A hatchery program comes with a fishery for them, which catches some wild fish, which causes some mortality...ALL hatchery programs in an area under the jurisdiction of the ESA cause "take"...that's why they need the permit.

The permit doesn't say "your program causes zero take"...the permit says "your take is Incidental Take, and is not inconsistent with recovery goals"...and the program needs to go thru the permit process so that NOAA-F can find that to be the case...that the take is incidental, therefore allowed, and the hatchery program is good to go.

Any introgression is interfering with breeding...any release of smolts is interfering with feeding.

Don't get caught up in trying to say the programs don't cause "take"...there is 100% no doubt in the world that they cause take.

The only question is about the nature of the take...and if the take does not significantly interfere with recovery goals then the take is "incidental", and the program will be issued an "incidental take permit".

Fish on...

Todd
_________________________


Team Flying Super Ditch Pickle