143 



Th« Jfirat two critoria aco approprlata. Howavor, th« tiilrd 

 criterion dealing with uncertainty about the relationship between 

 artificially propagatad fiah and tha natural population is 

 inappropriate. Dnder such uncertainty, the E8A requires that a 

 conccrvativc cci«nfcifio approach be adopted that provides th« 

 "benefit of the doubt" to the affectGd apecics. To be Gan3i«t«nt 

 with how oaptlve propagation io troatod undar tha ESA., tha third 

 criterion should be deleted. ' ' 



The last step involves deciding whether to include th« 

 artiflciolly propagated eioh aa part of th« stock when listing it 

 under the ESA. V?hen a stock 1« listad, artificially prQpagat«d 

 fiah from that stock would be protected undar the ESA. Tr«atixtg 

 as not listed a portion of a stock that ia indiatlngulehable £roa 

 a listed stock is arbitrary and haa aignlficant iaplicationa Cor 

 other listed species. In addition, we do not agre« with tha 

 position in the Policy that decisions to exclude broo<lstock as 

 aenbers of listed stocks should be baaed solely on a 

 determination some time aJTter the listing decision that those 

 populations are not "judged essential for recovery." 



Under the third tenet, the Policy allows for th« propagation of 

 "a very few generations." The genetic effects of hatchery 

 selection could be substantially miniaized if artificial 

 propagation were lijnited to no more than one gen«ration. 

 However, we recognize that it nay be necessary to continue 

 propagation for longer periods where habitat constraints are 

 severe. More specific guidance concerning when r«covery of a 

 species has occurred would be useful. In addition, ret«ntion 

 tine of hatchery-reared salaon should be aa short as practical to 

 ensure achieven«nt of restoration goals. 



mie Policy also states that safeguards to protect fish from 

 mortality and catastrophic loss during artificial propagation 

 should receive high priority. . Such serfeguarda should be 

 required. 



«ie fourth tenet of the policy statement section raguixea 

 systeaatic monitoring and evaluation to d«t«rmine when artificial 

 propagation is 410 longer essential for raoovery and ehouXd be 

 terminated. We conctir in this general approach to a tixxlta 

 application of stocking. In a recovery strategy. In applying this 

 tenet, however. It is imp<^i:ant to recognise that stocking of 

 artifteiaJly propagated fiah aay oontinua tov y«arc, if not 

 decades. 



In addition, several factors (e.g. the realities of commercial, 

 cport, or Tribal -laxploi tuition espeaially of small popu.latj.ona, 

 limitations on managing a fishery once a population is delisted, 

 and y«ar claca w<)akneaeee} may irequir* eome captive propagation 

 beyond the initial recovery of a poptilation. 



