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ansvers to r.p^.t-.iric questions. The NMFS ahould scliedule a 

 meeting of all affected parties as scxin as possible to provide a 

 foriun to discuss tho inplicationo of the Policy and to resolve 

 problems identified. 



In our view, tfle NMFS Policy affects many DOI salnon propagation 

 and restoration, prograaa on the West Coast. The DOI has several 

 broad concerns over the implications the Policy has for these 

 programs. These general concerns eunuaarlzed below more 

 appropriately should be subject to an interagency discussion. 

 The EncloGura provides more detailed comnents about the Policy, 

 and identifies implications that go beyond Pacific salmon. 



Recovery of listed species should be approached from an ecosystem 

 oerEpective, allowing flocibillty in artificial production in 

 case measures to address habitat, hydropower, and harvest impacts 

 do not vork cs pieutneC. By focusing nzirrowly on. hatchery issues, 

 to the neglect of habitat, harvest, and hydropower Impacts, the 

 Policy might be viewed as another step in a piecemeal approach to 

 the consulta^ion process. Earlier this year Judge Harsh 

 disraiaseO a Sierra -Club lawsuit that challenged the adequacy of 

 the consultation process under the ESA, largely because of the 

 FeUerdl Government's commitment to take a comprehensive approach 

 in futiure consultations. 



More than 30 Tribal governments have trust, treaty, and, other 

 interests in Pacific salmon. The four Columbia River treaty 

 fishing Tribes have established a contlnuin?r dialogue vith KHFS 

 relative to recovery planning. The 20 Boldt Case Area Tribes 

 conduct artificial propagation operations at approidjaatoly so 

 fish hatcheries and rearing facilities, and release 40-50 million 

 salmon and steel head into western Washington watora annually. 

 These hatcheries serve a variety of purposes including mitigation 

 for lost production due to habitat lose, cnhancoa^it of depressed 

 stocks, and. augmentation of fisheries in helping to meet Indian 

 treaty rights. Releases from Tribal hatchoriee benefit 

 commercial and sport fisheries in the United States and Canada, 

 and returning spawners help witisfy Tribal economic, euhslstence 

 and ceremonial needs. These Tribes generally believe" the draft 

 policy reflects a negatlvA bias towards artificial production, ' 

 and are concerned about the complex harvest sharing arrangements 

 under the United Sta'te.'^/Canada Paoifio Salmon Treaty, an<J on 

 associated future run strci>gths and treaty harvest opportunities. 



In view of the Federal Government's trufit responsibilities, self- 

 determination policies and govcnunent-to— govemmeht relationship 

 with Indian Tribes, and in consideration of Tribal roles and 

 responsibilities as co-mar.agcrs of tho Pacific ealtaon resoxirce, 

 and the potential impacts of airtif iclal propagation policy, on the 

 future eKercise of Indian r-ighte, ve believe it is critical that 

 the views of Tribal governraents be factored into the rulemaking •■ 

 process. Thi.-^ is espooiaily important since eome Tribes, not 



