Heeding agency scientists, the National Marine Fisheries Service (NMFS*) announced in the summer of 2002 that it would continue to protect wild salmon based on their declining population numbers. Soon, however, Mark Rutzick, a former timber industry lawyer became a political appointee with significant responsibility over salmon policies and urged the administration to delist wild salmon based on hatchery fish numbers -- an act that could jettison salmon habitat protections that constrain logging.

In April 2004, a new draft policy surfaced that, for the first time, would “count” hatchery fish and treat the hatchery’s concrete pools as extensions of natural rivers in deciding whether wild salmon need protection. In June 2004, NMFS published a proposed hatchery policy that would “count” hatchery fish in deciding whether wild salmon will be protected under the Endangered Species Act. While NMFS has not proposed to delist any salmon or steelhead populations at the present time, the new policy would, if adopted, sow the seeds for future delistings and for immediate shifts of resources away from habitat protection to hatchery operations. This policy is illegal, unwise, and contrary to sound science. Comments on this policy are due November 12, 2004.

The Endangered Species Act Promotes the Ability of Fish and Wildlife to Survive in their Natural Environments

The Endangered Species Act protects species and the natural habitats they need to survive. It prevents harmful activities that jeopardize endangered species’ ability to survive “in the wild” and protects habitat essential for the species’ recovery. The goal of the act is to bring species to the point where they no longer need the act’s protections to sustain themselves. For salmon, that means the focus must be on wild salmon and their ability to sustain themselves in native salmon streams. That has been the view of every administration until this one.

The Role of Hatcheries under the Endangered Species Act

Hatcheries evolved to compensate for declining salmon runs due to grazing practices, overfishing, dams, and habitat destruction from activities such as logging and development. While they have produced fish to support sports and commercial fisheries, they do not address the overfishing and habitat destruction that precipitated the decline of wild salmon runs. Worse yet, excessive reliance on hatcheries masks the real causes of decline.

The Endangered Species Act defines captive breeding and artificial propagation programs (which is what hatcheries are) as a tool to help species recover. Hatcheries are not entitled to Endangered Species Act protection in their own right; instead, they can receive protection under the act only to the extent they promote recovery of salmon in the wild.

The hatchery policy would count hatchery fish that are bred in captivity and spend their early freshwater life cycle in captivity. These fish are introduced into salmon streams when they are ready to migrate to the ocean. NMFS would “count” them upon their return, without requiring that they make it to salmon spawning grounds, reproduce in the wild, and produce viable offspring.

Concrete is Not Salmon Habitat

Salmon need cool, clean streams to spawn and rear, and fast-moving migratory corridors free of obstructions to migrate to and from the ocean. The proposed hatchery policy would provide an excuse to degrade freshwater habitat since more fish can be produced in hatcheries to replace those that perish in dams, dewatered streams, or headwater streams choked with sediment.

Overwhelming scientific evidence demonstrates that we must change dam operations, restore habitat, keep more water in streams, and regulate riverside development to rebuild salmon runs. The administration’s proposal to “count” hatchery fish provides cover for those who don’t want to make the necessary changes in practices that degrade salmon habitat. The federal government has spent billions of tax dollars on restoration that will be squandered if hatcheries become a substitute for restoring salmon habitat and the ability of salmon to reproduce naturally in salmon streams. The proposed hatchery policy would reverse the progress that has been made to improve habitat and the health of Northwest streams.

Suppression of Science

In March 2004, six leading marine scientists who had been hired as government consultants on salmon recovery published contrary views in the journal Science. NMFS told the scientists to eliminate a portion of their report that addressed policy matters. The excised material concluded that hatchery fish impede wild salmon survival and that recovery must focus on ensuring self-sustaining populations of naturally spawning salmon.

The editor of Science and former president of Stanford University, Donald Kennedy described the scientists as top-notch and stated that their article easily withstood review by scientific peers. One of the scientists, Ransom Myers, a fisheries biologist at Dalhousie University in Nova Scotia, stated: “One hundred years of hatcheries have not brought back wild Atlantic salmon to Maine. Once we lose the wild populations of salmon and the natural habitats that support them, we will never get them back.”

Denying Endangered Species Protection One Population at a Time

The Bush administration’s hatchery policy is part of a trend in which species are redefined by lumping disparate populations together and denying the individual populations protection because there are plenty of critters elsewhere. This trend defies Congress’s desire to afford Endangered Species Act protection to populations before the entire species is on the brink of extinction and to preserve remnant populations in the United States, even if a species may be more plentiful abroad. On that basis, we have protected bald eagles, grizzly bears, and wolves. This administration is taking a new tack, viewing US populations as dispensable, as long as a species continues to exist somewhere in the world.

This move to lump populations together to deny them protection is part of this administration’s hostility to endangered species protection. The U.S. Fish and Wildlife Service and NMFS have added no species to the endangered species list without being ordered to do so by a court.

If you prefer to send your comments yourself, you can send them before November 12 to: