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Oregon Anglers represents sports fishermen on this major undertaking with 2 board members. Bill Sanderson, of the N. Santiam River Guides and the Salem Steelheaders, and Dennis Richey, executive director of OA both sit on the committee. Bruce Harpole of the Oregon Fishing Club is Richey's alternate, and Alan Girod of Mill City is Bill's. The stakeholder group includes representatives from agriculture, commerce, conservation, forestry, local government, tribal, utilities, watershed councils, and of course fishing interests. The meetings have been on hold for about 9 months because of changes in personnel at ODFW. I spoke with one of the biologists assigned to take over the plan, and he said that the department was getting geared up to resume meetings. (Posted May 5, '08) At the Tuesday, Sept. 18, 2007 meeting a DRAFT copy of the first 7 chapters was presented and partially explained to the group. Written comments were welcome from the public in addition to the task force members. The document is lengthy and formidable. It can be viewed at http://www.dfw.state.or.us/fish/esa/upper-willamette/index.asp. Oregon Anglers written comments are below: Sport Fishing Comments on the Draft of the Oregon ESA Recovery Plan For the Upper Willamette River Domain October 25, 2007 I will address primarily limiting factors and management actions. The following comments are drawn on input from several stakeholder groups very familiar with the Willamette Basin: the Mid-Willamette Valley Anglers, the Salem Steelheaders, the Emerald Empire Steelheaders, and the North Santiam River Guides, plus several individual guides and fishermen. Limiting Factor: Predation and competition of hatchery fish upon wild fish. Proposed Management Action: Release hatchery smolts at the biologically optimum time. Recent studies by U.S. Fish and Wildlife biologists showed very little evidence of competition between hatchery and wild steelhead smolts.[1] Even though the hatchery and wild steelhead varied both physiologically and morphologically, with the hatchery fish being larger, no differences were found in wild fish habitat before and after the release of the hatchery smolt. Wild and hatchery fish were seldom found close together, and competition for habitat was not observed. If the habitat were limited, a prior residence advantage must have allowed wild fish to defeat hatchery fish during competitions for optimal habitat. Hatchery fish were found under surface turbulence, and wild fish were located in deeper water with larger substrate and more cover. Furthermore, hatchery smolts that were released too early, before “smoltification” or with a low gill Na+, K+ ATPose level, stayed in the release stream longer.[2] Those who had a higher gill Na+, K+ ATPose level and were released after the mean date of April 21st migrated immediately causing little interaction, and were also found to experience a lower level of predation by the Arctic Terns and Double Crested Cormorants in the Columbia estuary. Therefore, if hatchery steelhead smolt (and most likely Chinook also) were allowed to smoltify, or go through their pre-salt water adaptations before release, not only would they compete with and prey upon wild fish less, but would fall victim to avian predation at a much lower level. I understand that this is not currently the primary consideration in hatchery release dates. [i] Comparisons between hatchery and wild steelhead trout (Oncorhynchus mykiss) smolts: physiology and habitat use. Megan S. Hill, Gayle B. Zydlewski, and William L. Gale. Can. J. Aquat. Sci. 63: 1627-1638 (2006) [1][1] Relationship between smolt gill Na+, K+ ATPose activity and migration timing to avian predation risk of steelhead trout (Oncorhynchus mykiss) in a large estuary. Benjamin M. Kennedy, William M. Gale, and Kenneth G. Ostrand. Can. J. Fish. Aquat. Sci. 64: 1506-1516 (2007). Limiting Factor: Loss of wetland and side channel Habitat. Proposed Management Action: Create small side channel streams as has been successfully done on the Clackamas River. Previous side channels have been blocked off along many of the rivers in the Valley. Identifying and working cooperatively with landowners is one of the key factors in making this successful. Fishing clubs and STEP groups are a resource to utilize where watershed groups are not an option. Limiting Factor: Smolt migration mortality. Proposed Management Action: Examine some of the smaller, but deadly, man made obstacles and make the minor adjustments that may make a significant difference in smolt mortality. The diversion for the Salem water intake is a good example of an innocuous looking downstream passage obstacle. However the water spills over the lip down upon a flat concrete surface, which causes considerable immediate and delayed mortality of Steelhead and Chinook smolts. Spillways that direct the flow outward would reduce this mortality. Limiting Factor: Smolt mortality passing through hydropower turbines. Proposed Management Action: Smolts are not “chopped up” going through the turbine blades as many believe, but are exposed to the “bends” going from 2 gravities of pressure to 0 gravities, due to inefficient blade cavitation. Turbine blades can be redesigned to more efficiently produce more power and substantially decrease smolt mortality. This was proposed 15 years ago by a biologist from a local PUD, but was condemned by the FISHERIES DELEGATION because it could cut off some of the funding that they wanted to do habitat restoration. It is time to promote this course of action. Limiting Factor: Water levels for smolt downstream migration spills are high, causing redds created at these high levels to be dewatered when spill is cut back. Proposed Management Action: Experimentation should be allowed to save some spill water and thus moderate stream levels so redds can be saved until fry can emerge. There is only so much water. We can conserve, but can’t invent more. So we need to look realistically at flow demands. Where lack of current in the thalweg of impoundments cause migrating smolts to get lost or be delayed, flow velocity enhancement should be explored. The use of underwater venturies or eductors can be placed strategically to create a current for migrants to follow.[3] Limiting Factor: Summer Steelhead affecting spawning of wild Winter Steelhead by interbreeding. Proposed Management Action: Further objective studies are needed to verify alleged negative effects. The study that is the basis of this claim is from the Clackamas River by ODFW’s Katherine Kostow. She documented a decline in wild Winter Steelhead populations when hatchery Summer Steelhead were introduced and some strayed onto the spawning grounds. Then when hatchery stocks were removed at dam overpasses and not allowed access upriver the population of the winter stocks increased. In fact there is a very small overlap of winter vs. summer stocks in spawn time. But the main factor calling for a better study is that she did not take into consideration that there were very poor ocean conditions when the summers were introduced, and all stocks were suffering. And conversely, when the summers were kept off the spawning grounds, there was a huge upswing in all basin stocks due to the very good ocean conditions. Limiting Factor: Harvest management/ a failing policy. Many streams were closed to sports fishing to give salmon and steelhead a chance to spawn. Also the stocking of trout and hatchery salmonoids was terminated in many streams. The trouble is that the 2 actions were not coordinated. I will use the Little North Fork of the Santiam River as an example. This small stream runs from Opal Lake over 20 miles to the North Santiam, about 1 mile upstream from the Mehama / Lyons Bridge. It was home to a small run of wild Spring Chinook and a decent wild run of early Winter Steelhead. All trout and hatchery steelhead stocking was ceased. Today fishing is allowed on the steelhead even though there is no retention allowed. Many locals fish for and retain these wild fish, particularly on private property. There are no trout in the river during the summer, but fishermen are constantly pursuing trout, and killing many juvenile steelhead and salmon. The mortality rate has become so severe that very few juvenile are spotted in the lower river anymore. Proposed Management Action: Reduce mortality where there is no retention of fish possible. We propose that the river be closed to all fishing to see if that helps bring back the wild stocks. It may be too late. After 8 years we propose that if stocks have not rebounded, trout and hatchery steelhead be once again stocked and fishing be reopened. Or if there are too few wild returnees to seed a comeback, start planting it again now. This is but one example of doing something half-assed without following up on the consequences. ______________________________________________________________________________ The following articles are done by Bruce Harpole, President and founder of the Oregon Fishing Club.
"I do a monthly article for the Salem Business Journal. The attached article is about Salmon Over-harvest and will be in their May issue. When researching the article we found some interesting numbers I thought you might like to see."
Bruce Salmon Over-harvest? Fishing Matters By Bruce Harpole Virtually all commercially harvested fish stocks worldwide have been over-harvested. A few examples are the Grand Banks, the Gulf of Mexico, and the North Sea. Historically, the primary response to declining numbers of fish was to fish for the survivors more intensively. This is certainly true for salmon in the Pacific Northwest. Only in the last decade has harvest been reduced for conservation purposes. If you think the over-harvest of Pacific Northwest salmon is a recent occurrence, guess again. The first salmon cannery opened on the Columbia River in 1867, and by 1883, 55 canneries were harvesting 43 million pounds of Chinook annually. The first conference on the alarming decline in Columbia River salmon was held in 1873, 60 years before the first dam. The first salmon hatchery on the Columbia was built in 1887, 45 years before the first dam. The harvest level of Columbia and Snake River salmon had declined more than 50% by the time the first dam was built in 1933. The reality is, salmon numbers have been steadily declining for 150 years, and now runs are less then 5% of historical levels in the states of CA, OR, WA and ID. In a paper titled “Salmon Decline Creates Nutrient Deficit in Northwest Streams” Ted Gresh, Jim Lichatowich and Peter Schoonmaker stated “the historical level of salmon production for the Northeast Pacific Ocean ecosystem was 228 million—351 million fish annually, with the following distribution: 56 percent- 65 percent of fish returned to Alaska; 19 percent-26 percent returned to British Columbia; and 15 percent- 16 percent returned to California, Oregon, Washington, and Idaho. Today, 142 million—287 million fish are produced and 81 percent-90 percent return to Alaskan rivers; 8 percent- 17 percent return to British Columbia rivers; and 1 percent—1.5 percent to rivers in California, Oregon, Washington, and Idaho.” Why does Alaska get such large salmon runs when a century ago the great Bristol Bay salmon were virtually extinct? The only difference for these runs has been to eliminate over-fishing. In Alaska all fishing is managed on an “escapement basis”, meaning they only allow commercial fishing to begin after a certain number of fish have entered the rivers to spawn. Meeting this “escapement goal” prior to commercial fishing is a hard constraint to follow. With this system fishing levels become the dependent variable, not the numbers of in-river spawning fish. In contrast, Oregon, Washington and California first allow salmon fishing to occur, and then hope enough fish return to the rivers to repopulate the population. This policy does not work. Fish harvest should only be allowed after escapement goals are met. Some argue it is Alaska’s pristine habitat that is solely responsible for the health of their salmon stocks. But some Alaska rivers with healthy stocks are far from pristine; while several rivers in Washington State that remain nearly pristine have current escapement levels at a fraction of historic levels. So why pick on commercial fishermen and not sport anglers? Good question, especially when sport anglers have been part of the over-harvest problem for decades. The answer is in the harvest method. Sport anglers can selectively harvest by using hook and line, whereas most commercial fishing methods are non-selective killers. In today’s world, where abundant fin-clipped hatchery produced salmon swim side-by-side in the ocean with endangered naturally spawning salmon, the ability to selectively harvest fish is critical. The continued non-selective intercept fishing of mixed stocks (hatchery fish, healthy naturally spawning fish, and Endangered Species Act-listed fish) will only result in the continued decline of the weakest stocks, the one’s we are obliged to protect. The only thing that can save these weak stocks of salmon is adequate escapement. Some argue, “What about all the other problems salmon face, its not just over-harvest”? And they’re right. Salmon do face many other problems; water quality issues, dams blocking upriver spawning grounds, irrigation interests reducing in-stream flows, counterproductive hatchery practices, seals, fish-eating birds, and stupid humans. But, these things only come into play once the fish come back to the rivers. These naturally spawning fish need to be allowed back to their natal waters in sufficient numbers for them to have any chance to recover . Fin-clipping of hatchery fish provides one means to change recreational and commercial harvest methods to allow more ESA-listed naturally spawning salmon to escape, while also allowing for a higher harvest rate on hatchery salmon. It won’t work everywhere. It would work in many, many more places than it is currently being used. One big source of over-harvest is the Canadian commercial fishermen. It is estimated that 69% of British Columbia commercially caught salmon are returning to Oregon, Washington and California. A full 70% of those are ESA listed stocks. Fortunately, the United States is renegotiating with Canada on the Chinook portion of the Pacific Salmon Treaty, and a new federal policy is to appear by the end of 2006. Gary Loomis had a good suggestion on how to solve the non-selective harvest by commerical fishermen. He suggests the government subsidize the commerical fishing industry for a period of three years. During those years commercial fishermen and others must come up with a true selective way to harvest salmon, without nets and without impact to naturally spawning fish. By the end of year three, if there is no program for selective harvest in place, then the government can help train the commercial fishermen for a new occupation. Before you get all weepy-eyed for the poor commercial fishermen, know that their industry will not collapse if they can not kill salmon. In Oregon, only 7% of the industry’s revenue comes from salmon, the bulk of their revenue is from Crab, Whitting and bottom fish. We must stop the non-selective commercial harvest of our dwindling salmon stocks and establish generous basin by basin escapement numbers. To supply fish for the public to eat, the Indian Tribes are more than willing to harvest their allotted salmon, as agreed by treaty. The harvest would be more selective and escapement goals would be more adequately met. Over 2 million sport anglers from Califorina to the Puget Sound would have twice as many salmon available to selectively harvest. Sport fishing would boom and so would the small communities and businesses associated with sport fishing. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ Dept. Fish & Wildlife; is it worth the money? Fishing Mattersby Bruce Harpole
Are you, the taxpayer, getting your money’s worth from the Oregon Department of Fish and Wildlife? To answer this question we must first examine the overall State budget. The State of Oregon has an overall two year projected General Fund and Lottery dollars budget for 2005-07 of just under $12 billion dollars. About $10 billion of that money comes from personal income taxes (that’s us). The other $2 billion comes from lottery, corporate income tax, insurance, tobacco tax, and other sources. The State of Oregon’s two year proposed expenditures for 2005-07 are divided as follows in descending order; 1. Education $6.5 billion (55%) 2. Human Services $2.5 billion (21%) 3. Public Safety/Judicial $2 billion (17%) 4. Other $460 million (4%) 5. Natural Resources $260 million (2%) 6. Economic & Community Development (1%) The Dept. of Fish & Wildlife is one of the Natural Resources agencies. The $260 million spent on Natural Resources is divided as follows, 1. Parks and Recreation Dept. $72.3 million (35%) 2. Oregon Watershed Enhancement Board $43.4 million (17%) 3. State Forestry Dept. $37 million (14%) 4. Dept. of Environmental Quality $27.5 million (11%) 5. Dept. of Agriculture $24.5 million (9%) 6. Water Resources Dept. $19.5 million (8%) 7. Dept. of Fish and Wildlife $18.8 million (7%) 8. – 14. Another seven Natural Resources Depts. $6.8 million (3%) The Fish & Wildlife Dept. has a two-year budget of $228 million and funds come from the following sources: 1. Other Funds $112 million (49%) (Other funds are composed mostly of hunter/angler license and tag fees) 2. Federal Funds $97 million (43%) 3. State General Fund & Lottery $18.8 million (8.3%) So our research has shown us that as a percentage of the $12 billion General Fund/Lottery budget, ODFWs’ cut of the pie is only .0016% or 16 cents out of every $100 of General Fund money. ODFW also receives only 8.3% of their budget from State funds. The majority of the ODFW biennial budget is funded through means other than the state’s general or lottery funds. Now let’s examine what ODFW does with it’s money. All the Natural Resource agencies are charged with the responsibility of “managing Oregon’s natural resources for present and future generations while supporting a sound and sustainable economy”. All of these agencies have a stake in Oregon’s fish and wildlife, but obviously the agency with the most control is the Dept. of Fish and Wildlife. ODFW spends its money in the following fashion: 1. Fish Division $123 million (56%) (natural production, propagation, marine, interjurisdictional fisheries) 2. Wildlife Division $41 million (19%) (game hunting, wildlife habitat, wildlife diversity) 3. Administration $29 million (13%) (human resources, information, education, administrative services) 4. Oregon State Police $12 million (5%) (enforce game laws to protect natural resources) 5. Capital Improvement $10 million (4%) (new research hatchery, new headquarters, repair facilities) 6. Habitat Division $6 million (3%) (manage water and land resources) In business terms, ODFW’s product is fishing, hunting and wildlife viewing. Hunters, anglers and wildlife viewers annually spend approximately $2.1 billion in the State of Oregon, according to 2001 numbers. The $2.1 billion of economic activity from fishing and hunting generates an estimated $86 million annually in income taxes for the State. If we subtract $9.4 million (1/2 the ODFW bi-annually funding from the State) the State comes out ahead by nearly $77 million. That’s an 819% annual return on investment. Don’t you wish your investments did that well? So why did our Governor reduce the amount invested in ODFW by $5.5 million from the 2003-05 budget to 2005-07. Darn good question. If State government was run like the private sector our governor would be pumping investment capital into one of his best producing products, fishing, hunting and wildlife viewing. Eventually, they would run into a diminishing return, but there is obvious room for growth in the fishing and hunting “product line”. As it now stands, a tightening of State funds is constricting ODFW’s output. Also, a growing disenchantment among anglers and hunters, caused in part by a reduction in the availability of harvestable fish and game, is leading to fewer tags and licenses being sold thus weakening ODFW’s ability to self fund. If the State would reinvest just a small portion what fishing and hunting generates, we would have a prosperous agency that would create even more revenue for the State. A $2.1 billion industry with an 819% ROI is being squeezed out by an unappreciative State. For a comparison let us look at ODFW and the Oregon Parks and Recreation Department. Both receive about 37-38% of their funds from public fees. Both generate similar levels of economic activity. The great disparity is in the level of investment by the state. The Parks & Rec. Dept. receives nearly four times the amount of general fund/lottery revenues. The State is expanding it’s funding in parks while reducing it in fish and wildlife. The answer to our initial question is an obvious YES. In fact, fish and wildlife are not only worth the money, they are moneymakers for the State of Oregon. You can contact Bruce Harpole at the Oregon Fishing Club, 541-967-8301, ofc@ofc.org. OFC offers 43 private fishing locations in NW Oregon. --------------------------------------------------------------------------------------------------------------------------------------------------------
Ron Richey with 15 and 20 pound hatchery coho. --------------------------------------------------------------------------------------------------------------------------------------------------------------- Oregon Anglers strongly endorses the Oregon Department of Fish and Wildlife's development of the "Native Fish Conservation Policy and Guidelines" (December 14, 2001 draft): "Based on state statute, native fish are wild and hatchery fish indigenous to Oregon and not introduced" (ORS 496.171, ORS 541.351).
Note: NOAA Fisheries has finally agreed that the Coastal Coho have attained sufficient numbers that they can be de-listed. This is the first de-listing of any salmonoids on the West Coast. But it shows that with some help we can bring back runs to reasonable levels. ___________________________________________________________________________________________ Oregon Hatchery Research Center Oregon's new Fall Creek Research Hatchery grand opening- Oct. 14,2005. This project will help define the best way to use hatcheries for mitigation and conservation that will aid our wild fish- and keep sport fishing viable. Oregon Anglers has several members appointed to the advisory board of the Oregon Hatchery Research Center. Dr. Ben Stout, one of our science advisors, was been elected as the center's first chair. Dr. Stout recently passed away after serving out his term of office. He has been succeeded by Dennis Richey, co-founder and Executive Director of OA, as the second chair of the OHRC. Tillamook County Commissioner Mark Labhart was elected as vice chair and will succeed Dennis next year.
Dr. David Noakes, the newly appointed lead scientist for the research hatchery, cuts the ribbon in the ceremony officially opening a new era in Oregon's hatchery system.
From left: ODFW Commissioner Dan Edge of OSU, ODFW Commission Chair Marla Ray, Governor Kulongosky, ODFW Director Lindsey Ball (whose vision and effort made this center possible), and Dr. Noakes pose for the press.
The research hatchery's water intake facility and fish ladder on Fall Creek.
As the water come into the facility it goes through this settling pond.
Water from the settling ponds then goes through filtration and the 3 identical engineered streambeds. At the grand opening a pair of steelhead had already set up housekeeping. Water from the streambeds then goes on to be used for raising pens and the laboratories. (not shown here- as well as the labs, residences, and support buildings.) For more on the research at OHRC you can go to the Oregon Anglers Research Society web site at www.oregonanglersresearchsociety.org or to see the live web cams set up in the engineered stream beds go to the Oregon Department of Fish and Wildlife's link at www.dfw.or.us/OHRC/ .
____________________________________________________________________________________________________ Ocean Angling International Pacific Halibut Commission The IPHC met the week of Jan. 14th- 18th, 2008, in Portland. The Proposal that got our attention was a staff recommendation that Oregon and Washington's halibut quota would be reduced by 50% over the next 2 years. The intent was to transfer that poundage to Western Alaska in the Aleutian Islands to be caught by the commercial long-liners. The worst part was that the IPHC had gone from an assessment by areas (Oregon and Washington's coast is area 2A) to a coast wide assessment, and had data to support the transfer. THIS WAS NOT FOR CONSERVATION PURPOSES, AND STOCKS OFF OUR COAST ARE INCREASING, NOT DECREASING. Our task to preserve our sport catch was a long shot. We contacted many interested groups and started organizing. By conference time Oregon Anglers and our partner clubs had 4 accredited delegates. No other group had more than one. It took a lot of private meetings and a few bought drinks, but in the end the quota was saved. Our 2008 allotment is 1.22 million pounds for area 2A. This comes to 1% higher than we would have had under the old assessment system. Lobbying and hard work saved the day. many thanks to John Holloway and the Oregon Angler Ocean Team. BUT, the threat is not over! This next winter the Halibut Commission meets in Vancouver B.C., and the Alaskans are still trying to take quota from our area, which includes Washington and Northern California. We are adamantly opposed to ANY cut in our halibut quota. Oregon Anglers is planning on having a team of accredited representatives at the week long meeting. All our volunteers are doing so at their own expense. It will take forming a coalition of interests including tribal ( primarily the Macaws) to override the clout the Alaskans have with the Commission staff. Marine reserve update (05/05/08 The Governor is still set on creating something that could limit sport and commercial fishing in Oregon's territorial waters. On March 27, '08 the Ocean Policy Advisory Committee's Marine Working Group ( a sub-committee formed to deal with the implementation of marine reserves) met to hear the results of the coastal outreach . This series of meetings in port towns all along the coast cost $80,000 of our tax dollars. The summary was that the vast majority of residents either wanted no marine reserves, or wanted them done according to science. The presentation was made by Ginny Goblish and former ODFW Commissioner Jeff Feldner. Then Roy Eliker (ODFW's director) read an executive order by Governor Kulogoski. This order essentially said that OPAC was to see that up to 9 marine reserve sites would be nominated by Jan. '09- totally ignoring the feedback that was just given. In addition the Governor's staff was withdrawing from running the process and Director Eliker was to be the personal representative of the Governor. Oregon Anglers' Executive Board met with Director Eliker, Assistant Fisheries Director Steve Williams, and other staff Monday April 28 and proposed a plan that we feel will work to the benefit of all. The basics of the plan are: 1) Nominate up to 4 or 5 "marine research areas" this year through the OPAC process. 2) Research objectives must be set for each site. Species subject to research should fall under state, federal or international management plans. 3) Both biological and geographical screening to see if site fits the objectives before any set asides or exclusions are enacted. 4) ODFW will retain administrative authority. 5) If research cannot continue, or site is not meeting expected objectives, the site will become part of the publically available territorial sea. 6) No license or tag fees can be used to establish or maintain research areas. 7) Local jurisdictions must be part of the siting process.
Wave Energy The following letter to FERC outlines our concerns that we are jumping into another situation like we did with the dams- little on no scientific knowledge on how it will affect fisheries, not only marine but anadromous runs could be seriously threatened. We applaud the search for clean power sources, but let's do our homework first!
Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20406 Re: FERC Docket No. AD07-14-000, “Proposed Licensing Process for Hydrokinetic Pilot Projects.”
Dear Secretary Bose, Oregon Anglers (OA) and the Recreational Fishing Alliance (RFA) Oregon Chapter thank you for the opportunity to comment on the proposed licensing process for hydrokinetic pilot projects. The mission of Oregon Anglers is to further the interests of present and future generations of recreational anglers in our state. The RFA is a national 501(c)(4) non-profit grassroots political action organization whose mission is to safeguard the rights of salt water anglers, protect marine, boat, and tackle industry jobs, and ensure the long-term sustainability of our nation's marine fisheries. We understand the critical importance of developing our nation's renewable energy infrastructure and exploring new ways to generate electricity. For recreational fishermen, the primary concern is the loss of fishing grounds because most of these devices will take up significant area and will likely be surrounded by an exclusion zone banning all fishing and vessel traffic. There are several categories of this proposed process where RFA-Oregon has concerns: jurisdiction, navigation, environmental effects including socio-economic impacts, development process and lead times. Jurisdiction: The first and primary concern is the fact that when looking at the Federal Power Act no mention is found of FERC having jurisdiction in the Exclusive Economic Zone or the Territorial Sea (state waters). A determination is made therefore that this authority in the marine environment is being assumed. This jurisdictional ambiguity must be clarified before this licensing proposal is considered. Navigation: FERC hydroelectric projects are required to maintain open navigable waters at no charge to the United States. Exclusion zones present navigational problems and safety issues as well. Environmental effects including socio-economic concerns: Our number one concern is the proposal to bypass the normal federal environmental impact analysis process. A baseline status inventory of all environmental and socio-economic conditions in place before any projects are placed is the one area that cannot be bypassed. The necessity for this is in no way related to project size. Impact determinations are impossible to determine if no original status is known. This inventory must include analysis of cumulative impacts. Location of projects is critical to impact minimization. RFA agrees that this is important, yet it is revealed that a project is being proposed for the waters of the Olympic National Marine Sanctuary. The FERC pilot project white paper states: “The pilot project licensing process will not be available to projects that would be located in waters with sensitive designations”. Is this an indication that the “white paper" is not being taken seriously by FERC. A federal sanctuary is by default sited in waters with sensitive designations. The proposed project size limitation of 5 MW has less to do with potential impact than other factors such as size of footprint, unit size, configuration, and other mechanical and electrically induced fields of force. The criteria should not be focused on generating capacity. Cumulative impacts to fisheries and fishing communities: Area management already constrain commercial and recreational fishing vessels to defined areas, and any further loss of fishing area concentrates the effort in smaller areas, contributing to localized depletion of fish stocks. These projects will cause adverse economic impacts on fisheries. The only question is to what degree. The cultural and economic value must be estimated accurately before project placement no matter what the size. There are more factors than just displacement from a select area. Displacement will cause increased effort in remaining areas open to harvest. This could cause a situation of overcapacity of fishing vessels/effort. The domino effect could lead to fishing infrastructure being lost as well as possible fishing related business failures due to inadequate supply to maintain profitability for commercial and charter sectors and opportunity for private recreational. Smaller communities could suffer total fishery economic collapse especially if their margins were very thin at the onset of these constraints. Reduction of fishery harvest capacity is not a simple fix as there are many parts of the support structure that cannot be removed without collapsing the whole. Mitigation of losses will be necessary regardless of size of economic impact. Once again cumulative impacts come in to play and must not be ignored. There is a long list of known and potential ecosystem impacts which must be fully examined. Some of the predictable impacts will be in the form of fish attracting devices, acoustic pollution, species entanglement potential, marine life obstruction, wave loss, biofouling, benthic habitat loss, entrainment of juvenile fish, predator prey balance, seabird landings/obstruction, and a dramatic change in species population composition Some possible impacts could include electromagnetic fields, in-water electrical short circuits, navigation impediments for marine species, shoaling and scouring, and localized ocean current velocity and/or direction alteration. Fish Attracting Devices (FADs): many of the devices are anchored and tethered to the sea floor, forming an artificial structure that attracts and holds predatory fish, like rockfish, throughout the water column, up to near the surface in areas where they previously could not live. Out-migrating salmon smolts could face a gauntlet of these fish, further impacting threatened and endangered species. Acoustic pollution: Noise will emanate from these devices due to mechanical systems used for generation and anchoring. Species entanglement potential: Large marine species, such as whales, already have a history of entanglements with anchoring systems and cabling. Marine life obstruction: These devices will cause normal paths of travel for many marine species to be altered. Wave loss: wave energy power reduces the wave height and could reduce circulation in the surf zone. Biofouling: Animals such as barnacles and algae form encrustations on anything in the ocean environment; anti-fouling agents used on metallic surfaces of the devices can kill marine life. Benthic habitat loss: anchoring alters the bottom structure, and damaged devices may damage intertidal habitat. Entrainment of juvenile fish: some hydrokinetic generators work on tidal flow, rather than wave energy, and use turbines to create power from devices submerged underwater; these can kill fish that get sucked into the works. Predator-prey balance: This will change significantly due to habitat changes. Reef dwelling species will increase in abundance. There will be an increase in the mortality of prey that is the target of reef predators. Anchoring systems may serve as ambush points by lingcod and others directed at small fish such as ESA listed salmon that may be passing through. Seabird landings/obstruction: Seabirds will use any floating device for a landing site. This could alter their feeding patterns. Seabirds that fly low over the water while foraging may move elsewhere due to obstruction. Pelicans are an example. [JM1] Dramatic change in species population composition: Groundfish species composition will change due to habitat changes. “Overfishing” by predators could occur resulting in constraints on fisheries caused by hydrokinetic devices alone. More cumulative effects. Electromagnetic Fields (EMF): What are the effects of stray current, and electromagnetic fields? Fish species are extremely sensitive to these electrical impulses and may be attracted to and repulsed from the wave energy plants, altering their migration routes. Salmon are believed to navigate using magnetic fields. Some salmon species are ESA listed so there is little room for error. In-water electrical short-circuits: This should be of particular concern as it a known method used to stun fish in rivers and lakes. If the shock is not fatal these species become easy prey for predators and scavengers. Navigation impediments for marine species: Physical obstacles may alter the normal migration and/or movement paths for marine species. Shoaling and scouring: Disruption of normal sediment transfer would likely occur. This effect has been well documented with regard to devices placed in marine waters. Port entrance jetties are an example. Localized changes in ocean current and/or velocity: If this were to occur it could potentially affect the entire living and physical ecosystem. More cumulative effects. Development Process: We find the process to be almost totally lacking in accountability and definition. If FERC proceeds down this road of loose control and concern we would recommend that an astronomic level of bonding be required to cover catastrophic environmental damage. With possible impacts to ESA listed species and the potential for more to become listed, this rush to market appears to be similar to the process that was used to site the hydro dams. We are all familiar with the environmental impact results. This proposed process carries little in the way of definitions. What is a significant impact? Who determines any of the stated criteria? All appears vague and changeable. There is no comprehensive plan. Environmental analysis is proposed to take place only after the impacts are realized. No prior analysis of likely impact is to take place other than considering other existing pilot projects with very little history in different environments. Nowhere in this process is there mention of cumulative impacts. Lead times: The six month time frame for the decision process leaves no time for meaningful consultation with other entities whose jurisdictions and interests include the marine environment. It is recommended that the time frame be set to a length necessary to accommodate full consultation with affected entities. It is our conclusion that FERC my not actually have the legal authority to regulate energy projects in the marine environment. This pilot project process appears to violate the federal Administrative Procedure Act. We see this as an attempt to implement projects without public display of crucial details. At the very least FERC needs to use an open and public notice-and-comment rulemaking process and perform environmental analysis before it takes any further action to authorize any projects. Sincerely, John Holloway Oregon Anglers, Ocean Co-chair Recreational Fishing Alliance, Oregon State Chapter
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