May 14, 2004

Dear Member of Congress:

I am writing to inform you about the National Oceanic and Atmospheric Administration’s (NOAA) upcoming proposals to renew listings of Northwest salmon populations under the Endangered Species Act (ESA), to explain how hatcheries will be taken into account in the proposals, and to correct recent erroneous accounts of how our hatchery policy will be used.

At President Bush’s direction, recovery of salmon is the major focus for NOAA in the Pacific Northwest, an objective widely shared in the region and the nation. We have been pleased to work with you and Congress to direct over $100 million of NOAA’s budget, and hundreds of millions more from other federal agencies to the cause of salmon recovery this year alone. These substantial resources are enabling the hard work of countless communities to improve hundreds of miles of fish habitat, to enhance fish passage to the habitat, and to rebuild fish stocks in order to re-establish sustainable natural salmon populations. Combined with favorable ocean conditions, this hard work is producing dramatic increases in nearly all of the salmon runs. Much work remains to be done to expand the habitat to support future generations of naturally spawning populations.

NOAA will shortly propose a renewed set of listings of salmon populations under ESA. Since 1991, the federal government has listed 26 species of salmon and steelhead in the Northwest and California for protection under the ESA. In a lawsuit that followed these listings, a federal judge set aside the listing of Oregon Coast Coho salmon because NOAA failed to include closely-related hatchery fish in the listing decision. Since the same flaw was present in almost all of the other listing decisions, NOAA voluntarily agreed to reconsider all of our earlier listing decisions and to adjust our policy for considering hatchery fish in making those decisions - and NOAA will be asking the public to comment on both. NOAA’s decisions are driven by the science, which suggests benefits, risks, and uncertainties regarding salmon hatcheries. Simply put, some well-managed conservation hatcheries are fostering recovery of species, some hatcheries are having little or no effect, and some hatcheries potentially hinder recovery.

After re-evaluating the listing of 26 species of salmon and steelhead, and considering the science on hatcheries, we have preliminarily determined to propose relisting at least 25 of the 26 species, with evaluation of the remaining species still underway. A final proposal will be completed in the next two weeks and the new hatchery policy will be only one factor for the evaluation still under way.

The central tenet of the hatchery policy is the conservation of naturally-spawning salmon and the ecosystems upon which they depend. As our preliminary conclusions indicate, appropriate consideration of hatchery fish does not lead to wholesale de-listing of species as some are claiming. Equally erroneous is the suggestion our policy would allow the purposes of ESA to be satisfied by having all the salmon in a hatchery. Salmon hatcheries have long played an important role in the Northwest, including fulfilling trust and treaty rights of Northwest Indian tribes, and supporting sport an commercial harvest cherished by Northwest citizens. NOAA is encourage by improvements in hatchery management, and is seeing their increasing contribution to speeding the recovery of salmon.

The communities of the Northwest have set high standards for their stewardship of land and water and NOAA urges them to continue this important work. NOAA strongly applauds the inspiring collaborative efforts underway in communities across the Northwest states and is pleased to be one of the region’s most committed partners.

Sincerely,

Conrad C. Lautenbacher Jr.
Vice Admiral, U.S. Navy (Ret.)
Under Secretary of Commerce for
Oceans and Atmosphere

That is certainly a much more reassuring stance from NOAA-F. It's great to hear that the new policy will likely not change the status of 25 of the 26 listed stocks this time around. However, it does not completely guarantee adequate protections for these threatened wild stocks in the future.

I now see that what Todd posted a few days ago was right on (What's new!?).... the key language being thrown around with some element of ambiguity is the concept of "divergence" of hatchery stock from wild stock. If the two are deemed "closely related" then they will be counted as one.

The key definition we must all keep our antennas up for is what level of genetic similarity NOAA is looking for. That might mean the progeny of only system-specific native wild broodstock. That could be tightened further to mean only one generation removed from wild broodstock.

As Todd said, the narrower the definition, then the better the situation. The broader the definition, the thinner the ice upon which NOAA-F is treading.

If this is the scheme they plan to use for counting these hatchery-produced fish, then wild broodstock programs that operate with the intent of "rebuilding" depressed populations of native fish should NOT be fin-clipping the smolts they release. The returning adults should be able to escape the fishery and contribute to seeding the river gravel alongside the naturally produced fish. Eggs mined from wild stock should not be used to fuel production of fish that will be harvestable upon their return (until of course wild populations have recovered to the point that harvesting them is appropriate).

I must emphasize that any hatchery program operating under such guidelines is at best an experiment. There are as yet ZERO published studies that support the concept that taking a pair of wild adults from the river and artificially raising their young in a hatchery can outperform simply just leaving that same pair of fish to do it on their own in the wild.

Perhaps hatchery reforms that include raising the juveniles in natural ponds where the fish must actively forage for sustenance and seek cover from natural predators (instead of being passively fed in protected concrete raceways) might actually improve the productivity of the hatchery as measured by the number of returning adults rather than just the number of smolts released.

We shall see.

Fish-N-

Actually, there is quite a lot of data that at least on some rivers, using hatcheries helps to rebuild stocks... at least for one generation. The important question that I see unresolved is that when the hatchery hatched fish come back and spawn in the river, do their progeny then have similar success as the others? That's really the important question from a genetic fitness standpoint.

On several streams and rivers in the OP, they have been doing broodstocking on summer chum. All of the rivers and streams have shown impressive returns coincident with the program.

I think that some major differences in the life histories between summer chum and chinook might make the same kind of program more challenging for chinook, though.

Looks like the heat already got to them - that was quick!

Good job to everyone who spoke up against this insanity.

In the talent contest, I'm giving NOAA a well deserved score of 9.8 in the 'back-pedaling' event.