Todd, my good man, I do hope at some time that you and I get a chance to fish together. I say that because I have no doubt that you are one of the "good guys" and I appreciate what you have to say, even if I don't whole-ly support it.

I'm not sure about the cost to hatch and then replant fry, but at least part of the lengthy cost of feeding fish until they reach smolt stage would be no longer necessary.

You say the survival rate to return would be lower than when planted as smolts.....OK, I'll agree. But then with smolt plants you are talking about hatchery fish which have been domesticated to the point that they would just as likely approach a seal to be fed, or a sea gull, etc., as they have never known enemies.

Fry would have the advantage of learning in a natural environment ,i.e., their native river, before going to sea. (I'm even thinking that hatching them in gravel beds in a hatchery might even instill in them spawning characteristics as well.)

Would planting them require special considerations? Of course. They would require dispersal, as opposed to just dumping them in the river. (Although the Bull trout and gulls would love that technique.)

Now I'm not sure what the hatchery personnel would do with all their spare time, since there would be no fish to mother for months at a time, but that's not a concern, is it?

Biologically, clipping fins would be BS as well, since the fry only hatched in a protected environment, and were not raised there. I know, it's not legal....but changing the verbiage to exclude hatching as being the same as hatchery-raised could take care of that problem.

Methinks that there is a reluctance to change long established practices....even for the betterment of the fish.