Thursday, April 9, 2009

WDFW and Quinault Tribes release infected fish


In the last few weeks both WDFW and the Quinault tribe have released hatchery reared steelhead smolts infected with IHNV a viral disease which could potentially spread to wild fish populations. The disease stays with a fish for life and is highly contagious. This represents an extremely negligent act with very little ultimate benefit considering the potentially catastrophic impacts. Below are memos written by the Tulalip tribe protesting the decision to release infected smolts.

TO: JOHN KERWIN, RON WARREN, JIM SCOTT; WDFW
FROM: RAY FRYBERG SR., TULALIP TRIBES
CC: TERRY WILLIAMS, TULALIP TRIBES
SUBJECT: CONTROL OF IHN AND RELEASES OF LAKE ABERDEEN STEELHEAD AND RAINBOWS
DATE: 4/2/2009
The Tulalip Tribes are very concerned that the steelhead releases from Lake Aberdeen Hatchery
could pose a significant risk of contributing to the establishment of the M-D strain of IHNV to
coastal steelhead populations. We appreciated receiving the March 30, 2009 (10:02 AM) email
from John Kerwin to Bruce Stewart containing the notification regarding the intended releases of
steelhead smolts and sub adult rainbow trout that have had past or ongoing problems with the MD
subclade of infectious hematopoietic necrosis (IHN) virus. The Tribe also valued the viral
sampling and detection activities and operational steps taken by your Department to control the
spread of infection. We also appreciated getting the Risk Assessment on March 30th in
accordance with the Co-manager Guidelines to Prevent the Establishment of the M-D Strain of
IHN Virus in Washington State River Basins Outside of the Columbia River. While we
appreciated getting this information, it was unclear from your notification and risk assessment
what dates were intended for any of the releases, or how many fish were involved.
However, we regret your decisions to release the brood year 2008 yearling winter- and summerrun
steelhead and rainbow trout from the Lake Aberdeen Hatchery that have tested positive in
the past for M-D IHNV. We now come to find out that the steelhead releases were initiated
within a day after the notification was made, and were completed yesterday, April 2, 2009,
which does not meet the minimum five days pre-notification as agreed upon in the abovementioned
Guidelines. We believe these releases are a mistake and pose much more risk than
you have determined. Without even knowing the numbers of fish involved and other important
details, we still believe these risks are unacceptably high. Our concern is that the planned
releases have a high probability of spreading the virus to other brood years of your hatchery
production while exposing other natural- and hatchery-origin fish in the Chehalis basin and other
unexposed basins and lakes. The risk of further spreading and amplifying IHN disease could
have devastating effects to other natural-origin steelhead populations and other hatchery
programs. This virus has already spread through several watersheds, and we are greatly
concerned that, if these release practices are not halted, they will continue to spread this

pathogen throughout the State. We make a few key points in the bullets below and follow these
with a more detailed discussion of the risk assessment and management actions taken.
• We believe these releases pose much more risk than was determined, because we think
there is a relatively high probability of spreading the virus to other natural- and hatcheryorigin
fish in the Chehalis and other unexposed basins, further spreading the virus.
• There has been a disturbing trend toward the relatively new practice of retaining hatchery
fish actively infected with IHN disease, particularly fish carrying the M-D strain, and
knowingly releasing them in Washington State outside of the Columbia basin, which
goes against many years of strict eradication efforts.
• Standards for proving the virus has cleared a stock in question have not been developed
or put into any policy and no real input from other comanagers is incorporated into the
current management decision-making process.
• The March 30, 2009 notification and risk assessment lacked key information such as
dates for intended releases, locations for trout releases, numbers of fish being released,
and tissues assayed for virus.
• The testing appeared inadequate (low numbers of asymptomatic fish, tested infrequently,
found negative on only one occasion in tissues that are less likely to detect virus in).
• The releases occurred within a day after the notification was made, which does not meet
the minimum five days pre-notification in the above-mentioned Guidelines.
• While the current agreed-to Guidelines intended to prevent the spread of the virus are
better than none, we disagree with the language currently adopted, which enables releases
of infected fish if any comanager facility determines that the benefits outweigh the risks.
• Given the apparent failure to control the spread of this strain of IHNV and the release
practices that have occurred in the past year, we continue to advocate for much stricter
control measures, that would still enable some flexibility for certain rare exceptions.
• We believe adequate control measures will first include standards for testing fish and
reporting results, followed by providing adequate time for written responses and then
inclusive meetings between all comanagers when eradication is not proposed to explain
the rare, extenuating circumstances and that will ultimately require a consensus to be
reached among comanager’s fish health specialists if alternative actions are proposed.
• We are first requesting a convening of the Treaty Tribes to re-address this matter, to be
followed up with a comanagers meeting, with the ultimate intent of adding new,
specifically clear restrictions to the Comanagers Salmonid Disease Control Policy
regarding the rearing and release of fish known to be infected with regulated pathogens.
• We are aware that there are gray areas and difficult details to be resolved on different
aspects of the relevant issues, but at the same time, if the virus continues to spread and
the comanagers cannot resolve these issues and develop an effective policy that results in
effective change, we will continue to build support for taking whatever actions are
necessary to prevent this problem from continuing to worsen.

We think that the appearance of this virus in Grays Harbor tributaries should have been expected,
given the long history of this disease and numerous releases from Idaho and other Oregon and
Washington hatcheries of the adjacent Columbia River basin. We are not surprised that it has
now spread to the adjacent Quinault basin and see a likely, direct relationship between the
steelhead releases last March that exhibited elevated mortality at Humptulips and the first
detections in the Quinault system three months later in June of 2008. Similar to this current
situation, we objected to those releases in writing immediately after we were informed of the
intent. We were not surprised that there were 15 new detections of this strain of IHNV between
2007 and 2008 in adult and juvenile steelhead, rainbow, and coho from Lake Aberdeen as well as
the Skookumchuck, Wynoochee, Satsop, and Humptulips Rivers, we will not be surprised when
it continues to spread further and/or to persist in the already infected watersheds because we
believe it is these release practices that are continuing to cause the spread of this virus. Besides
the diseased hatchery fish that directly contribute to the dissemination of IHN, we believe these
releases create numerous additional opportunities for viral transmission, which endangers wild
and hatchery fish throughout the state and burdens all of us who depend on these resources.
While we appreciated receiving the Risk Assessment, we feel it is critical at this juncture to
clarify some of the points made. We think the analysis made some good points and explained
some of the new actions your agency has taken to control the spread of the virus, which we
applaud. However, we disagree with the level of risk assessed and the conclusions drawn and
feel we need to add some clarifications to a few key points made. Therefore, the remainder of
this letter will mainly address some of the specific points made in the March 30, 2009
notification and attached Risk Assessment. Again, we offer the following comments not as
criticism but to add additional points to the analysis for the overall purposes of improving how
we tackle this problem in the hope that our collective efforts will eventually eliminate the virus
from spreading and causing any more major losses to wild and hatchery steelhead.
First, addressing the body of the March 30 email and also as mentioned in several parts of the
Risk Assessment, you stated that while the juvenile steelhead were found to be positive in the
past, recent testing has been negative and mortality rates low or typical of what is expected of
steelhead at this stage in their life. However, this is also consistent with a low incidence and
level of infection typical in juvenile O. mykiss undergoing subclinical IHN infection.
We agree with the concern expressed by your fish health staff “that the virus may be present at
very low levels in the stocks planned for release. If that is true then it is likely that these fish will
expose other fish to the virus as they migrate out of the Chehalis River Basin.” Even at very low
incidence and intensity in host trout, past studies have shown that a small number of juvenile
rainbow trout, sub-clinically infected only in gill tissues, still shed large amounts of virus. Also,
in a past study we are aware of, exposure of O. mykiss to low waterborne levels (<>

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