NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


										


		


April 7, 1998





Robert Koch


Protected Resources Division, F/NW03


National Marine Fisheries Service


525 NE Oregon Street, Suite 500


Portland, Oregon 97232





RE:  Section 10 Permit Application # 1129 (Tucannon Hatchery)





Dear Mr. Koch:





	Thank you for providing the Native Fish Society with the opportunity to 


comment on the Section 10 permit application #1129 for the Tucannon Hatchery.  


We have the following comments regarding that permit application:





Spring chinook:


1.	The Section 10 permit #1129 for Tucannon Hatchery spring chinook 


should be based on having the hatchery product conform to the life history and 


fitness of the wild spring chinook native to the Tucannon Basin.  Under the 


previous permit, this was not accomplished and the hatchery product has diverged 


from the wild salmon in age structure, spawning distribution, fecundity and smolt 


to adult survival.  If the hatchery is to be used to recover a listed species, 


divergence in life history traits that affect utilization of available habitat and fitness 


of the hatchery product compared to the donor wild population, must be avoided.  


Under previous Section 10 permits, the hatchery fish diverged from the wild donor 


population, creating a situation where the hatchery is contributing to the loss of the 


wild spring chinook population.  





2.	It is firmly held by the applicant that hatchery supplementation is needed 


to prevent demographic extinction of wild spring chinook.  But this cannot be 


justified, based on the information contained in the permit application.  For 


example the recent decline (1994-1996) shows that both hatchery and wild spring 


chinook declined, the hatchery was unable to overcome  factors limiting the 


productivity of the altered natural system throughout the life cycle of the fish, and 


the hatchery population is replacing the natural population in terms of abundance.  


The result may be that the wild spring chinook is driven into extinction (partially 


due to hatchery practices) and is replaced by a hatchery spring chinook that has 


diverged in important life history characteristics from the wild population.  This 


kind of recovery effort, sanctioned by NMFS, is not consistent with the 


Endangered Species Act.





3.	The purpose of actions to recover a species under the ESA is to recover 


natural populations in their natural habitats.  If the domestication trend for the 


Tucannon River spring chinook continues as it has, the wild salmon will be 


replaced with a less fit hatchery fish.





4.	The NMFS should establish strict operation protocols for this hatchery to 


control domestication selection in the hatchery environment.  The factors that have 


been identified are a top priority:  divergent age structure, lower fecundity, spawner 


distribution, and low smolt to adult survival.  





	Issuing a permit under Section 10 for the Tucannon Hatchery spring 


chinook program should be based on a set of standards and a hatchery operation 


plan that address the factors causing the hatchery chinook to diverge from the 


original wild population.  The NMFS should issue a conditional permit for a 


duration of only one year at which time the applicant would have to reapply.  Re-


application would be based on taking specific steps, proposed by NMFS, to control 


divergence in the hatchery chinook population.





Steelhead:


The permit application discusses steelhead, a species listed as threatened by NMFS 


in 1997, but the application does not propose any specific actions on steelhead.  If 


the applicant proposes to take steelhead, then a separate application should be 


prepared.  The applicant states on page 11 ãAt this time, the WDFW has no firm 


plans for initiating a hatchery supplementation program with locally adapted 


steelhead.ä  However, the WDFW should be required by NMFS to terminate 


releases of non-native steelhead in the Tucannon River and use the hatchery weir 


to trap all non-native spawners and remove them from the river.  	





Sincerely,








Bill M. Bakke, Director