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Comments on NMFS Proposal to ESA List 23 Hatchery Programs

Wild Fish Conservancy recently sent the National Marine Fisheries Service (NMFS) a letter that outlines our concerns about their proposal to list 23 hatchery programs under the Endangered Species as well requests that NMFS conducts a full EIS and evaluate/revise the 2005 Hatchery Listing Policy.

For more than a century, fisheries managers have tried to replace the dramatic loss of wild salmon and steelhead with manufactured hatchery fish. But now the National Marine Fisheries Service (NMFS) is taking this effort a dangerous step further by trying to treat hatchery salmon and steelhead - fish that are produced to subsidize harvest opportunity - like wild fish. If NMFS succeeds in doing so, their actions would have cascading effects that would set a dangerous precedent to further the decline of wild salmon and steelhead as well as undermine the foundation of endangered species protection for all species.

By trying to list these hatchery programs, NMFS is turning its back on mountains of scientific evidence, including science produced by the agency itself. And by choosing to circumvent the public process by proposing this listing without conducting an environmental impact statement and providing a sufficient public comment opportunity, NMFS is shutting out science and the public.

Therefore, the Wild Fish Conservancy is asking that NMFS conduct a full EIS as well as evaluate/revise the 2005 Hatchery Listing Policy.

We believe these are legitimate requests given that:

  • This proposal requires a substantial scientific review.
  • There are significant inadequacies and scientific shortcomings in the Federal Register (FR) Notice and supporting documentation.
  • The eleven-year-old Listing Policy is out of date and is inconsistent with the best available scientific data and knowledge, which have evolved and become far more sophisticated over the last decade.
  • No quantitative data or related analyses are provided to justify the assertions that specific hatchery programs and populations warrant inclusion in the 23 listed ESUs and DPSs proposed.
  • These documents focus purely (albeit inadequately) on genetics and fail to address features of life history, ecology and demography of populations, which were a prevailing concern of the Hatchery Science Review Group (HSRG).
  • And much more…

To read the full set of comments that the Wild Fish Conservancy submitted to NMFS, please click here.

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