226 



DRAFT 



Wild fish that are allowed to move above hatcheries also act as reservoirs of infection 

 to fish reared in hatcheries. 



"...hatchery reliance on antibiotics may result in mutant strains of 

 pathogens. ..antibiotics may not eliminate infections in hatchery fish, but 

 merely maintain mortalities in the hatchery at an acceptable level. " 



Again, the authors report possible problems as events which "may" occur without any 

 substantiating evidence. 



Page 51, 1.3.8. Hatchery Production for Harvest 



There appears to be two different opinions in the fishery community as to the purpose 

 for hatchery fish production. One opinion considers that hatchery fish should only be 

 used to maintain native wild populations of anadromous salmonids and that fish 

 production should be dependent entirely on wild fish. 



The other opinion considers hatchery production for supplementation of fish to supply 

 both sport and commercial fisheries that could not exist if they had to depend solely 

 upon natural fish production. 



Both goals are correct for some streams but neither is appropriate in all situations. 

 Each is a management tool to be used in a specific instance to accomplish a specific 

 management goal. 



ENVIRONMENTAL FACTORS 



Section 2.1 Water Use 



Page 56, 2.1.3. Upstream Passage - Gross Habitat Area Losses 



"Estimates of Columbia Basin salmon and steelhead spawners based on 

 habitat availability before 1850 are 6.2 million salmon and 8.3 million 

 steelhead (NPPC, 1986).... At a 2:1 catch to escapement ratio, this is an 

 annual loss of 6.8 million salmon and 9.2 million steelhead to fisheries 

 on a sustained basis. " 



The total Columbia Basin losses cited from NPPC 1986 appears to be incorrect: the 

 authors cite a loss of 7.9 million salmon and steelhead. The loss of salmon and 

 steelhead estimated by NPPC above Bonneville is between 8 and 16 million fish 

 annually (NPPC 1987). The authors also incorrectly apply a catch/escapement ratio to 

 the NPPC data in order to estimate losses to fisheries. However, the NPPC data is a 

 total production estimate that includes harvest. 



A-20 



