Based on the results-to-date from kelt reconditioning efforts, the ISRP questions whether this recovery strategy is efficacious and whether the fundamental assumptions of a benefit from kelt reconditioning are adequately reasoned. In any case, the experiments outlined in this proposal are insufficient to generally address the primary uncertainties underlying kelt reconditioning as a restoration tool, or specifically to provide a benefit in the proposed setting. Although kelt reconditioning is an inherently attractive proposition even to the reviewers, it may be time to reevaluate the effort being dedicated to this strategy. If there is empirical evidence in support of kelt reconditioning as a restoration tool that was not presented in this proposal it should be brought to the attention of the ISRP in a revision.

The proposal is to add an unspecified number of acclimation ponds for long-term rearing (but not full-term rearing) of spring Chinook and summer steelhead in the Wenatchee and Methow subbasins. One objective of the proposal is to develop a plan for the addition of these ponds (facilities). The proposal narrative was sufficient to understand the intent of the sponsor, but not enough detail was provided to fully appraise any likely benefits to fish and wildlife. Since the first objective is to produce a plan, it should probably be a Master Plan, although the scale is such it would not necessarily require the full implementation of a three-step process. Any plan should: 1. fully document the current status of the resource (spring Chinook and summer steelhead) in the two subbasins; 2. establish clear improvements to the VSP parameters for these focal species as a consequence of using long-term acclimation ponds; 3. craft a monitoring design to evaluate any success (especially since the sponsor acknowledges not much is known about whether this strategy will improve the status of the species); and 4. integrate the principles from the Council’s 2009 program, the HSRG findings, the Upper Columbia River Chinook and Steelhead recovery plan, the 2008 BiOp, and impending hatchery biological opinions. The qualifications are covered by the four points above. The spring Chinook and steelhead ESUs are endangered (or threatened) so any artificial production needs to be carefully directed at improving the status of these species, not harvest, to be consistent with the Upper Columbia recovery plan and the Council’s Fish and Wildlife Program. Any program that has the purpose of putting hatchery fish on the natural spawning grounds needs to be fully consistent with best management practices that are reflected in the HSRG guidelines for PNI, pHOS, pNOB, and limitations of the number of generations of supplementation reflected in the Council’s 2009 Fish and Wildlife Program. Without a more complete analysis, it is not possible to determine whether the use of the long-term acclimation strategy will be an improvement over the status quo, detrimental, or neutral. The hope appears to be that the long-term acclimation will distribute spawning hatchery fish broadly across the subbasins. However, the HSRG report states that spring Chinook released from the acclimation ponds in the Chiwawa River in the Wenatchee subbasin are found straying all over within the subbasin. So it is not clear how the additional ponds will add to the spawning distribution. Without knowing where the current hatchery steelhead spawn, it is not possible to know whether there are reaches that have suitable habitat but are underseeded. At this time the PNI for each of these programs is very small, and there is a need to progress toward larger proportions of natural fish on the spawning grounds and in any artificial production. So it is not clear that there is a need or desire to substantially expand the natural spawning by hatchery-origin adults.

Our data will be electronically availbable when data becomes available.  We have yet to recondition a single kelt as we continue to work out major kelt reconditioning facility issues.  Presently, we are looking at finally building a facilty next summer (2011) with initial collections beginning in spring, 2012.

The sponsors responded sufficiently to the queries posed in the ISRP preliminary review of the project. Most of the questions are dealt with in greater detail in the ISRP Step One Review. For completeness, brief ISRP responses to this follow-up are provided here.

The sponsors responded to the ISRP recommendation for Fundable-in-part, for completing the Three-Step process, by identifying that funding for 07/09 was for continued feasibility level fish culture operations and completing the Three-Step process. No funds for construction or expanded fish culture operations are in the FY 07/09 budget. The ISRP thanks the sponsors for this clarification. The final funding level is a matter for Council and BPA, but the ISRP notes that the ISRP's preliminary Fundable in Part recommendation in fact includes all the activities that they are requesting support for.

The ISRP recommended in the preliminary proposal review, and in the Master Plan Step One Review that sponsors alter the primary biological objective from "biologically sustainable" to "naturally self-sustaining population." The sponsors provide an adequate summary of the history of the development of the primary objective and use of the term "biologically sustainable." They provide their rationale for using the term:

"Our use of "biologically sustainable" does not make any assumptions about whether future hatchery supplementation will be required. Very early versions of the Master Plan included the term "self-sustaining" in the vision statement. The term was eliminated after much consideration by the Mid-Columbia Coho Technical Work Group because no other species of anadromous salmonid within the upper Columbia currently is self-sustaining. All other species of salmon and steelhead receive supplementation of some kind. Inclusion of the term "self-sustaining" may unintentionally predispose the project for failure in terms of whether or not a realistic vision is achieved."

This rationale is exactly the reason the ISRP continues to recommend changing "biologically sustainable" to "naturally self-sustaining." The ISRP recognized that biologically sustainable could be interpreted to mean "supported indefinitely by hatchery-origin adults." In the present case, however, the project proponents have clearly designed a program that implies it is going to proceed to entirely natural production. It is the hedges that appear occasionally in the Master Plan and in this reply that back away from the schedule to attain self-sustaining status that is of concern to the ISRP. It is worth attempting to reintroduce coho and achieve self-sustaining status. If that is the goal, a production and habitat restoration plan needs to be designed to accomplish that task. If it does not work, then the program can be altered at the end of the experimental phase. This might be a harvest augmentation program, as the sponsors identify in the Master Plan, or it might be some other integrated hatchery program.

The ISRP emphasizes that integrated hatchery programs that include a goal of keeping the artificial and natural components genetically similar, and adapted to the natural environment, require the natural population to be self-sustaining, require the proportion of natural-origin adults in the hatchery broodstock to exceed the proportion of hatchery-origin adults in the wild. Finally, the total number of salmon used for broodstock (NOR plus HOR) cannot exceed the natural-origin escapement that spawns in streams.

In response to the ISRP comment that the project was ambitious and it did not appear that the sponsors had given themselves much time to address unanticipated challenges, sponsors provided a verbatim copy of section 4.3.5 Contingency Plans and Decision Processes from the Master Plan. The ISRP acknowledges this contingency plan. In the ISRP Step One Review we do not explicitly address the contingency plan, but do suggest when addressing the consistency of the Master Plan with Council Artificial Production principles, that the ISRP recommends adhering to a rigid schedule of transition through the broodstock development and natural production phases of the reintroduction. The contingency plan is appropriate in that it poses questions of whether the difficulties encountered can be surmounted, but it is of concern to the ISRP that it extends the phases or exits to a harvest augmentation program fairly early in the reintroduction effort if not successful at achieving that stage's goals. In our more lengthy step review we recommend establishing a schedule of pHOS, and pNOB, and following it strictly through the generations of this experimental reintroduction. If the reintroduction is ultimately determined to be infeasible, options for a harvest augmentation program, whether integrated or segregated will not be lost. However, if this reintroduction experiment focuses on release numbers and relaxes the fish culture practices to maintain high production, then the reintroduction itself could be compromised.

The reintroduction could be compromised by the focus on a rearing and release schedule rather than on a broodstock mating protocol for pHOS and pNOB because it is this protocol that will provide the "selection" that will lead to the hoped for adaptation of the lower river stock to the mid-Columbia tributaries. In the broodstock development phase two, releasing fish in upper areas of the watershed and then use the returns of these fish for broodstock is suppose to provide the opportunity to select parents that have exhibited the stamina and other behaviors to migrate to the release sites. If these fish are spawned with individuals from families that have not exhibited those capabilities, and these fish predominate in the pool of parents, you could actually be selecting against the genotypes that you hope to increase in proportion in the population. The same rationale holds for the natural production initiation and support phases.

The sponsors indicate that they will use standard metrics to evaluate the productivity of their program. The ISRP recommended that adult replacement rate would be based on female to female, and certainly not include jacks. The ISRP points out that even the female-to-female replacement rate may not be sufficient under all circumstances, if the age structure of the female offspring differ across generations or between eggs incubated in the streams versus those incubated and then reared in a hatchery. Under these circumstances the appropriate measure would be each generation's egg production. This requires estimating the fecundity of females of different sizes and ages each generation, and estimating the proportions of females in body size (and age) categories. The data to estimate the egg production should be available since fish will be collected for hatchery spawning and fish released for natural spawning will be enumerated at weirs. Sponsors indicate that the data that is collected is sufficient to calculate the female-to-female metric. The ISRP is satisfied that these metrics can be evaluated.

Finally, the sponsors clarify the plan to construct acclimation ponds. In general the ISRP was encouraged that expanding hatchery facilities within the subbasins to produce smolts was not necessary. The ISRP thanks the sponsors for clarifying the construction schedule. The ISRP remains concerned about the environmental conditions that may develop from feed and feces that could accumulate in semi-natural acclimation ponds that are not as easily cleaned as traditional raceways. Additional discussion of the specifics of this type of fish culture issue would improve the Master Plan.

Fundable (qualified) with the qualification being that the sponsors revise the Master Plan before proceeding to Step Two, and that they fully address the ISRP concerns about clearly establishing unambiguous biological objectives.