Protection for Wild Salmon and Steelhead and their Habitat

Protection of sensitive species through listing under the Endangered Species Act (ESA) is an essential ingredient in most conservation strategies. Threatened populations of salmon, steelhead and trout would likely go extinct without ESA protection. In 2004, NMFS created controversy when it proposed revision of its 1993 Hatchery Policy, which excluded hatchery fish from decisions to list threatened and endangered stocks, and reconsidered the ESA listing status of 25 already listed salmon populations based upon the influence of hatchery fish.

Some policymakers and anti-ESA interests pushed NMFS to pull protection for the few naturally-spawning wild fish that remain based upon a  biologically wrong argument - that large numbers of artificially produced hatchery fish eliminated the need for listings.  Pacific Rivers Council was concerned that NMFS might decide to not list the wild fish on this basis. Although a "no list" decision for wild salmon would have been ludicrous in light of the facts about their imperiled status, the politics threatened to overshadow the facts.

Pacific Rivers Council has been determined to make sure the latest science about the role of hatchery fish is included in the ongoing debate. Our contract with modeling expert Gretchen Oosterhout, Ph.D. and aquatic ecologist Chuck Huntington addressed the question of how and whether hatchery fish contribute to the health of wild salmon populations. While numerous studies have shown the behavioral and genetic deficiencies of hatchery fish, little scientific work has investigated the actual biological contribution of hatchery fish to wild salmon populations.

Spawning Sockeye Salmon. Photo by Scott Church

The final report concludes that, even given ideal assumptions about hatchery management, hatchery fish cannot justifiably be considered a significant positive influence in population recovery of coho salmon. Instead, the quality and spatial distribution of freshwater habitat is the most critical variable (other than ocean conditions, which are beyond direct human control). This report is significant science that NMFS must consider when it evaluates the role of hatchery fish in salmon and steelhead recovery. The report has been updated to include more species, has been peer reviewed, and was printed in the Canadian Journal of Fisheries and Aquatic Sciences Volume 62 in 2005.  Click here to learn more about the report.  We submitted this hatchery report as part of the comment record on the hatchery policy (see below).

Despite the scientific evidence, the proposed federal "Hatchery Listing Policy" was released in May 2004, and it opened the door to political manipulation of the ESA and listing decisions for salmon and steelhead species. The policy required the agency to consider wild and hatchery fish together as one unit, and determine whether the unit as a whole required listing. However, NMFS proposed to extend protections provided by listing only to wild fish, and not hatchery fish. NMFS planned to base its listing proposals on this new policy.  Pacific Rivers Council carefully reviewed the policy and submitted extensive comments on the proposed hatchery policy in late 2004, as well as comments on the 4(d) rules that would extend protections only to wild fish. We also submitted a letter to ensure appropriate documentation was in the record for the proposed listings.

The final policy was released in 2005.  Click here to view our press release.  Fortunately, when NMFS made a final determination regarding the 25 listed salmon populations, most of the populations retained their protected status. However, NMFS did reduce protections for the Upper Columbia Steelhead population based upon the abundance of hatchery fish, changing the population’s status from endangered to threatened. 

As intervenors, PRC successfully defended in court NMFS's decision to retain existing ESA protections for 16 salmon stocks, despite an industry effort to push for delisting based upon the abundance of hatchery fish.  Unfortunately, despite our legal efforts, the 2005 Hatchery Policy remains in effect today, as does the downlisting of the Upper Columbia Steelhead.  The Hatchery Policy gives NMFS a great deal of discretion in making ESA listing decisions, but that also means it gives them the discretion to do the right thing, which is to focus on the protection and recovery of wild salmon and steelhead.  PRC will continue to advocate for this goal. 

View the current listing status of salmon, steelhead, and other aquatic species in the Northwest.