More talking points

Additional talking points not directly applicable to these comments (but maybe for later?)

• Hatcheries are required for salmon recovery and harvest as mitigation for habitat damage; yet, these hatcheries, built to make up for lost fish because of damaged habitat, are increasingly under attack, while the condition of habitat continues to worsen and goes unchecked due to inadequate habitat protections, climate change, and other environmental and ecological factors (such as climate change, or pinniped predation) that have nothing to do with hatcheries or harvest
• The fact that these programs were developed as mitigation for lost habitat and resultant natural salmon and steelhead production is well documented and very clear to everyone including myself
• Because of the ongoing habitat loss, we have been forced to become more and more dependent on hatcheries to provide any steelhead or salmon for our fisheries – today, the vast majority of our harvest is dependent on hatchery fish, including all the steelhead caught in recreational fisheries that are the subject of this evaluation
• Funding for hatcheries continues to be cut from crippled budgets that have already resulted in significant hatchery closures and reductions – in just the past six years alone, the Washington Department of Fisheries has cut more than 50 million dollars from its budget, much of it from hatchery production
• Meanwhile, greatly worsening effects from climate change are causing more and more harm to steelhead and salmon throughout their life cycle (use example of the current drought to emphasize that these effects, heaped on top of already depleted freshwater and marine habitat, are causing the vast majority of the problem/99% of the problem and something Has to change)!
• That something is the share of the conservation burden not being carried by habitat
• Chief opponents mainly just want all of the hatcheries to be shut down (and the alternatives as initially presented by NOAA Fisheries only offer this same failed remedy), yet, if wild fish continue to disappear primarily as a result of lost habitat and hatcheries are reduced or closed, there won’t be any fishing, or ANY fish left the fact that these programs were developed as mitigation for lost habitat and resultant natural salmon and steelhead production is well documented and very clear to everyone including myself
• Comanagers have greatly reduced harvest of wild stocks and have significantly changed hatchery programs to reduce wild stock impacts
• Hatchery programs, and recreational and commercial harvest programs that depend on them, are well managed/the tribes and state operate safe, responsible hatchery programs that are guided by the best available science and we will need these programs for as long as habitat continues to limit production from our watersheds
• NOAA Fisheries’ NEPA and ESA risk assessments should support hatchery and harvest programs that employ best management practices
• If simply eliminating hatcheries and harvest was the solution, we would have accomplished natural stock rebuilding a long time ago. Though these programs have been crippled and greatly curtailed or eliminated in many instances, the stocks have not rebounded and are declining at a faster rate than ever because habitat quantity and quality drives steelhead and salmon health. We have lost more steelhead and salmon due to disappearing habitat than have ever been harvested or lost due to hatchery effects
• These hatchery programs support the economy and way of life for all Washingtonians, and the current climate of litigation, hatchery closures, and reductions has harmed all of the citizens of Washington State. NOAA Fisheries must do a better job in this EIS to recognize the importance of harvest to all constituencies, the economy, and the northwest way of life
• The burden of conservation must be better shared by habitat if we ever going to recover steelhead or salmon and state and tribal hatcheries and fishers have been carrying most of the weight for far too long/or, and we/I have been carrying…..
• NOAA Fisheries must adequately clarify interactions between habitat, natural production and hatchery production in the EIS for early winter steelhead hatchery programs and their relative cumulative effects and
• Hatchery programs, where severely depleted fish populations exist due to degraded habitat conditions, should be managed appropriately for all factors affecting viability and not solely on hatchery effects. Until these populations are healthy, these hatchery programs are essential and must not be reduced or eliminated - all this will lead to is no fish whatsoever
• Habitat is the cause, the mitigation, and the solution to recovering our imperiled steelhead and salmon populations, not any further devastating cuts to hatchery and harvest programs and NOAA Fisheries’ NEPA and ESA risk assessments must consider all factors affecting priority salmon populations, not just Tribal and State hatchery and harvest programs
• Hatcheries can help rebuild natural populations or buffer impacts on natural populations, meet treaty fishing rights, and critically important tribal and non-tribal fisheries simply could not happen today without hatcheries.
• Hatcheries help recreational fishers and tribes pass on the culture of fishing between generations, preserve the icon of our state, and the important values and treaty rights that depend on them, affecting all citizens
• Hatchery fish are used daily in management to assess the status of natural populations through marking, tagging tracking studies, etc, e.g., Indicator Stocks, or, related to the marine mammal predation problem: Recent radiotagging and tracking studies show that >80% of WILD juvenile steelhead die in Puget Sound before they reach the ocean
• As already presented in the scoping, the DEIS suggests that the only options to benefit conservation are through reduced hatchery production. This is ludicrous! There are other actions that can actually achieve conservation benefits that don't include reduced production.
• In general, the DEIS scoping has a very negative connotation to it (i.e. issues, concerns, impacts) that already sets the tone for the scoping that the actions themselves are harmful and destructive, while ignorig the immense benefits.

So what is the best way to move forward?
• Adjust parts of some programs, possibly (in very few cases)... but if at all, do it based on rational thinking, not rapid reaction to lawsuits
• Base considerations on hatchery, harvest AND especially, HABITAT.
• No closures, injunctions, or reductions before NEPA and ESA processes are COMPLETED, which is unfair a illegal
• Use the comanagement process at all stages. It’s the law anyway - - -
• State and Tribes must work, and are working, together to prevent 3rd Parties from subverting the process any more than they have already done
• Tribes and sport fishers are weighing in on NEPA and ESA consultations this time around to let everyone know who the majority is in Washington State
• TOGETHER, the State, Tribes, and the Federal Government must vigorously fight any future injunctions that would threaten to unfairly eliminate these programs through attrition even before they have been evaluated
• While it is highly likely, or it should be anyway based on the best available science, that the final decision by NOAA Fisheries on these hatchery programs may result in a no jeopardy determination, for ALL of the proposed early winter steelhead hatchery programs, but if yet another injunction is unfairly allowed before the facts are in, they will be killed anyway, and that will not be acceptable and will only trigger additional litigation
• I think each watershed should have its own balance of natural and hatchery production, based on the needs of treaty and non-tribal fisheries, tailored to its own needs based on the unique habitat conditions, the specific hatchery practices, and the status of the hatchery and natural populations and the robustness of the watershed’s natural production potential
• Hatchery programs that is based on habitat condition & coordinated with habitat restoration & protection
• The only approach that will lead to long-term sustainable salmon and steelhead resource, and the only way this NEPA evaluation can begin to adequately encompass the scope of possible and realistic alternatives, is to integrate all of the “H’s” into the effects analysis of the proposed alternatives. The programs do not occur in isolation and their evaluation must recognize the cumulative effects of all of the actions on steelhead viability, which is NOAA Fisheries’ responsibility under the ESA anyway