In case everyone is not aware.. the progress of the Cedar River Sockeye Hatchery has been held up with an appeal to its EIS last spring. No resolution to the appeal yet, but I understand there may be a hearing later this month. The EIS was not appealed by Washington Trout, but by an ex-King County DNR employee who would like to see the City of Seattle's funding for the hatchery diverted to King County's land aquisitions downstream. I've attached the appeal text below, but understand many of the assertions are bogus, i.e., with the interim test sockeye hatchery at Landsburg in operation for almost 10 years now, the Cedar River Hatchery program is probably the most researched program ever to come forward.

Appeal text:
Roz Glasser
5609Greenwood Ave. N.
Seattle, WA 98103

April 3, 2003

Meredith Getches
Seattle Hearing Examiner
1320 Alaska Bldg.
618 Second Ave.
Seattle, WA 98105

Subject: Appeal of the Seattle Public Utilities Cedar River Sockeye Hatchery Final Environmental Impact Statement.

Dear Ms. Getches,

Enclosed please find my appeal of the Seattle Public Utilities (SPU) Cedar River Sockeye Hatchery Final Environmental Impact Statement and the $50.00 appeal fee.

The appeal includes three attachments. The body in Attachment A, substantiates numerous failures of the FEIS to comply with procedural and substantive provisions of the SEPA regulations at both the state and City of Seattle level. The appeal also asserts that the FEIS has been deliberately written to avoid mitigating for known and probable significant environmental impacts to the Lower Cedar River and Lake Washington ecosystems. Among these impacts are losses of reproductive fitness of wild sockeye stocks, further declines in chinook populations (a threatened species), disease risks to wild stocks, and increased predator populations. Some, or perhaps all of these impacts may be irreversible. Finally, it asserts that the FEIS makes many claims about the efficacy of the hatchery and a long term research program to address the impacts. However, little or no scientific data are provided to validate the claims. This is most disturbing for a project of the magnitude of the proposal involving major and highly valuable natural resources.

To support the assertions of this appeal, two extensive annotated bibliographies are included in Attachment B and C. They summarize the scientific research on hatcheries and their failure to adequately supplement wild stock without imparting significant impacts on the ecosystems in which they operated. Attachment B covers research on problems hatchery programs have caused for native and wild fish. Attachment C includes research on the interactions between hatchery propagated salmon and wild salmonids. While t do not claim to be an expert on the specific of each of these studies, I believe that even a nontechnical person can readily see the compelling record of failures. Nonetheless, I am prepared to provide technical experts who can discuss the details of these findings for your consideration. These bibliographies underscore the need for rigorous scientific analysis that strongly supports the efficacy of the proposal before it is implemented and not wait to conduct fundamental research after the EIS process is completed, as is proposed.

I recognize that SPU has spend years and may hundreds of thousand of dollars conducting the EIS process for the hatchery project. However, as a taxpayer concerned about the abuse of public money, and a professional watershed planner who has worked on the Cedar River Basin, I am deeply concerned about the effects of this project given the current scientific literature cited. After reviewing this science in Attachment B and C I am convinced that the FEIS has not presented the objective assessment of issues and impacts required.

In view of the extensive omissions and lack of analysis in the FEIS, I have concluded that the authors should prepare a Supplemental EIS which includes the best available science on the subject to discuss the affected environment and identify and, evaluate cumulative Impacts. The SEIS should also Include a hatchery management plan and detail mitigation measures for known impacts and provide and specific criteria in the adaptive management plan framework. I also suggest that if the acknowledged research Is permitted to continue under an adaptive management program, further environmental review should be required to evaluate the risks, impacts, and mitigation of each phase.

Finally, because there appears to be an inherent bias In the development of the FEIS, I am submitting a public disclosure request to SPU (Attachment D) to obtain communications and reports associated with this study which I hope will assist you in your deliberations.

Thank you for your attention to this important matter. If you have questions please call me at (206) 789-1097.


Sincerely,

Roz Glasser

Enclosures

Attachment A - Appeal Text
Attachment B -Annotated Bibliography
Attachment C -Annotated Bibliography
Attachment D - public Disclosure