May 18, 2004

Mr. Don Koch
State of California – The Resources Agency
Department of Fish and Game, Northern California – North Coast Region
601 Locust Street
Redding, California 96001

Dear Mr. Koch:

On behalf of the Klamath Water Users Association, I would like to outline some concerns and questions our association has regarding operations at Iron Gate Fish Hatchery. It is our understanding that the hatchery is scheduled, or has started, releases of fingerling chinook salmon into the mainstem Klamath River below the hatchery. It is our understanding that the hatchery has modified practices in recent years, but we are not completely clear on several issues. The purpose of this letter is to secure additional information on this matter, and more importantly, to urge that the California Department of Fish and Game (CDFG) collaborate with the U.S. Bureau of Reclamation (Reclamation) to ensure that hatchery and Klamath Project operations are coordinated and enhanced to the maximal possible extent.

In the past year, our association has accelerated outreach efforts with other stakeholder groups, particularly those that rely on the resources of the Lower Klamath River. In meetings with commercial and sport fishermen, as well as irrigators in the Scott and Shasta Valleys, the issue of state hatchery management often arises. It appears that the effect of hatchery fish on populations of wild salmonids in the Klamath basin is not well understood. However, judging this matter based upon our recent stakeholder discussions and based on the final 2003 report prepared by the National Research Council Committee on Endangered and Threatened Fishes in the Klamath River Basin, hatchery impacts to threatened coho salmon appear to be negative. For example, the release of millions of juvenile chinook salmon every spring floods the river with fish that are larger than the wild fish. The hatchery fish may displace or stress wild coho salmon. If hatchery production does indeed result in net loss of wild coho salmon, hatchery operation should be modified.

Currently, just over a week since Reclamation was required to change the water year type to "dry" on the Klamath River because of plummeting runoff forecasts, it appears that CDFG is still on track to release 6 million juvenile chinook into the river at Iron Gate. We are hearing reports of diseased fish in the Klamath River, which may or may not have a relationship to the hatchery fish. We have three questions related to this issue:

1. Has CDFG or others performed an assessment of the health of the hatchery fish prior to the release of these fish?
2. If so, could we obtain related records?
3. If not, will such an assessment be prepared?

If CDFG or others are not planning on performing a disease assessment, including a disease history for the fish that are being released, please consider this letter as the formal request from our association to do so.

Our fisheries scientist – David Vogel – played an important role in coordinating hatchery releases from Coleman Fish Hatchery with water releases from Shasta Dam on the Sacramento River. This required improved cooperation between the U.S. Fish and Wildlife Service and the U.S. Bureau of Reclamation in the Central Valley. Mr. Vogel believes there is merit to pulse flows associated with release of juveniles, but that the related flow magnitude and duration is a matter that must be very carefully developed. On the Sacramento River, Reclamation’s Shasta Dam water releases were coordinated with fish releases from Coleman hatchery to allow larger fish to move downstream earlier in the year. We believe that Reclamation and CDFG should investigate developing a similar relationship between Iron Gate hatchery operations and Klamath Project flow operations. With that said, we have two questions on this matter:

1. How is CDFG working with Reclamation to consider coordinated management operations that benefit the objectives of both agencies?
2. At Iron Gate Hatchery, what types of internal hatchery practices has CDFG implemented or considered, towards releasing these juvenile fish earlier in the season, when water temperatures are cooler?

It is our understanding that CDFG has an option of holding some of the fingerling populations over the summer at the hatchery and releasing them downstream when the fish are larger and stronger. We understand that this practice does entail increased expenditures at the hatchery, and that, in recent years, this policy has not been exercised. One question:

1. Is the current practice of releasing all of the fingerlings during the spring a decision that is driven by biological justification, or is it a function of diminishing funding?

We are already seeing claims from some interests that another fish die-off on the Klamath River is imminent. We also understand that a certain mortality rate is expected any time millions of small fish are released into a river system. For example, the Eureka Times-Standard recently reported that 200,000 Klamath River fingerlings died in the spring of 2001.

1. For the past 10 years, what has been the observed and/or estimated mortality associated with spring releases of Iron Gate Hatchery fingerlings?
2. What is the expected mortality for this year?
3. Is the Times-Standard estimate correct?
4. Where did the fingerlings die in 2001?

It is our understanding that returns to Iron Gate Hatchery in 2002 were the third highest on record, despite the deaths of 33,000 fish on the lower river that fall. In late December 2002, CDFG officials notified our office that at Iron Gate Hatchery, 24,641 chinook adults, 950 adult coho and 114 adult steelhead returned to the hatchery. This was the third highest total since the hatchery began monitoring returns in 1961, which brings up some additional questions:

1. We have been told by CDFG officials that Iron Gate Hatchery requires 8,000 returning fish to meet production goals. Is this number correct?
2. If this is correct, it would appear that in 2002, returning adult chinook salmon exceeded the number required to replenish the brood stock by over 16,000 fish. What exactly happened to the surplus returning adult chinook that exceeded the amount required to replenish the hatchery stock?

On behalf of KWUA, I thank you for considering these questions. Again, we strongly encourage that CDFG work closely with Reclamation to enhance the Klamath River objectives of both agencies wherever possible. If you have specific questions about this letter, please do not hesitate to contact our office.

Sincerely,

Dan Keppen

Executive Director