Endangered and Threatened Species: Proposed Policy on the Consideration of Hatchery-Origin Fish in Endangered Species Act Listing Determinations for Pacific Salmon and Steelhead

Public Comment Period Ended October 20, 2004 Read Environmental Commons' Letter to NMFS See detailed fact sheet for more information  (pdf, 138 KB) Read the Proposed Policy: www.nwr.noaa.gov/reference/frn/2004/69FR31354.pdf

Wild Salmon copyright Will Guyan

The questions to be addressed are:

1. Are hatchery (or artificially propagated) populations of salmon and steelhead part of the endangered and threatened biological units?
2. How should we consider hatchery fish in terms of extinction risk?

According to the Endangered Species Act, to be listed as endangered or threatened, a group of organisms must constitute a "species," which is defined to include "any subspecies of fish or wildlife or plants, and any distinct population segment of any species of vertebrate fish or wildlife which interbreeds when mature."

To qualify as a distinct population segment, a Pacific salmon or steelhead population must be "substantially reproductively isolated from others in its species and represent an important component in the evolutionary legacy of the biological species." A population meeting these criteria is considered to be an Evolutionary Significant Unit (ESU) (56 FR 58612; November 20, 1991). For the purposes of the policy, a distinct population segment and an ESU are considered one and the same.

Based on current science which shows that hatchery fish have diminished fitness and survival relative to naturally spawned fish; have genetic deficiencies as a result of poor stock and rearing including inbreeding and selection; have a greater incidence of disease; and increased rates of competition with and predation on naturally spawned populations, hatchery fish populations should not be included as a component of the endangered and threatened natural population biological unit.

The purpose of the Endangered Species Act requires that ecosystems upon which species depend as well as the individual species be conserved. The Endangered Species Act also requires consideration of the best available scientific information. Introducing hatchery fish and subsequently including them in the definition of an ESU would institute a system whereby artificial fish propagation would run counter to the equally important intention of the Act to restore habitat. Current research shows that individual species benefit more from an ecosystem-based fishery management (EBFM) plan. (Pikitch et al, Ecosystem-Based Fishery Management. Science 2004; Vol 305, Issue 5682: 346-347.) Adding artificially bred populations of fish to streams does not substitute for the naturally spawning evolutionary legacy of our wild salmon populations.

The Endangered Species Act mandates that we conserve the habitat as well as the species. An ecosystem-based plan has scientifically shown to better support recovering natural populations. We encourage the National Marine Fisheries Service to remove hatchery fish populations from consideration when making listing determinations for naturally spawning Pacific salmon populations.

Therefore;
We urge the National Marine Fisheries Service to clarify the definition of an ESU addressing the issue of importance of captive bred and artificially propagated species to the evolutionary legacy of the natural species. Hatchery fish populations should not be included as a component of the endangered and threatened natural population biological unit.

We further believe artificially propagated hatchery fish will increase the extinction risk of naturally spawning salmon based on the phenotypic differences between the fish.

We recommend that emphasis be placed on recovering the habitat of naturally spawning Pacific salmon populations. Scientific research states that an ecosystem based plan benefits the recovery of species.