kjackson

You are absolutley correct in your explanation of the Hogan Ruling, and that is important information that everyone here needs, thanks. But what your posts fail to note is that while the original Hogan Ruling only applied to the Orgegon Coast coho ESU, this new policy being proposed by NOAA will apply to ALL ESUs. NOAA is saying that the new policy reflects compliance with the law as judge Hogan interpreted it, an interpretation that they now say they support.

When the new policy is formally announced on June 30, it will be accompanied by announcements of any changes to the indivicual listings prompted by the new policy. Expect at least a couple de-listings or downgrading of listings from Endangered to Threatened. But that won't be the end of it. The major threat of this policy is the unjustified acceptance of the notion that hatchery production by itself can be a legitimate path to "recovery" and delisting. Expect periodic review of ESUs to determine when the listed hatchery populations have "helped" the ESU meet the four criteria enumerated in the new policy (abundance, productivity, spacial distribution, and genetic diversity). The relevant hatchery programs will be "designed" (more likely simply re-labeled) to contribute to those criteria. The criteria are so broadly described in the very short and broad policy (less than one page) that it won't be difficult to for managers to determine that almost any situation would qualify, and there won't be any way to challenge the decision.

For instance, the policy says that hatchery fish "genetically no more than moderatley divergent from natural populations" can contribute to de-listing. Whether or not that is good science (it's not), it is very bad policy writing. Each of you, my friends, are genetically no more than moderately divergent from a chimpanzee, only aboout 2%. Expect de-listing of most ESUs with listed hatchery populations within, say, four years of this November.

The final policy has no basis in science, and in fact diverges significantly from the draft policy prepared by NOAA's NW-Region Science Center. Far from a road to recovery, hatchery production has been a significant factor in the decline of wild salmon and steelhead populations, and continues to jeopardize their actual biological recovery. The hows and whys have been discussed on this board at length, are well documented in the scientific literature, and are available to those interested. If you can stomach it, try starting at the WT website (www.washingtontrout.org).

The fact of the matter is that captive breeding programs are very bad ways to recover at-risk and declining wildlife populations, and should only be considered as the absolutely last resort, as when you have two sockeye returning to Redfish Lake, or are looking at the last several breeding pairs of California Condors. Even then we should take a very sober look at the record. In over 25 years of trying, the California condor program has NEVER produced a single pair of birds that have successfully bred in the wild. There was a lot of excitemennt a year or so ago when a pair actually laid and hatched an egg, but then the pair killed the fledgling. The program produces condors and releases them in the wild; the population of living birds in the wild has increased slightly since the beginning of the program. But it is looking increasingly likely that if we want condors flying around, we'll have to keep making them forever.

Is that a future we want for salmon and steelhead? It's the one this policy will deliver.

Ramon Vanden Brulle,
Washington Trout