults
ISRP 2000-7 Sturgeon 3-Step

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are anadromous, but no evidence has been found that individuals seek out specific

spawning locations within the river, and such behavior would be unexpected. Even if it

occurs, the effect on genetic integrity would be minimal, due to the nature of their

spawning habits. Sturgeon are broadcast spawners. Eggs are deposited in areas of high

flow, where they are rapidly carried downstream and widely distributed on the way. Thus,

a mechanism, such as occurs with salmon where they hatch in a particular place upon

which they may imprint, is lacking in sturgeon. At the same time it is to be recognized

that in situations where sturgeon populations have been isolated by natural barriers, such

as in the Kootenai River, the fish have been shown to have developed unique genetic

characteristics. Whether these are of selective advantage or merely a result of genetic drift

might be debatable, but it is clear that sturgeon populations that are isolated can develop

such characteristics.

The Management Plan refers to studies being conducted by the University of Idaho

genetics lab to assess the genetic variation among Columbia Basin white sturgeon

populations. Considering the extent to which the river has been fragmented by dams, it

will not be surprising if these studies show differences among isolated stocks. It is

questionable whether detection of such differences should be interpreted to mean it might

be important to maintain isolation. Perhaps a more important question relating to the

proposed put, grow, and take project, is whether sturgeon arising from a fish culture

program that depends for its brood stock upon fish taken from the Snake River might

adversely affect the genetic composition of the original group if planted individuals that

emigrate happen to spawn naturally with the parent stock. Both questions, however, seem

rather academic, perhaps with little practical application to the situation described in this

management plan. Even if the stocked white sturgeon survive and spawn with wild fish

below Hells Canyon, they would not necessarily pose a risk to Hells Canyon populations.

In this context, the planned experiment that would attempt to measure survival of

entrained sturgeon is probably unnecessary. What if a portion of the emigration occurs

over the spillway? How would this be taken into account in estimating the total number

of survivors?

Finally, the few fish involved in these initial tests are unlikely to pose a genetic risk to a

large natural population. As the authors note (section 5.2.5), the essential issue in

minimizing genetic risk is maintaining a large genetically effective population size (Nc).

But the ability to do this may have been compromised early in the culture history of these

fish. The investigation and monitoring of Nc should be developed as an ongoing priority.

(Questions 1.19, 1.20. 3.3, 3.4)

Feasibility of Supporting a Fishery Using the Production Assessments and Model.

The Management Plan provides a population model to estimate potential fishery benefits

and to evaluate potential genetic risks. However, the authors start with little to no

information about the dynamics of sturgeon in these reservoirs and develop a model

(Excel spreadsheet) that seems to indicate the potential for the successful development of

a small fishery (consistent with their goal of about 500 animals per year).

Demonstrating potential is about as far as this assessment should go. The proponents

simply must collect some data, particularly on growth rate, before any credible dynamics
ISRP 2000-7 Sturgeon 3-Step

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model should be developed further. In our opinion, certain assumptions clearly dictate the

outcomes in Tables 2 through 5. For example, the assumption of constant growth

accounts for increasing biomass with stocking numbers (weight harvested to weight

stocks constant in Table 4) and the conclusions about stocking densities (page 24). Is the

resulting implication that there is no limit to carrying capacity in these systems? We find

this result to be highly doubtful given the turnover rates stated on page 9. Also, the

assumption of constant natural mortality is a very optimistic scenario to rely on.

Alternative survival models might have been examined, such as survival being inversely

proportional to weight. It is far more reasonable to assume larger natural mortality at

small size than to assume equal mortality rates over all ages. For these reasons, it seems

unlikely that a defensible determination of feasibility can be made prior to planting larger

numbers of sturgeon and following their progress with more intensive sampling over a

longer time period than the two years proposed. (Questions 1.12-1.18, 4.2).

Environmental Assessment: The Management Plan postpones consideration of this

issue. It might at least recognize that the ecosystem will adjust for the presence of larger

numbers of sturgeon. Since salmon are not present above Hells Canyon Dam they will not

be affected. With use of information from food habit studies of sturgeon elsewhere, it

should be possible to predict effects on certain aquatic components of the food web.

Summary of Previous Sturgeon Studies in mid-Snake River. The NPT proposal refers

to a white sturgeon conservation plan being developed by the Idaho Power Company and

notes in their response to Question 3f that Idaho Power Company has collected extensive

information on the status and life history of white sturgeon throughout the Snake River.

The proposal also noted that IDFG had planted more than 5000 juvenile sturgeon in the

mid and upper Snake River in the early 1990s (pp. 20-21, Partial Step One Plan). The

ISRP wondered what information is available from IDFG and Idaho Power Company

from their past and present efforts, and how might this be used in the proposed NPT

feasibility study. We feel that the lack of summary and discussion of work by Idaho

Power Company and Idaho Department of Fish and Game constitute a serious omission

from the proposal. (Questions 1.9, 3.2).

General Recommendations

The submittal is not adequate to pass this Partial Step One Review due to deficiencies in

project organization and design. The Partial Step One Plan does not adequately address

concerns expressed in earlier ISRP reviews (FY2000 and the subsequent ”Fix-It Loop”).

It does not provide a logical research design that is likely to answer uncertainties about

the project’s feasibility. (Questions 1.1 – 1.3, 1.14, 1.20, and 3.1-3.3).

In those reviews, the project sponsors disagreed with the ISRP about whether the project

was an implementation or research project. Regardless of whether the project is labeled

as research, implementation, or mitigation, the questions raised by the feasibility study

and the data needed to answer them, constitute research. Feasibility studies, by their very

nature, ask questions and attempt to answer them through the collection of appropriate

data.
ISRP 2000-7 Sturgeon 3-Step

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The project sponsors need to reevaluate their basic plan and develop a more disciplined

approach that first identifies and then designs a plan to measure the critical elements

necessary to determine feasibility of the proposed put-and-take sturgeon fishery. The

sponsors need to provide a structured approach that considers the potential outcome of

their efforts and the potential utility of the information gathered.

The plan lacks any kind of a decision tree into which anticipated results would be used to

define the project’s feasibility toward future actions. As part of subsequent submittals,

the project sponsors should present, in point form or flow chart, an outline of what the

feasibility study really has to demonstrate so they can have a successful fishery. The

ISRP requested a similar decision tree from the NPT for its Clearwater Hatchery

Monitoring and Evaluation Plan. Project sponsors for this plan might gain valuable input

from other NPT or CRITC staff familiar with the Clearwater plan as this Step One Plan is

revised for resubmission.

The monitoring and evaluation plan needs to be revised to conform to the project’s

overall goals and objectives. Whether or not this is called a research proposal, it must

generate research-type data in order to provide information useful at the assessment

Phase. This requires that there be a scientifically acceptable monitoring and evaluation

design. The usefulness of data to test hypotheses depends on having hypotheses, or

questions, specified in advance so that the appropriate data set is defined before

collection. Further, often, pre-treatment (i.e. before fish stocking), initial (i.e., time of first

fish stocking), and continuing data (e.g., data on food availability) are needed to

understand the outcome of work such as this; the design and sampling need to be planned

before the work is begun. The plan needs to be bolstered particularly in terms of

assessment of carrying capacity, emigration, survival, and growth rates. The plan does not

describe enough about the intended fishery, such as length of time needed for the

sturgeon to reach a harvestable size, anticipated angler response, expected regulation of

the fishery, and fishing pressure, etc. (Questions 3.1-3.4).
ISRP 2000-7 Sturgeon 3-Step

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Section 2. Specific ISRP Reviewer Comments

This section is adapted from the Nez Perce Tribe’s Three-Step submittal: Appendices 7-9.

Each Three-Step question (red text) is followed by the Tribe’s response to the question, or

reference to a section of the master plan or other supporting documents where the

question is addressed (black text). This response is followed by the ISRP’s review

comments on whether the master plan and supporting documents adequately address the

Three-Step question (blue text).

Program Language Regarding Master Planning

Requirements

7.4B.1 Master Planning

Because of the need to address potential conflicts among increased production, mixedstock harvest, gene conservation, consistency with other plans and other objectives, the

Council calls for detailed master plans where there is not a National Environmental

Policy Act document that provides enough information to evaluate new artificial

production projects. Below, the Council provides a suggested list of master plan

elements. This list is intended to offer guidance, not to impose requirements. Not all of

these elements may be relevant in all projects, and some unlisted elements may be

important. In general, however, the elements listed below should be considered in the

course of master planning.

Question 1.1: Project goals

NPT Response: Determine the feasibility of a ‘put, grow, and take’ white sturgeon

fishery in Oxbow and Hells Canyon reservoirs.

ISRP Reviewer Comments: The primary factors that will determine feasibility are rate

of emigration, rate of survival of planted sturgeon, and the fishing rate that is applied. At

the present time information on these factors is not available. The feasibility study is

intended to develop estimates of the first two factors, but there is no discussion of any

fishery that might be encouraged or permitted on the planted sturgeon. The plan should

include NPT’s estimate of the number of sturgeon desired; this places some scale to the

practicality of the program.

Question 1.2: Measurable and time-limited objectives

NPT Response: See chapter 5, page 18.

ISRP Reviewer Comments: Phase 1 is to take place between 2000 and 2002 (page 32).

Phase 2 would extend for 6-8 years thereafter to “build up the sturgeon population” and

allow them to reach catchable size (page 17), and Phase 3 would continue from that time

using stocking densities determined in Phase 2. Prior to initiation of Phase 2 there would

be an “assessment of feasibility” in 2002-2003, using a mathematical model. The

proposal does not make it clear that sufficient information can be gathered up to that time

to make an appropriate assessment. For example, there is not adequate time allowed in
ISRP 2000-7 Sturgeon 3-Step

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Stage 1 to evaluate sustainable growth rates and carrying capacity. Some thought should

be given to this.

The NPT Plan indicates that sturgeon would be stocked at the age of 2 (page 20). We note

that white sturgeon in the lower Columbia River reach the legal minimum size limit of 36

inches when they are 8 or 9 years old. Of course, the same size limit would not

necessarily apply here, but it would be useful to consider what size limit, if any might

apply and to relate that to the number of years during which estimates of rates of

emigration, of survival in the reservoir, and of fishing might be obtained by the

monitoring efforts that are proposed. Consideration of the expected precision of those

estimates arising from observations on 50 fish in each of two years would also be a useful

exercise in designing the monitoring program. In other words, we wonder whether the

stated time limited objectives are realistic. Can enough observations of sonic tagged

sturgeon be made during the expected lifetime of the sonic tags to provide useful

estimates of rate of emigration or other characteristics? How do the PIT tags fit into the

picture? Where and how would recoveries be made?

Question 1.3: Factors limiting production of the target species

NPT Response: See chapter 2, pages 6-9.

ISRP Reviewer Comments: This reference is actually to the Status section but the

impact of dams and the lack of recruitment are included. The Management Plan ought to

have recognized that production of sturgeon will be limited by the basic productivity of

that portion of the system upon which the plan is focused. There are interactions among

the fish species that are present, and these will be adjusted in response to stocking of

sturgeon. While the Plan mentions other species that are present, it makes no

acknowledgement of these interactions.

Question 1.4: Expected project benefits (e.g., gene conservation, preservation of

biological diversity, fishery enhancement and/or new information).

NPT Response: Information regarding the potential of entrainment of white sturgeon and

entrainment survival at Hells Canyon Dam.

ISRP Reviewer Comments: The NPT response should have simply acknowledged that it

is a fishery enhancement effort. It is not clear why their response focuses only on

entrainment ... the expected Stage 1 benefits are broader including growth, survival, etc.

Question 1.5: Alternatives for resolving the resource problem

NPT Response: Proposed activities are directed toward information collection.

ISRP Reviewer Comments: This reply is inadequate. It is true that their Stage 1

programs address information collection but they are intended to examine the feasibility

of outplanting juvenile sturgeon. The alternative sources of sturgeon were noted but only

the cultured stock was detailed in the assessment and no comments were made about the
ISRP 2000-7 Sturgeon 3-Step

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feasibility of juveniles from other Snake River populations. The authors do note that this

is not intended as a new production hatchery program. However, what is not commented

on is the feasibility of altering flow regimes to provide spawning areas or to provide

downstream passage from the larger up-stream natural populations.

Similarly, section 2.3 notes that other sections of the upper Snake River (here referred to

as the Mid-Snake) support reasonably robust sturgeon populations (> 3,000 sturgeon in

the Lower Granite to Hells Canyon section and ~ 2,500 sturgeon in the C.J. Strike to Bliss

area), while the Hells Canyon to Swan Falls area (which includes the study area) appears

to support only about 150 sturgeon. Limiting factors that have produced these

distributional abundances are not discussed in the plan and may be critically important in

the success or failure of the proposed “put-grow-take” fishery. The plan attempts to deal

with some of this question by identifying uncertainties associated with growth, survival

and potential yield (section 5.2.2).

The activities are built around substituting a sturgeon fishery in this reach for sturgeon

fisheries adversely affected by the hydroelectric system. The information collection

element is, or ought to be focused on evaluating the effectiveness of this particular

activity. The proposed information gathering activities are primarily designed to

determine feasibility of the management plan not primarily designed to gather

information as the NPT response implies.

Question 1.6: Rationale for the proposed project

NPT Response: See section 1.2, pages 2-3.

ISRP Reviewer Comments: OK. Agreed citation to section, but response also needs to

refer to Status section. The stepped progression of research programs is a strong point.

Question 1.7: How the proposed production project will maintain or sustain increases in

production

NPT Response: The current proposed activities does not include increasing production.

ISRP Reviewer Comments: Stage 1 may not have this intention, but the purpose for the

program is to increase production by outplanting cultured (commercially available, cooperative program) or by transfer of juveniles from other Snake River populations. Over

the long haul, it does propose to increase production. Even over the short term, it

presumably could add to production if any effort is undertaken to measure the potential

catchability of planted sturgeon, which would require some fishing. In fact, this seems to

be a key missing element. The questions not addressed in the Plan ought to be: “Will

anyone fish for these sturgeon and can they be successful?” The way to find out would be

to open a fishery.

Question 1.8: The historical and current status of anadromous and resident fish in the

sub-basin
ISRP 2000-7 Sturgeon 3-Step

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NPT Response: See Chapter 2, pages 6-12

ISRP Reviewer Comments: Brief but sufficient.

Question 1.9: The current (and planned) management of anadromous and resident fish in

the sub-basin

NPT Response: See Chapter 3, pages 13-15.

ISRP Reviewer Comments: OK. Good/informative chapter but focused on sturgeon. Is

there any basis for interactions with other species (did comment on Bull trout).

Concern about Co-managers issue:

Throughout the text, there are references to ongoing programs that should substantially

aid in this evaluation. However, there are also notations to past releases of sturgeon and

programs by IDFG and ODFW that provide some basis for concern (see Chapter 3 and

page 20/21, and Appendix 1). Principally, if IDFG released large numbers of sturgeon,

what was learned from that experience? There is no comment at all on these activities.

Further, Appendix 1 implies the development of a program similar to that suggested by

the NPT; was this program implemented and, if so, what has been learned? Finally,

Chapter 3 and Appendix 1 certainly seem to indicate another program involving cultured

sturgeon ... and one that could involve greater genetic risks than that proposed by the

NPT. Was the standard of care required of the NPT program applied to these State

programs and, if not, is there any basis for concern that one program may confound the

assessment of the other? There is frequent reference in the text to discussions between

co-managers, so we were uncertain whether there is any basis for concern, but it is not

commented on in the current text.

Question 1.10: Consistency of proposed project with Council policies, National Marine

Fisheries Service recovery plans, other fishery management plans, watershed plans and

activities

NPT Response: See Chapter 3, pages 13-15

ISRP Reviewer Comments: Covered

Question 1.11: Potential impact of other recovery activities on project outcome

NPT Response: Proposed activities are directed toward information collection.

ISRP Reviewer Comments: The NPT response is not appropriate, but a brief statement

as to the relevance or lack of relevance of the question would have sufficed. Their

comment is strictly correct for Stage 1 but ultimately their goal is to increase production

in these reservoirs. Given that this would occur over several years, it is possible that

alterations in dam management and flow, for salmon recovery, could impact this program
ISRP 2000-7 Sturgeon 3-Step

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Question 1.12: Production objectives, methods and strategies

NPT Response: Proposed activities are directed toward information collection.

ISRP Reviewer Comments: The NPT response interpreted the question too narrowly,

rather than broadening it to apply to this situation. Some production is involved in the

Management Plan in order to provide the sturgeon that will be planted and followed to

collect information. The objectives, methods and strategies are specified in Chapters 4

and 5. See additional comments below.

Question 1.13: Brood stock selection and acquisition strategies

NPT Response: See section 5.2.1, pages 19-20. Further acquisition strategies will be

covered in a final implementation plan.

ISRP Reviewer Comments: Covered, but see genetics section below.

Question 1.14: Rationale for the number and life-history stage of the fish to be stocked,

particularly as they relate to the carrying capacity of the target stream and potential impact

on other species

NPT Response: The proposed activities are designed to collect information to determine

appropriate stocking densities and provide initial information on the carrying capacity of

white sturgeon in Hells Canyon Reservoir.

ISRP Reviewer Comments: The rationale deserved more attention than it was given in

the Management Plan. For example, there is no discussion of the expected recovery rate

of the 50 marked sturgeon to be released or whether the expected number of recoveries

will be adequate to answer the questions related to feasibility. Consideration might have

been given to the length of time over which observations might be made of each group of

released marked fish. The sonic tags proposed for use have a limited and rather short

lifetime. Yet, the fish are long lived, and information on their rate of survival is important

to evaluating the potential for supporting a fishery. Thought should be give to using other

methods of following individuals over a number of years. Application of PIT tags is

mentioned in connection with the studies in 2000-2001, but no description is provided of

any recovery efforts. Given the timeframe allowed for Stage 1, it is unlikely that data on

stock density and/or carrying capacity will result. Statements should be more consistent

with programs described in the text.

The carrying capacity question could easily have been dealt with, as we suggested above.

The Plan dismisses the subject by interpreting the question in the narrowest light, rather

than considers it in a broader context that would encompass the other fishes in the

ecosystem.

Question 1.15: Production profiles and release strategies
ISRP 2000-7 Sturgeon 3-Step

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NPT Response: With the completion of proposed activities, information will be available

to determine production needs and appropriate release strategies

ISRP Reviewer Comments: Although the proposal is not a Hatchery based activity, it

does potentially involve release of cultured sturgeon or the capture and transfer of wild

juveniles. The source of wild juveniles is not described, nor are there comments on the

feasibility of this capture, transport, and release of juvenile sturgeon. If cultured fish are

used, what do we know about the stock, its effective population size, juvenile quality, etc.

(see below).

Question 1.16: Production policies and procedures

NPT Response: The proposed project will not be involved with fish production facilities.

ISRP Reviewer Comments: A goal of the program will be to provide the data upon

which to evaluate and develop a production policy and procedure. Fish production

facilities are required to support this proposed project. If the concept proves to be

feasible, larger facilities will no doubt be required. The fact that the facility is funded

outside of this project does not exempt it from considering an appropriate answer to this

question.

Question 1.17: Production management structure and process

NPT Response: The proposed project will not be involved with fish production facilities.

ISRP Reviewer Comments: The text does refer to development of the program in

consultation with co-managers. See also ISRP response to Question 1.16

Question 1.18: Related harvest plans

NPT Response: The proposed project does not include harvest objectives.

ISRP Reviewer Comments: The NPT response is not accurate. The question was

interpreted in the narrowest possible sense, and should have been discussed more fully.

Question 1.19: Constraints and uncertainties, including genetic and ecological risk

assessments and cumulative impacts

NPT Response: See Chapter 5, pages 19-32.

ISRP Reviewer Comments: This is the technical heart of the proposal. Comments

follow:

Production Assessments and Model:

The authors start with little to no information about the dynamics of sturgeon in these

reservoirs and develop a model (Excel spreadsheet) that seems to indicate the potential
ISRP 2000-7 Sturgeon 3-Step

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for the successful development of a small fishery (consistent with their goal of about 500

animals per year). Demonstrating potential is about as far as this assessment should go.

The proponents simply must collect some data before any credible dynamics model

should be developed further. In our opinion, certain assumptions clearly dictate the

outcomes in Tables 2 through 5. For example, the assumption of constant growth

accounts for increasing biomass with stocking numbers (weight harvested to weight

stocks constant in Table 4) and the conclusions about stocking densities (page 24). Is the

implication that there is no limit to carrying capacity in these systems? We find this

result to be highly doubtful given the turnover rates stated on page 9. Also, the

assumption of constant natural mortality is a very optimistic scenario to rely on. Why

were not alternative survival models examined, such as survival being inversely

proportional to weight? It is far more reasonable to assume larger natural mortality at

small size than to assume equal mortality rates over all ages.

Further, the modeling procedure is not documented for any evaluation. For example, how

was fishing mortality implemented in the model? Also, the model results in Table 5 seem

extremely insensitive to entrainment (over a wide range of values), what is the

explanation for this?

And finally, when the values of parameters are highly uncertain, it would be more

advisable to acknowledge this uncertainty and apply a range or distribution about “best

estimates”. To assist in reviewing the model or this assessment, we would need more

documentation about processes, equations, etc. Given the present lack of knowledge,

however, this assessment may place the expected outcome in a reasonable “ball park”, ...

but we would strongly recommend the development of a fully dynamic model (and

documentation) as the new information is being collected. A good model could greatly

facilitate your evaluations and target your research into “sensitive” data issues or

relationships.

Genetic analyses:

We have confirmed the relationships/analyses presented in section 5.2.3 but are

concerned about inferences drawn from Figures 6 and 7. It will seldom be true that Ne

equals the census population size of mature animals. Most commonly, Ne will be onequarter to one-third of the census reproductive population, ... and for longer-lived species

such as sturgeon the Ne could be even lower than these values. We therefore see little

value in this artificial calculation or the speculation about numbers from a family (bases

for Fig. 6 & 7). However, if the investigators do have an estimate of the effective

population size for the cultured population, then a more defensible calculation could be to

estimated Nc and the census population size for sturgeon below Hells Canyon dam.

Simulations could then be conducted to examine the numbers of spawners in the mixture,

using a range of Nw expressed as a portion of the census population size in the wild.

We are also concerned about the reference to numbers from one family and the stocking

of one family each year (page 30). We presume these statements are for ease of

assessment/discussion ... but these statements are totally contradictory to minimizing

genetic risk. Further, given that any mixing calculation such as Ryman and Laikre's must
ISRP 2000-7 Sturgeon 3-Step

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assume fully random mating of Nc with Nw ... why is it necessary to conduct

assessments at that level. The procedure may provide a “risk assessment” of sorts, but we

could never evaluate these results.

In the end, however, we must assess whether any of these analyses make any difference to

this proposed set of initial evaluations. We do not believe that they do (based on the

Stage 1 programs as presented), but there are some outstanding questions:

(a) The authors seem focused that Nc will be needed (as opposed to “wild stock

transfers”), but if juveniles were transported from another Snake population into Hells

Canyon and Oxbow reservoirs, why would any of this concern for Nc be necessary?

Why was this option for a source of fish not developed in the text?

(b) What are the estimates of Nc for the source populations and who is monitoring it over

generations in culture?

Such estimates of Nc would be important to determining whether there is any cause for

concern. For example if the Nc is very small, then there is need for concern. If Nc is large

(say 50-100), then there is much less need for concern, particularly for a few years of

evaluations.

If we do not know Nc, then this is really only a statistical game at this point. A few fish in

these initial tests are not a genetic risk to a large natural population ... and these

proponents could then collect the data necessary for numerical evaluations. As the

authors note (section 5.2.5), the essential issue in minimizing genetic risk is maintaining a

large genetically effective population size (Nc). But the ability to do this may have been

compromised early in the culture history of these fish. The investigation and monitoring

of Nc should be developed as an ongoing priority.

Critical Information Needs:

We generally agree with the three information needs identified on page 32, but given the

comments above also recommend adding the development of a modeling tool to learn

from their investigations, and the examination of the genetically effective population size

for the cultured stocks. We are also doubtful that literature values for production in

habitats will be applicable to this situation. We suggest a more fully developed

monitoring program will be needed to examine growth limits, survival by age and over

winter, and harvest rates. The programs could, for example, apply PIT tags to each

sturgeon introduced to the reservoir. Growth and survival could then be estimated for

each individual as opposed to sampling for population-at-age values. Entrainment could

also then be monitored directly by sampling in the natural populations.

There is an additional uncertainty that does not seem to have received any attention.

That is the ability to capture juveniles in other natural populations, transport them to

these reservoirs, and monitor their survival. If there are healthy populations above and

below these reservoirs, is this actually a possible alternative to cultured fish being
ISRP 2000-7 Sturgeon 3-Step

14

outplanted, or has this been precluded somehow? If this has simply been omitted from

this proposal for specific reasons, those reasons need to be stated explicitly. We

recommend the addition of a feasibility study on this type of capture and transport

program. We would expect some mortality associated with each activity but simply have

no idea how feasible such a program would really be. If we are actually limited to

cultured fish only, then more immediate attention should be directed to understanding the

effective population size of those fish and how sustainable that source of juveniles really

is.

Question 1.20: Monitoring and evaluation plans, including a genetics monitoring

program

NPT Response: See Chapter 5, pages 32-38.

ISRP Reviewer Comments: The monitoring and evaluation plans should be more fully

developed to make them useful for determining the feasibility of planting sturgeon to

support a fishery. We see no description of the type of fishery, its duration, extent, or of

any plan for maintaining catch records.

Another concern is the frequent reference to programs being conducted by other agencies.

This places the NPT program at some risk due to non-performance by the other agencies.

The Stage 1 proposal to develop programs in steps is endorsed but we must strongly

recommend that each step be reported for review.

Question 1.21: Conceptual design of the proposed production and monitoring facilities,

including an assessment of the availability and utility of existing facilities

NPT Response: The proposed project does not include the construction or maintenance

of facilities.

ISRP Reviewer Comments: Not applicable

Question 1.22: Cost estimates for various components, such as fish culture, facility

design and construction, monitoring and evaluation, and operation and maintenance.

NPT Response: See Chapter 5, pages 40-41. The proposed project does not include the

construction or maintenance of facilities.

ISRP Reviewer Comments: A concern with this budget is that it offers insufficient

manpower to conduct these Stage 1 programs. We are also concerned that these fish

would be released without a unique tag identifying each individual! Given the small

sample sizes involved and the critical nature of the M&E information required to

determine feasibility, we recommend that unique tags be used to identify each individual.
ISRP 2000-7 Sturgeon 3-Step

15

Questions Identified in the September 1997 Council Policy

Document for FY98 Project Funding

Question 2.1: Has the project been the subject of appropriate independent scientific

review in the past? If so, how has the project responded to the results of independent

review?

NPT Response: Previous ISRP review was based on the implementation of the project.

This master plan describes activities and plans to address some previous comments by the

ISRP. Other previous comments not covered in this plan will be addressed in a final

implementation plan and NEPA documents if the project is determined to be feasible.

ISRP Comments and Recommendation from FY2000 Review:

ProjectID: 20135

Consumptive Sturgeon Fishery-Hells Canyon And Oxbow Reservoirs

Nez Perce Tribe

Short Description: Provide fishery opportunities for white sturgeon in Oxbow and Hells

Canyon reservoirs to mitigate for loss of white sturgeon fisheries in Columbia and Snake

River basins due to hydropower development and operations.

CBFWA Funding Rec.: $250,000 Sponsor Request: $250,000

ISRP Response Evaluation:

Do not fund. This proposal was deemed not scientifically sound and received a do not

fund recommendation in the initial proposal review. The proposal was criticized for lack

of presentation of adequate scientific rationale, calculations, and data to justify the

proposed work. The reviewers noted that the proposal states hypotheses, but not methods

for testing them, and the work is required to include monitoring and evaluation, but this is

not in place.

The responses from CBFWA and from the NPT do not address these concerns adequately

from the viewpoint of scientific soundness. There is not scientific justification for

initiating a sturgeon stocking program in the absence of a management plan (which is

stated to be developed) and in the absence of a sound data collection plan designed to test

hypotheses about how well the stocking program is meeting its biological goals and

avoiding generating unwanted damaging side effects.

Whether or not this is called a research proposal (the responses state that the work is

mitigation, not research), it must generate research-type data in order to have

scientifically acceptable monitoring and evaluation. The usefulness of data to test

hypotheses depends on having hypotheses, or questions, specified in advance so that the

appropriate data set is defined before collection. Further, often, pre-treatment (i.e. before

fish stocking), initial (i.e., time of first fish stocking), and continuing data are needed to

understand the outcome of work such as this; the design and sampling need to be planned

before the work is begun.
ISRP 2000-7 Sturgeon 3-Step

16

Similarly, sound application of science dictates that unwanted side effects would be

scoped in advance of beginning the stocking program and that this information would be

subject to outside review by other scientists. It is not scientifically adequate to plan to

raise and address these later. It is not adequate to assert that so few sturgeon are present

that an introduction program cannot harm them; what about other fish species and what

about other elements of the food chain. The response that full augmentation will be

delayed misses this essential point. Past manipulations of lake and riverine food chains

make clear that this extended food web analysis must by considered and that food web

responses must be monitored.

The response refers to the management plan in future tense. It sounds like funding for the

development of a management plan was received previously, and the plan was supposed

to be developed with IDFG an ODFW during FY 1999. When will it be completed? Why

isn’t it referenced or central details presented for scientific review? Additionally, a master

plan and NEPA documents are scheduled to be completed and approved prior to the

initiation of fish stocking. Without these documents, it is impossible to complete a

comprehensive review of the project. A decision concerning further funding and

implementation of the program should be contingent on a favorable scientific review of

the management plan, master plan, and NEPA documents.

The respondents’ claim that public review in the FWP amendment project provides

justification to the work, however, this does not supply information about scientific

soundness.

ISRP Reviewer Comments: According to a February 4, 2000 letter from the Council’s

Mark Fritsch to NPT’s Silas Whitman, this project received funding to develop this

master plan and to address the ISRP comments. Funding was initiated in FY1999 and

carry forward from the FY99 was used to develop this plan.

See General Comments at the beginning of this review. The process of setting some

standard for deciding whether or not it is feasible to establish a fishery for sturgeon will

encourage thinking about what needs to be monitored. Once the needs are determined, a

plan can be developed for measuring those elements and deciding on the precision needed

in the measurement to allow reasonable evaluation of the feasibility.

Question 2.2: Have project sponsors demonstrated adequately at earlier stages that the

project is consistent with the Council’s policies on artificial/natural production in Section

7 (the specific concern of the Panel)? If not, can these points be demonstrated now?

NPT Response: This document is the initial planning document for the proposed project.

ISRP Reviewer Comments: The NPT response fails to address these concerns in the

Partial Step One Plan, however the issues will need to be addressed in the Final Step One

Plan.

Question 2.3: Is the final design of the project consistent with any master plan and

preliminary design?
ISRP 2000-7 Sturgeon 3-Step

17

NPT Response: The final implementation plan will be submitted if the project is

determined to be feasible.

ISRP Reviewer Comments: How will the decision be made on feasibility? Decision

criteria and decision steps need to be included in the Step One Plan.

Question 2.4: If not, do the changes raise any underlying scientific questions for further

review?

NPT Response: NA

ISRP Reviewer Comments: Not applicable at this point in the review process.

Question 2.5: Has information about the project or its purposes changed in such a way to

raise new scientific concerns?

NPT Response: This document is the initial planning document for the proposed project.

ISRP Reviewer Comments: The old concerns are still present.

Question 2.6: Has the underlying science or the way it is understood changed so as to

raise new scientific issues?

NPT Response: This document is the initial planning document for the proposed project.

ISRP Reviewer Comments: The answer is inappropriate. However, it is doubtful that the

underlying science has changed. That should have been the answer.

Question 2.7: How technically appropriate are the monitoring and evaluation elements

of the project?

NPT Response: The monitoring and evaluation elements in the document are designed to

assess entrainment potential and habitat use.

ISRP Reviewer Comments: The monitoring and evaluation elements need to be

rethought and further developed.

Question 2.8: Are there ways to obtain the same production benefits with facilities that

are lower in cost or less permanent, should monitoring and evaluation later indicate that

the effort be abandoned?

NPT Response: The proposed project does not include construction or maintenance of

facilities.

ISRP Reviewer Comments: A more complete answer might have been provided, but the

crux of the matter is that the question is not appropriate for the circumstances here.
ISRP 2000-7 Sturgeon 3-Step

18

Program Language Identified by the ISRP

Question 3.1: Measure 7.0D: Comprehensive environmental analysis assessing the

impacts on naturally produced salmon of hatchery produced anadromous fish.

Measure 7.0D of the Council’s 1994 Fish and Wildlife Program calls for a comprehensive

environmental analysis assessing the impacts on naturally produced salmon of hatchery

produced anadromous fish. The primary question we would like to have addressed with

regard to the project is, does the environmental assessment adequately deal with the

question of interactions of hatchery-produced salmonids and naturally spawning

salmonids and steelhead in the Columbia River Basin? If so, how? If not, what are the

potential or posited interactions and impacts?

NPT Response: Appropriate NEPA documentation has been submitted and approved for

the first year of studies covered in this document (Appendix 5). Currently the project is

submitting this document to initiate step 1 of the Three Step Process. A comprehensive

environmental analysis will be developed for step 2, after the completion of proposed

studies in the document.

ISRP Reviewer Comments: The measure cited is intended to apply to salmon and is not

appropriate for this project with sturgeon.

Question 3.2: Measure 7.1A: Evaluation of carrying capacity and limiting factors that

influence salmon survival.

Measure 7.1A of the Council’s 1994 Fish and Wildlife Program calls for a basinwide study on the ecology, carrying capacity, and limiting factors that influence

salmon survival. The primary question we would like to have addressed with

regard to this measure is:

Question 2a: How does the project intend to address the issue of carrying

capacity within the watershed(s) into which fish will be placed?

Question 2b: Do these fish originate from the most appropriate native stock?

Specifically, how will the artificial production which is proposed impact natural

production?

Question 2c: What are the impacts on mainstem and ocean harvest? How are

these impacts addressed?

NPT Response: Activities proposed in this document will aid in evaluating the carrying

capacity for white sturgeon in Hells Canyon Reservoir. Ongoing studies by Idaho Power

in the project area will also aid the evaluating carrying capacity.

ISRP Reviewer Comments: OK. Idaho Power has been studying sturgeon in the Hells

Canyon dams for some time. Results of their studies and conclusions should be presented

more fully in the Final Step One Plan. Similarly, Idaho Fish and Game has planted

upward of 5,000 sturgeon in the mid-Snake since 1989. A summary of these activities
ISRP 2000-7 Sturgeon 3-Step

19

should be presented in the Partial Step One Plan along with inferences that bear on the

proposed project.

Question 3.3: Measure 7.1C: Collection of population status, life history and other data

on wild and naturally spawning populations of salmon and steelhead.

Measure 7.1C calls for the collection of population status, life history and other

data on wild and naturally spawning populations of salmon and steelhead. The

primary question we would like to have addressed with regard to this measure,

especially with regard to listed species is:

Question 3a: What biological baseline information on naturally spawning

populations of salmon and steelhead have been collected, and what high priority

populations and “provisional population units” have been identified?

Question 3b: Does this baseline information include a profile on the genetic and

morphological characteristics of wild and naturally spawning populations? What

characteristics are to be maintained by management actions?

Question 3c: What are the limiting factors for wild and naturally spawning

populations?

Question 3d: What is the natural carrying capacity for the identified

populations?

Question 3e: What monitoring of identified populations of salmon and steelhead

is identified as part of the project?

Question 3f: Are these efforts being coordinated with NMFS? If so, how?

NPT Response: Idaho Power has collected extensive information on the status and life

history information on white sturgeon throughout the Snake River as part of their FERC

re-licensing efforts. Results and conclusions of these studies will be publicly available in

2002.

ISRP Reviewer Comments: OK, except that it should have been possible to make some

general statements.

Question 3.4: Measure 7.1F: Systemwide and cumulative impacts of existing and

proposed artificial production projects on the ecology, genetics and other important

characteristics of the Columbia River Basin anadromous and resident fish.

Measure 7.1F calls for a study to address the system wide and cumulative impacts

of existing and proposed artificial production activities on the ecology, genetics

and other important characteristics of Columbia River Basin anadromous and

resident fish. This study is to be coordinated with the genetic impact assessment

of Columbia River Basin hatcheries called for in measure 7.2A.2 of the Council’s
ISRP 2000-7 Sturgeon 3-Step

20

program. How does the project's environmental assessment address the direct,

indirect and cumulative effects of the proposed production activities on

anadromous and resident fish? Have those effects commonly associated with

cumulative hatchery releases -- density dependent, competition, predation,

disease transmission and genetic effects on other fish in the mainstem and oceanic

environments been addressed? If so how? Have the genetic effects of the project

on fish within and outside the Columbia River Basin been specifically addressed?

NPT Response: Currently the project is submitting this document to initiate step

1 of the Three Step Process. A comprehensive environmental analysis will be

developed for step 2, after the completion of proposed studies in the document.

ISRP Reviewer Comments: Previously discussed in earlier responses.

Policies of the Artificial Production Review, Report and

Recommendations (Document 99-15)

4.1. The manner of use and the value of artificial production must be considered in the

context of the environment in which it will be used.

NPT Response: The use of artificial production proposed in this document is for the

collection of critical information and is limited to a total of 550 fish. This represents a

stocking density of 0.56 fish/ha. White sturgeon are indigenous to the project area.

Currently the white sturgeon population in the project area is severely depressed with no

known natural reproduction occurring.

ISRP Reviewer Comments: While the portion of Phase 1 described in the NPT Plan

calls for 550 fish over the period 2000-2002, it is the long-term effect that ought to be

considered in this response. The response might have considered two outcomes, one if the

decision is the concept is determined to be feasible and the other if not.

4.2. Artificial production must be implemented within an experimental, adaptive

management design that includes an aggressive program to evaluate benefits and address

scientific uncertainties.

NPT Response: The primary purpose for use of artificial production proposed in this

document is to address critical uncertainties which currently limits the development of a

final implementation plan and appropriate NEPA documents.

ISRP Reviewer Comments: OK.

4.3. Hatcheries must be operated in a manner that recognizes that they exist within

ecological systems whose behavior is constrained by larger-scale basin, regional and

global factors.
ISRP 2000-7 Sturgeon 3-Step

21

NPT Response: The proposed project does not include the construction or maintenance

of fish culture facilities.

ISRP Reviewer Comments: The question does not apply.

4.4. A diversity of life history types and species needs to be maintained in order to

sustain a system of populations in the face of environmental variation.

NPT Response: The use of artificial production proposed in this document is for the

collection of critical information and is limited to a total of 550 fish. This represents a

stocking density of 0.56 fish/ha. White sturgeon are indigenous to the project area.

Currently the white sturgeon population in the project area is severely depressed with no

known natural reproduction occurring.

ISRP Reviewer Comments: OK

4.5. Naturally selected populations should provide the model for successful artificially

reared populations, in regard to population structure, mating protocol, behavior, growth,

morphology, nutrient cycling, and other biological characteristics.

NPT Response: The use of artificial production proposed in this document is for the

collection of critical information and is limited to a total of 550 fish. This represents a

stocking density of 0.56 fish/ha. White sturgeon are indigenous to the project area.

Currently the white sturgeon population in the project area is severely depressed with no

known natural reproduction occurring.

ISRP Reviewer Comments: OK

4.6. The entities authorizing or managing an artificial production facility or program

should explicitly identify whether the artificial propagation product is intended for the

purpose of augmentation, mitigation, restoration, preservation, research, or some

combination of those purposes for each population of fish addressed.

NPT Response: The proposed activities described in this document rely on 550 sturgeon

from artificial production to assess critical uncertainties.

ISRP Reviewer Comments: The end product of this artificial production project is

intended for harvest augmentation.

4.7. Decisions on the use of the artificial production tool need to be made in the

context of deciding on fish and wildlife goals, objectives and strategies at the subbasin

and province levels.

NPT Response: The use of artificial production proposed in this document is for the

collection of critical information and is limited to a total of 550 fish. This represents a

stocking density of 0.56 fish/ha. Over 3,500 hatchery sturgeon have previously been
ISRP 2000-7 Sturgeon 3-Step

22

stocked through the mid-Snake River by IDFG as part of their sturgeon management

activities.

ISRP Reviewer Comments: It would be short sighted to view this project in isolation

from its primary goal, which is to use artificial production to support a fishery. The NPT

response is part of the picture. The Final Step One Plan needs to summarize the results of

the IDFG sturgeon stocking program more thoroughly than did the Partial Step One Plan

we reviewed. What was learned through that stocking effort and how does it apply to this

proposed project?

4.8. Appropriate risk management needs to be maintained in using the tool of artificial

propagation.

NPT Response: The primary purpose of activities proposed in this document is to collect

information on the entrainment potential and entrainment survival of stocked sturgeon in

Hells Canyon Reservoir. This information is critical for a risk assessment of the project.

From the risk assessment appropriate risk management strategies can be developed.

ISRP Reviewer Comments: The survival study is probably unnecessary, since the risks

associated with artificial production have been dealt with by the appropriate choice of a

donor stock.

4.9. Production for harvest is a legitimate management objective of artificial

production, but to minimize adverse impacts on natural populations associated with

harvest management of artificially produced populations, harvest rates and practices must

be dictated by the requirements to sustain naturally spawning populations.

NPT Response: The proposed activities described in this document rely on 550 sturgeon

from artificial production to assess critical uncertainties not to provide additional harvest

opportunities.

ISRP Reviewer Comments: Again, the long-term goal should be considered. Because

naturally spawning populations do not occur in the area of interest, there is no problem

associated with harvest rates such as would occur in a mixed-stock fishery.

4.10. Federal and other legal mandates and obligations for fish protection, mitigation,

and enhancement must be fully addressed.

NPT Response: Appropriate NEPA documentation (Appendix 5) and state permits

(Appendix 6) have been obtained for the first year of proposed activities described in this

document.

ISRP Reviewer Comments: OK

________________________________________
ISRP 2000-7 Sturgeon 3-Step

23

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