When you say that WT believes LLTK's work violates the ESA, what do you mean? We certainly don't beleive that the HSRG hatchery reform process violates the ESA or is even a bad thing. Overall, we support it, as far as it goes.

We are concerned that the issueing of reports is as far as the HSRG process is going to go. The HGMPs certainly provide no evidence that WDFW will implement even one of the approximately 500 HSRG recommendations for improving hatchery practices in Puget Sound.

Hatchery reform isn't about three or four experimental programs scattered throughout the 180-odd programs WDFW runs, no matter how promising they might be. The entire program needs to be reformed, state wide, and in the meantime, it should be significanlty scaled back to reflect the inherent risks to listed species and the acknowledged experimental nature of the reform efforts.

Here is a good analogy made by a guy the other day testifying before the Pacific Fisheries Management Council. He was talking about harvest policy (yes WT works on commercial harvest issues), but I think it applies in this case as well.

He said it's as if we were heading down a dark mountain road at 100mph, in a car with faulty brakes. Any qualified observer could predict disaster. Of course no observer can say at what curve the car will leave the road, which tree it will hit, or how much damage will ultimately result. Nor can they blame with any certainty the faulty brakes on driving too fast.

"Well, I'm sorry," says the driver, "But if you can't get any more specific than that, then I don't see any reason why I should have to slow down. Hold on."

Or the dirver says," Ok, maybe you've got a point, but I already slowed down to 95. Get off my back."

Can anybody see how this is going to end?

Ramon Vanden Brulle
Washington Trout