142 



li.">te<5 salmon populations. Thano potential rioka include 

 incrcaeod competition and predation, di8placem«nt of natural 

 fich, aluorad niigrator-y and apawning behavior, <m<l dia«Q«a 

 transfer. For example, the release of large niunbera of hatcliery 

 fich can alovato lovolc of competition for food, habitat or 



mates, and may lead to displacement of natural fish from th«ir 

 habitat. 



To minimize the riaks o£ artificial propagation, HMFS should 

 consider jointly developing minimum atamdarda for hatch«ry 

 operations that meet th« objoctivea of the Policy And uao the 

 best hatchery technologies available to reduce artificial 

 selection of genetic traits. Horeover, HKTS should cloxlfy the 

 role of captive broodstock programs in the preservation of 

 endangered and threatened fitih stocks and should eatabllsh a 

 protocol vrith critical thr«Eholda for taking any actions to 

 collect and maintain a C<iptlve bcoodstock. 



He are still very concerned about how HMFS intends to Inplcnent 

 its definition of a "species" as an "evolutionarily fiignificant 

 unit" (ESU) . There is considerable professional debate on the 

 West Coast concerning the number and significance of salmon ESU's 

 and the role of "hatchery stocks in salmon «nhancenent and 

 restoration. The second part of the definition reflecting th« 

 contribution to the biological species' evolutionary legacy is 

 nebulous and subjective. In practice, this concept cannot be 

 measured. The DOI has not been supportive of the concept in 

 earlier discussions - 



The document would be enhanced by inclnsion of citations to 

 relevant studies supporting the assertions on \rtiich the Policy is 

 based- This is aJ.so important because the ESA rajutres that the 

 best scientific information available be used as the basis for 

 resolving the issues this Policy addresses. On page 17574, the 

 reference in column 3 shotild indicate that the Snake River 

 sockeye salmon are listed as endangered rather than threatened. 



The first tenet in the policy statement section of the Policy 

 (page 17S74, column 3) establishea a three step deolslon process 

 for deciding whether to list axtifieially propagated Pacific 

 salmon. The' first step Involves identlfyixig stooks.at risk as 

 the basis for listing and other actions under the £SA. The 

 second step is to decide vhether artificially propagated fish are 

 part of that stock. Decisions tinder this second step are to be 

 based on three criteria specified in the first peiragraph, 

 column i, paga 1757S. 



