Opening the process will put some teeth into it, not just "repeat" it. I believe you must be referring to the anticipated NMFS public-review process, that this new process will augment. The NMFS public-review process will likely focus on its own approval decision, not the individual HGMPs. It will come after NMFS will have already esentialy made its decision. Actually under the terms of WDFW's Puget Sound HGMPs, NMFS is not even required to offer any comment period at all.

Now WDFW will have to submit not only its hatchery plan to NMFS for review, it will also have to submit your challenges or comments on that plan, and WDFW's response to those comments, as part of its application for ESA approval. The real issues will be part of the record, issues that WDFW might be happier to leave out. That will make it much harder for NMFS to approve a bad plan, and easier to challenge them if they do, or at least call them on it in their own public-comment process.

This will offer supporters of the HSRG process an opportunity to evaluate and comment on how well WDFW is following, or even trying to start to follow, the HSRG recommendations, before WDFW sends its plans to NMFS for approval. This should help jump-start the hatchery-reform process, and give the public an opportunity to monitor its progress.

We think the public can and should be engaged in the whole process, not just get to comment on the finished product. This year, NMFS imposed conditions on the tangle-net fishery in the Lower Columbia that significantly reduced the impacts of that fishery on listed steelhead and salmon. NMFS based its conditions on several sets of comments they recieved from WT, TU and others, over the entire period of time decisions were being made regarding the planned fishery, not just one set they got at the end. Good public comments, based on facts and good science, if they can really engage the decision-making process, can be much more effective at influencing management practices.

Ramon Vanden Brulle,
Washington Trout