Please review below, excerpts from a document called “Review of Salmon and Steelhead Supplementation” (June 2003), prepared by the Bonneville Power Administration’s Independent Scientific Advisory Board. The ISAB prepared the Supplementation Review at the specific request of NOAA Fisheries and the Northwest Power Planning Council, an agency of the BPA. I have excerpted and abridged the eight principal findings of the review, from the Executive Summary. (They are abridged in the interest of brevity and clarity, an attempt not entirely successful; these are scientists after all. If anyone feels inclined to accuse me of cherry-picking, here is a link to the entire document: http://www.nwcouncil.org/library/isab/isab2003-3.htm.)

While these findings are admittedly conservative and cautious, as scientific language generally is, taken together, they support my statement: the idea that hatchery salmon are capable of contributing to the recovery of ESA- listed wild populations is completely unproven. As far as the other statements I made regarding the impacts of hatcheries on wild-fish populations, they are supported by an entire bibliography of scientific literature. I invite grandpa and Keith to do THEIR homework.

To be fair, the findings below could support Auntie’s position: “We do not have definitive evidence that hatchery intervention is not a workable solution YET.” But the point is that this would be a very thin thread to hang an entire recovery strategy from, as this policy proposal does.

If the best you can say is that we can’t PROVE hatchery-supplementation WON’T work, then it at very best irresponsibly premature to say that hatchery fish are capable of contributing to recovery, particularly in the face of the overwhelming scientific evidence of the risks hatcheries pose to wild populations, and the poor record of existing programs documented by the ISAB review. (Keep in mind that the ISAB WORKS FOR THE BUSH ADMINISTRATION. When NOAA requested the review, they were looking for cover for this policy-proposal; this is what they got instead.)

I think Dave Vedder has it about right. You don’t have to be “anti-hatchery” to be against this policy or to recognize it for what it is, at best irresponsible, at worst a cynical attempt to circumvent true recovery, for the benefit of particular stakeholders. Make no mistake, if this policy is adopted, it WILL result in the early and inappropriate de-listing of salmon and steelhead stocks throughout the NW, allowing forestry, development, agricultural, and other economic interests to damage and destroy fish habitat without the important restrictions currently in place. Yes, Lautenbauer’s letter and statements by Bob Lohn give lip service to protecting wild fish, but the policy itself is artfully vague enough to allow NOAA to do essentially anything it wants, with no way to challenge it. It’s not just bad science; it’s very bad public policy.

The Bush administration wants you to believe it is offering a future of plenty of hatchery fish to catch, even if they aren’t quite the same as the wild salmon and steelhead that are your children’s birthright. Even if you think it will work and that it’s good enough (I don’t believe it will work, and I don’t believe it is good enough), what you are really being offered is a future of “adequate” numbers of facsimile salmon returning to completely spoiled rivers. They believe you will be satisfied with what Jim Lichatowich called “salmon without rivers.” Will you be? Washington Trout will not be.

(BTW grandpa: I did not say “Bush.” I said “Bush Administration,” of which Admiral Lautenbauer and Mr Lohn are certainly a part. They are both Bush appointees and serve at the pleasure of the president.)

The ISAB findings:

“Finding 1: Hatchery programs in the Columbia River Basin provide some salmon harvest and reintroduction opportunities. Those hatchery programs which are based on hatchery broodstock lines, and which allow the hatchery products to interact intensively with natural populations, almost certainly impose a large cost on the affected natural populations. For hatchery programs where the hatchery and natural population are integrated, the empirical basis is inadequate for determining the cost to the natural population.

“Hatchery programs in the Columbia River Basin release nearly 200 million salmon and steelhead smolts into the natural environment annually. These releases of hatchery-reared juveniles can return large numbers of adult fish, providing commercial, sport, and tribal harvest. Hatchery-reared juveniles are also beginning to be used to reintroduce salmon into areas where they had become extirpated. Most of the hatchery programs are not integrated with natural production because they rely extensively on fish of hatchery-origin for their broodstock. Nevertheless, the hatchery productions from these programs are present in large numbers on the breeding grounds of many natural spawning stocks. In some cases this is deliberate; in others it is inadvertent. Either way, this constitutes a supplementation action.

“The impacts of these hatchery programs on the extinction risk to (or recovery of) the remaining natural populations of salmon and steelhead have not been determined empirically. These knowledge gaps need to be filled.

“Finding 2: Contemporary genetic/evolutionary theory, and the literature that supports it, indicate clearly that supplementation presents substantial risks to natural populations of salmon and steelhead.

“Supplementation can affect the adaptation of natural populations to their environment by altering genetic variation within and among populations, a process that can negatively affect a population's fitness through inbreeding depression, outbreeding depression, and/or domestication selection.

“These genetic risks of supplementation suggest that it would be prudent to continue to treat supplementation as experimental, that supplementation should only be deployed on a limited scale, and that better and more extensive monitoring of such experiments be required to generate an empirical record capable of evaluating those experiments.

“Finding 3. The immediate net demographic benefit or harm to population abundance from supplementation depends on three things: intrinsic biological parameters of the stock in its environment; policy constraints; and management control variables. The integration of these factors, much less their measurement, has not been adequately considered in supplementation evaluations to date.

“Finding 4. Current monitoring and evaluation efforts are inadequate to estimate either benefit or harm from ongoing supplementation projects. The correct parameters are not being consistently measured.


“Finding 5. Columbia River Basin supplementation projects are considered to be ‘experimental.’ Unfortunately, inadequate replication and widespread failure to include unsupplemented reference streams coupled with a lack of coordination among projects make it unlikely that these projects (as currently conducted) will provide convincing quantification of the benefits or harm attributable to supplementation.

“There are enough streams in the basin already being "treated" with supplementation. Future investment should be in establishing robust experiments with unsupplemented reference streams and rigorous monitoring. Treatments on streams that do not have a matching reference stream should be terminated.

“Finding 6. The following operational conclusions emerged from our review of case histories of Columbia River Basin supplementation programs:

“Among the programs that we assessed, the presence of appreciable numbers of hatchery-origin adults on the spawning grounds in the late 1980s and early 1990s did not prevent declines in the abundance of natural-origin spawning adults. There is no evidence that similar problems will not occur in the future.


“Finding 7. Many hypotheses and conjectures concerning supplementation are largely unevaluated. This finding is based on our review of case histories of Columbia River Basin supplementation programs. Three examples are provided.

“Assertion 1. Even though natural populations supplemented with hatchery-origin adults through the mid-1990s exhibited a continued downward trend in natural-origin adult abundance, it has been claimed that supplementation still aided the natural populations by providing additional adults for spawning. The validity of this assertion is unsubstantiated. A test of this claim would have required an experimental design employing unsupplemented reference populations.

“Assertion 2. It has been claimed that supplementation will provide a net ‘demographic boost’ to a target population, because the total production of offspring from natural spawning of the hatchery-origin adults is larger than the production of offspring that would have occurred if the broodstock in the previous generation had been allowed to spawn naturally. This assertion has not been tested because the reproductive performance of hatchery-origin adults spawning in the wild has not been adequately compared to that of natural-origin adults.

“Assertion 3. It has been claimed that the long-term fitness of progeny that result from the in-river breeding of hatchery-origin individuals with hatchery-origin or with natural-origin individuals is comparable to the fitness of progeny from two natural-origin individuals. This assertion is unevaluated in programs following an integrated breeding protocol, and it is contradicted by empirical evidence on the natural spawning performance of domesticated hatchery strains.


“Finding 8. With our current knowledge base, a technically valid risk-benefit analysis of supplementation is dominated by the high level of scientific uncertainty about the possible magnitudes of the potential beneficial and detrimental effects.”


Addtionally, in response to a specific question from NOAA about “what would be an appropriate level of intervention,” the ISAB gave the following response (abridged):

“Currently available empirical information is inadequate to predict the outcome of a thoughtful conservative supplementation effort for any potential target population or on collective populations … (This after pointing out that no such “thoughtful conservative supplementation effort” currently exists). …(The ISAB) argues for limiting the scale of supplementation and for ensuring that a considerable fraction of the populations not be supplemented….”

Again: The foundation of this proposal, that hatchery salmon are capable of contributing to the recovery of ESA- listed wild populations, is completely unproven.

Ramon Vanden Brulle
Washington Trout