Regarding whether a permit is needed, it is my understanding that any form of "take" of wild Puget Sound steelhead would require a permit. Perhaps some of the others with more ESA knowledge can confirm that.

If that's the case, even if genetic introgression is low, and the negative effects of introgression are minimal, it seems like it wouldn't be difficult to show that some form of "take" is occurring through the hatchery programs. If that's the case, then I'm not sure how such programs would be in compliance with the ESA.