SRF Hatchery Comment Letter
Joshua Israel, President November 12, 2004 Chief, Protected Resources Division, NMFS RE: Hatchery Listing Policy To whom it may concern: I am the President of the Salmonid Restoration Federation (SRF), a California statewide non-profit organization that provides training, professional development, and advocates on behalf of salmon and steelhead restorationists. I am writing to comment on the Proposed Policy on the Consideration of Hatchery-Origin Fish in Endangered Species Act Determinations for Pacific Salmon and Steelhead. For the past twenty-two years, SRF has been convening restorationists at annual conferences, field schools, and workshops and three themes have appeared in our programs consistently- habitat restoration, protection of instream flow, and hatcheries. In the past three years, we have held conference sessions on conservation hatcheries twice. While SRF generally supports the proposed policy on consideration of hatchery salmon and steelhead in Endangered Species Act determinations and the resulting listing determinations as described in the Federal Register1, it feels there remains some issues requiring clarification to ensure a precautionary and conservative application and utilization of the policy. As currently proposed the policy lacks guidance for utilizing 4(d) rules in hatcheries that utilize wild broodstock, seems to not include lessons learned from the NMFS and California Department of Fish and Game’s Joint Hatchery Review2, and does not clarify how uncertainties in hatchery management influence Endangered Species Act determinations.
Specifically, a sixth point should include information about Hatchery
Genetic Management Plans, as a mechanism for protecting genetic resources
and life history diversity. Discussion of these plans in the policy
are an opportunity for guidance on how NMFS will apply Section 4(d) “take” prohibitions
to hatcheries operating in threatened ESUs. The final policy must include
a point that incorporates continuing the process of assessment, evaluation,
and monitoring of hatchery stocks that are included in listed ESUs.
NMFS and the state agencies have done considerable review of their hatchery programs, including the NMFS-CDFG Joint Hatchery Review for California hatcheries. Lessons from these operations should be synthesized and included in a final policy. The Joint Hatchery Review suggests the CDFG Cooperative Hatchery Program is a critical link between hatcheries and recovery of endangered salmonids. It states that many of these small-scale natal rearing hatcheries may help achieve ESU-wide recovery when they focus on re-establishment, expansion, or maintenance during periods of poor population size because of watershed condition or ocean survival. These small scale hatcheries are required to mark all fish, often revealing more information about hatchery salmon escapement in these basins then large scale hatcheries are able to in the basins they operate in. Additionally, most basins that these small scale cooperative hatcheries have operated in have community-based monitoring programs quantitatively assessing juvenile outmigration and adult returns of wild stocks of salmon, as well as their hatchery returns. Unfortunately, CDFG ended funding for these programs this year. SRF suggests that NOAA-Fisheries review the results of operations like the Prairie Creek hatchery on Redwood Creek operated by PCFFA; the Humboldt Fish Action Council hatchery on Freshwater Creek in Humboldt Bay; and the Redwood Creek hatchery on the South Fork Eel River operated by the Eel River Salmon Restoration Program. In Oregon, where the state has spent considerable time developing salmon and steelhead recovery efforts similar cooperative rearing programs in the ODFW STEP program are viewed as a critical element of stock restoration efforts. NOAA should provide some guidance in their final policy for identifying the population and spatial scale of effective hatchery operations.
No where in the new policy or Federal Register does NMFS discuss the uncertainty involved in modeling population demographics in the artificial hatchery environment, the inability to account for differences in wild and hatchery stocks, or the types of hatcheries operating and how this affects salmon populations. The new policy should provide information about how uncertainty in decision-making surrounding hatchery practices can be reduced in order that hatchery practices enhance recovery of listed species. The policy should provide simple definitions of supplemental, conservation, and natal-rearing hatcheries. Some hatcheries are now using conservation genetics techniques, behaviorally appropriate feeding and raceway design, incubation and rearing techniques that approximate natural profiles through increased habitat complexity and water cycling, and aggressive monitoring and evaluation of their approach. These should be mentioned as ways ecologists and managers are attempting to reduce uncertainty through a more cautious approach to hatchery operations. In summary, it seems when conservation techniques are applied at a watershed level, focused on recovering and maintaining viable populations of wild salmon as sources for migration and gene flow within a salmon metapopulation, managers will begin to see meaningful recovery of wild populations of salmon and steelhead. This policy moves consideration of hatchery salmon and steelhead in listing determination in the right directions, but lacks the guidance to insure correct interpretation of it by administrators and managers in the future. Further detailing of previous lessons from hatcheries and a format for Section 4(d) permitting would improve the utility of this policy and provide critical guidance for state agencies, community organizations, and tribes working to recover salmon and steelhead. Sincerely, Joshua A. Israel President, Salmonid Restoration Federation 1. 69 Fed. Reg. 33,103 (June 14, 2004) 2. CDFG (California Department of Fish and Game). 2001. “Final report on anadromous salmonid fish hatcheries in California.” California Department of Fish and Game and National Marine Fisheries Service Southwest Region Joint Hatchery Review Committee. Review draft, June 27, 2001. |
