Here's a post I put on a different forum on the subject...I think it will be appropriate here, now, too.

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I think I can boil my personal feelings about this policy shift down to one single issue...which all the rest will flow from.

How is "moderately divergent" defined?

It's the type of definition that really means nothing, and when those types of definitions are used by the experts (which the courts define as the agencies charged with implementing the policy...i.e., NOAA Fisheries and probably the USFWS), the courts tend to defer to the definition given by the agency.

The broader the definition, the more hatchery fish will be counted, and the less money and time will be spent on upgrading concerns within the 4 H's. The narrower the definition, the more protections...

Here's a BIG issue for me...if it is defined broadly, then more effort will go into broodstock programs to create more "essentially" wild fish, using hatchery raceways as "habitat" to help recover salmon and steelhead stocks.

All of the science shows that this does not work, that with proper habitat, two wild fish left in the river to do their thing will produce more returning adults than will the same two fish put into a hatchery situation.

Accepting that as a truth (it continues to be debatable, for some reason, but no one has ever produced a peer reviewed study to say anything but that), there are two options.

Option one is to NOT have broodstock programs, continue to have hatchery fish that are more than "moderately divergent", the so-called "segregated" hatchery programs, and use manipulation of the other 3 H's to recover wild fish.

Option two is to rely on broodstock programs to create loads of fish that are less than "moderately divergent", utilize hatchery raceways as the preferred habitat of these "wild" fish, and continue to degrade the river habitat, which won't be necessary to recover wild runs because of all the raceway habitat that we will have.

If option one was the one that the administration was going to go with, then they wouldn't have had to do anything...it's essentially what we're doing already...only counting truly wild fish.

So...since they're attempting to change somthing, rather than keep it the same, I see Option #2 coming down the pike.

By the time the science is proven out in widespread practice, that this won't work, it will be too late. With no more truly wild fish to rely upon to create more "wild" hatchery fish...well, I don't even want to go there.

This is how the runs will eventually end...to maintain the less than "moderately divergent" status of the hatchery fish, there is a certain amount of truly wild fish that must continue to be introduced into the hatchery stock to, a percentage, say, 25% for argument's sake.

As the amount of truly wild fish dwindle, so does its contribution to hatchery programs. To maintain the proper percentage, less hatchery fish will have to be utilized. This, of course, will lead to less fish overall. As the cycle continues...less and less fish return, until all are listed again under the ESA, only now we have less fish and less habitat.

The tradeoff for this is increased revenues for the habitat destruction industry, for a limited time, which will also stop when the re-listing occurs.

Again being cynical...short term economic benefits for a few, long term economic and ecological costs that will almost certainly outweigh those short term benefits...but that will be someone else's problem by then.

This assumes, of course, that there are fish left to re-list, , which is far from assured, unless we use fish that are "moderately divergent" from hatchery fish that are "moderately divergent" from wild fish. And so on...

Fish on...

Todd
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Fish on...

Todd