69 Fed. Reg. 31354 (June 3. 2004)

1. A Salmon or Steelhead species now includes hatchery fish!
   NOAA Fisheries identifies and manages salmon and steelhead as Evolutionary Significant Units (ESUs). A group qualifies as an ESU if it is 1) substantially reproductively isolated and 2) represents an important component in the evolutionary legacy of the biological species. Under this proposed policy, the ESUs can now include hatchery fish in the ESU if they are within some range of genetic similarity to the locally adapted wild population.
   
   
2. Hatchery fish will determine if a species is threatened or endangered!
   NOAA will determine whether the entire ESU (both hatchery and wild populations) is threatened or endangered under the Endangered Species Act. If the ESU is threatened or endangered, the entire ESU, including hatchery fish, will be listed. They will decide the future of salmon based on whether the wild and hatchery fish improve the abundance, reproduction (productivity), spatial distribution and genetic diversity, of the species.
   
   
3. The proposed Policy recognizes that the long-term risks of hatcheries outweigh any short term benefits
   According to the proposed policy, the potential short term benefits of hatcheries to salmon, such as increasing the number of fish or as providing emergency safety nets, are very likely outweighed by the long term negativeimpacts to the behavior, genetics, disease and habitat use of the wild fish to the point where salmon may never recover. Nonetheless, as a result of the policy, over 140 hatchery populations will receive protection under the Endangered Species Act.
   
   
4. NOAA argues that this policy is required by the courts and by new science
   NOAA argues that new science in the last decade and the court in Alsea Valley Alliance v. Evans forced it to propose this new hatchery policy. However, the court in Alsea Valley Alliance told NOAA that it could exclude all hatchery fish from the ESUs, and that option was squarely before NOAA in numerous “wild-only” listing petitions which it denied. Similarly, NOAA could have appealed the case demanding a more sensible outcome. Finally, NOAA ignored the very scientists it hired to advise them on this issue. In March, 2004, those scientists wrote in the journal Science that based on decades of scientific evidence, hatchery fish should not be included in the ESU.
   
   
5. NOAA argues that not much will change.
   The proposed policy states that the purpose and multiple provisions (sections 7 and 10) of the ESA allow NOAA to give “special recognition” to wild fish as a measure of sustainability without requiring separate treatment between hatchery and wild fish. Furthermore, the policy acknowledges that hatcheries are not a substitute for addressing the real factors for decline. Yet in the proposed application of this policy, NOAA argues that additional concrete raceways increase the “spatial distribution” of the ESU and thereby reduce the risk of extinction. More concrete is not the kind of change these fish need to survive and is not representative of the state policy of recovering wild fish in their natural habitat.
   
   
6. The proposed policy lacks incentives for hatchery reform.
   Contrary to public statements, there is nothing within the proposed policy to indicate that NOAA will use the policy to encourage hatchery reform. Indeed, in the Lower Columbia River coho where there are some of the worst hatchery practices in the West, NOAA proposes including over 21 hatcheries in the listing. Instead of changing hatchery practices, this policy protects the very practices that lead to the near extinction of Lower Columbia River coho.
   
   
7. The proposed policy applies only to Pacific salmon and steelhead.
   
   
8. A policy on how hatchery fish contribute to conservation and recovery is forthcoming.