144 



Subatajitial elaboration of the parenthetical refaranca to 

 directed take in the fifth tenet of the policy atatement section 

 is nacassary to ensure offactiva recovarv efforts. This would 

 also minimize disruption of aurtificial propagation activities in 

 support of other fiKhary refiponsibiliti«s. The FMS'a experience 

 supports the experinental use of cuppleaantation or outpleuiting 

 AC a pot<>nt5ally effective fishery resourc* rootoration 

 technique. However, it is not perfected so a fall-back strategy 

 would ba osconci&l to ancur« p«rp«tuation of the otoakjs involv«d 

 until sufficient natural production is re-«atabliahed. 

 Maintaining raturne directly to fish hataheries would be 

 required, at least on an interim baa is, to guarantee a. source of 

 broodstock for sustaining the qrenetio intogrlty of th.e at:ocko 

 involved- Aleo, recovery would b« accelGrated and th« 

 fulfillment of compatible fichery r-esponaiblliti«a would b<s 

 facilitated. This requirement to intentionally take listed fish 

 ' at hatahcrico or other £ocilitlea for br-oodatock ohouXd ba 



explicitly authorized in the Policy. Since the principle focufi 

 is on the use of artificial propagation for recovery, addreasing 

 this issue under the third tenet nay be. more appropriat*. 



Also, under the fifth tenet, the Policy Indicates that stock 

 transfer of unliated species should be "avoided." Stock 

 transfers may need to be prohibited unless ther« is a clear 

 determination that there will be no impacts to listed or "at 

 risk" species. 



Implica tions beyond Pacific salmon 



We are concerned about the broader Implicationa of th« ESU and 

 the definition of "si>ecies« under the ESA applied to Pacific 

 salmon in the Policy- The FWS has yet to finaliz* its policy oh 

 the definition of species (i.e., vertebrate population*). £ence, 

 it is tmclear whether the HMFS definition of apeci«s will be 

 consistent with the FWS definition. The two agencies need to 

 coordinate finalizing definitions that are, if not identical, at 

 least conpatible, prior to impleaentation of the Policy. 



If extended beyond Pacific salmon, the concepts and principles 

 embodied in the Policy could establish precedents for captive 

 propagation programs for fish other than Pacific •almon under the 

 ESA and for other ptsrposes. Currently FWS .propagates several 

 species of sturgeon and desert fishes that ar« listed aa veil as 

 Atlantic salmon. Major problems would be encountered in aRJiying 

 this Policy to these species since very few natxiral populations 

 exist and they tend to involve small ntimbera of individuals. 



