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Washington Trout, Native Fish Society, Environmental Community, Oppose New NOAA Hatchery Policy
Federal Policy Still Ignores Science; Opens Door for Inappropriate De-Listings
The Bush Administration is scheduled to formally announce on Friday a new policy regarding the treatment of hatchery and wild salmon and steelhead in federal ESA-listing decisions. A one page draft of the policy, developed by NOAA Fisheries, the federal agency in charge of managing ESA-listed salmon and steelhead, was leaked several weeks ago, and appeared to indicate the administration intended to count hatchery fish with wild salmon in an attempt to remove ESA protections from declining wild populations, provoking broad opposition throughout the region from scientists, environmentalists, community leaders, regional policy makers, and members of Congress.
Since then, the administration has appeared to back away from some of the most potentially damaging immediate impacts of the policy, sending a letter to Congress stating that at least 25 of the 26 currently listed populations of salmon and steelhead would likely remain protected under the new policy. However, the administration has made no indication that it intended to revise any language presented in the leaked draft, and while temporarily retaining federal protections for wild fish stocks, the policy will still include hatchery fish along with wild fish in determining health of individual stocks, something most scientists say likely will impede long-term recovery.
A wide range of respected fisheries scientists and ecologists have gone on record in recent weeks maintaining that a policy that combines hatchery fish in with wild fish in making decisions on protections will jeopardize the recovery of listed wild populations. Representatives from NOAA’s own scientific advisory panel noted in an article that appeared in the prestigious journal Science, “much evidence exists that hatcheries cannot maintain wild salmon populations indefinitely,” and warned that while it is contrary to the science, including hatchery fish in listing decisions “opens the legal door to the possibility of maintaining a stock solely through hatcheries.” (Emphasis added.)
The new policy will be the subject of public hearings and comment periods. Conservation groups do support the opportunity for the citizens of the Northwest to voice their opinions on what is clearly an important issue. Also reacting loudly to speculation about the legal implications of the policy have been industry and development groups, who favor the removal of ESA protections for both hatchery and wild fish, and the reduced restrictions on logging, agriculture, and development that would result. It is clear they believe this policy should open the door to early de-listings, and plan on using the policy to further that agenda.
The foundation of NOAA’s new policy, that hatchery salmon are capable of contributing to the recovery of ESA-listed wild populations, is completely unproven. While hatcheries can produce fish for harvest, not one hatchery program designed specifically to supplement and recover a wild population has any record of proven success, and the preliminary results from these programs are far from encouraging. A review of hatchery supplementation programs in the Columbia River, published last year by the Columbia River Power and Conservation Planning Council’s Independent Science Advisory Panel, was extremely critical of current conservation-hatchery programs in the Columbia Basin, and found few encouraging results.
“This is not based in science, and it’s bad public policy,” said Kurt Beardslee, Washington Trout’s Executive Director. “At best, it is irresponsibly premature to even partially base a salmon-recovery strategy on such an unproven and risky approach. At worst, it’s a cynical attempt to circumvent true recovery, for the benefit of particular stakeholders.”
In fact, far from being a means to recovery, the overwhelming preponderance of scientific evidence strongly suggests that hatchery fish threaten the long-term viability of wild salmon and steelhead populations. Hatchery fish decrease the genetic fitness of wild populations, compete for food and habitat, spread disease, and promote increased predation. Hatchery runs create harvest pressures that declining wild runs cannot support. The offspring of wild-hatchery mating survive and reproduce much less successfully than true wild fish, weakening a population’s ability to sustain itself.
Current science strongly suggests that hatchery fish can “replace” wild salmon populations only insofar as they are likely to wind up eliminating the true wild population. The region would be accepting not recovered populations of wild, native salmon, but substitute populations of artificially produced animals significantly different than the lost wild population, and significantly less likely to be able to sustain itself in the wild, no matter what how high the quality of the wild habitat is. It is important to understand that hatchery salmon are not just different than wild fish; they are demonstrably inferior in the traits necessary to survive and reproduce effectively in the wild. Mating between hatchery/hatchery fish and between hatchery/wild fish both result in lowered spawning success relative to wild/wild mating, generally 50%-80%. Healthy, abundant salmon populations generally replace themselves at ratios only slightly above one to one. Even seemingly small reductions in reproductive success at the population level could have devastating results.
In recent weeks, administration officials have claimed they were at the mercy of a 2001 court decision by Judge Michael Hogan to lump hatchery fish in with the wild fish in making ESA determinations. Conservation groups say that simply isn’t true. Judge Hogan did not lump together hatchery and wild salmon under a single category. In fact he did not address the scientific distinction between hatchery and wild fish. On purely legal grounds, Judge Hogan found that the government had acted improperly in the way it had made the distinction. He did not preclude it making that distinction in a different way.
Environmentalists point out that NOAA could have accepted 15 petitions to separate hatchery and wild fish and just list the wild fish, which is both legally possible under Judge Hogan’s opinion and biologically necessary to protect wild fish, they say.
Conservation and fishing groups have also voiced concern over what could lead to relaxed protections for salmon habitat resulting from the policy. Even if hatchery salmon were not an actual threat to wild fish, the statutory mission of the ESA is to recover naturally reproducing populations by preserving and restoring the natural ecosystems they depend on, not mass-producing artificial facsimiles.
The successful recovery of biodiversity and ecosystem-function requires both high quality habitat and high quality animals to interact with that habitat. Even a policy that preserves salmon-habitat protection through continued ESA-listing of wild salmon and steelhead, but allows those fish to be substituted with unfit hatchery fish, will not result in true or sustainable salmon recovery, and could in fact lead the region’s native salmon populations closer to extinction.
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