PG&E released their Final Draft License Surrender Agreement (LSA) for the Eel River Dams.
This is one step before the Final LSA is released in early summer. In addition to the LSA, a
recent Memorandum of Understanding (MOU) has been released by water users on the
Russian and Eel River sides. In the MOU, a run-of-the-river diversion to the Russian River has
been agreed upon that has reduced resistance against the dam removals. While parts of the
MOU are not ideal, it should result in a smoother path to dam removal. The LSA was a beast of
a document, with some reasonable points and timelines, and some issues that need to be
addressed. PG&E is trying to get these dams out as quickly as possible, as it is in their best
interest for liability and financial reasons. The major problem we had with the LSA was in the
vague, but repeated suggestions for “relocation and broodstock rescue” to aid in recovery of
salmonids. This is just a trap and haul and hatchery program by another name. We submitted
the following comment to express our concerns regarding this proposal. Stay tuned for future
opportunities to comment to PG&E or NMFS on these proposals.

Dear PG&E,
We are writing to comment on the Final Draft Surrender Application. The primary freshwater issues negatively affecting salmonids and other native fishes are the four H’s, i.e., Harvest, Habitat, Hydropower and Hatcheries. The Eel River does not currently have any harvest of wild fish. Habitat has been altered and damaged by numerous causes, some of which will take untold generations to heal, but restoration projects are being implemented throughout the basin, and many harmful practices have been curtailed. The habitat blocked by hydropower operations is on the verge of being reconnected and accessible to migratory fishes. And the Eel River does not currently have any hatcheries. Salmonids in the Eel River are well suited to move towards recovery. We are concerned with the suggestion in 3.4.1.4, Environmental Effects: Fish and Aquatic Resources, pg. 1401 that “The Post-dam Removal Aquatics Species Management and Monitoring Plan would include measures to capture/salvage, relocate, and implement broodstock rescue of aquatic species.” We are not convinced capture/salvage and relocation is a necessary measure, considering that DO was measured to be 0 in the Klamath River for multiple periods during fall-run Chinook migration and yet thousands of adults made it through those abhorrent conditions to spawn above the old dam sites. If capture/salvage and relocation were deemed necessary, based on severity of sediment load and duration, it should have very clearly defined goals, specific start and completion dates, and occur for as short of a duration as possible. We do not see any scenario under which broodstock rescue for either steelhead or Chinook, would ultimately benefit wild salmonids in the Eel River. Hatcheries were used as mitigation for habitat lost from dam construction. There is ample published literature showing that they are unsuccessful in that role and usually have adverse effects on wild fish. In a synthesis of 207 studies on impacts of hatcheries, McMillan et al. (2023) found that 83% of the studies examined had negative impacts, and only 3% had positive impacts. Hatchery fish, even those used in “broodstock rescue” i.e., the first generation bred from wild broodstock, have significantly lower fitness than wild offspring of wild fish (Chilcote, 2002). If hatcheries were able to rebuild or even maintain healthy populations of wild fish, then close to half of California’s Evolutionarily Significant Units of salmonids wouldn’t be listed under the Federal Endangered Species Act (Moyle et al., 2017). There are a couple prominent examples of wild fish rebounding after severe disturbance, akin to what will occur when the Eel River dams are removed. Seven years after Mount Saint Helens erupted and buried the Toutle River in superheated ash and sediment, wild steelhead runs exceeded carrying capacity. Wild summer-run steelhead numbers increased from less than ten to hundreds of individuals six years after dam removal was completed on the Elwha River. In most other cases we have been unable to observe what the response of wild fish would be due to the pre-emptive construction of hatcheries as mitigation for the disturbance. Genetic diversity in the resident O. mykiss population above Scott Dam has been maintained up to the present. From Kannry et al., 2020 “Our results suggest that, considering their present state of run-timing genotypes, the potential to exhibit migratory behavior, and overall genetic diversity, the resident trout population above Scott Dam would be primed for reestablishment of steelhead post dam removal. Given the results of our study and the potential negative consequences and costs of hatchery fish, it seems prudent to give the native O. mykiss the opportunity to autonomously reestablish anadromy in the upper watershed upon dam removal.”
All Chinook hatchery operations in the California Coastal ESU ended in 2007, as it was recognized that Chinook numbers were still declining and the hatcheries, even though they were small, localized efforts, were likely contributing to the decline (Moyle et al., 2017). Chinook salmon have a higher rate of straying than other salmonids (Westley et al., 2013) so are well positioned to make use of newly accessible above dam habitat. The idea of “broodstock rescue” is usually reserved for instances in which a population is either extirpated or so depressed, that they have no chance of rebounding. That is not the situation on the Eel for Chinook (or steelhead). Precise population estimates are not available, but over 1000 Chinook were observed at Van Arsdale and in Tomki Creek this year. There are many thousands more in the other major forks and tributaries. These numbers are unequivocally fractions of what existed historically, but not a population on the verge of imminent collapse. From Chilcote (2003), “For natural populations, removal rather than addition of hatchery fish may be the most effective strategy to improve productivity and resilience.” The removal of the Eel River dams is an opportunity for recovery of the native fishes. Let us not continue the same error of hubris and think human technology can more effectively produce fish than a free-flowing river.

References:
Chilcote, M. (2002). ODFW Broodstock Memo.
Chilcote, M. W. (2003). Relationship between natural productivity and the frequency of wild fish in mixed spawning populations of
wild and hatchery steelhead (Oncorhynchus mykiss). Canadian Journal of Fisheries and Aquatic Sciences, 60(9), 1057-1067.
Kannry, S. H., O’Rourke, S. M., Kelson, S. J., & Miller, M. R. (2020). On the ecology and distribution of steelhead (Oncorhynchus
mykiss) in California’s Eel River. Journal of Heredity, 111(6), 548-563.
McMillan, J. R., Morrison, B., Chambers, N., Ruggerone, G., Bernatchez, L., Stanford, J., & Neville, H. (2023). A global synthesis of
peer‐reviewed research on the effects of hatchery salmonids on wild salmonids. Fisheries Management and Ecology, 30(5), 446-
463.
Moyle, P. B., Lusardi, R. A., Samuel, P. J., & Katz, J. V. (2017). State of the Salmonids.
Westley, Peter AH, Thomas P. Quinn, and Andrew H. Dittman. "Rates of straying by hatchery-produced Pacific salmon
(Oncorhynchus spp.) and steelhead (Oncorhynchus mykiss) differ among species, life history types, and populations." Canadian
Journal of Fisheries and Aquatic Sciences 70.5 (2013): 735-746.
Sincerely,