Supervisory Fishery Biologist/Branch Chief Garth Griffin
Protected Resources Division, NOAA Fisheries
525 NE Oregon St. Suite 500
Portland, OR 97323

RE: My comments on Docket # 040525161-4161-01

Dear Chief Griffin,

I very strongly oppose the proposed hatchery policy and its application to 27 salmon and steelhead species in the West. Wild salmon are the key to the recovery of the species and the communities and economies that depend on them, but the new proposal would have devastating, long-term impacts on the future of wild salmon and steelhead and their habitat. The proposal defies the goal of restoring abundant, self-sustaining, and harvestable populations of wild salmon, which would provide valuable economic and recreational opportunities.

The Endangered Species Act was not intended to provide a means to conserve fish in concrete hatchery tanks. Rather, it was enacted to conserve threatened and endangered species and their ecosystems. Including hatchery fish in population counts of wild salmon and steelhead does not conserve those truly threatened and endangered species, but instead creates an incentive to continue harming the fragile ecosystems they depend on and to ignore much needed restoration efforts in those systems. Without good habitat, these species will face continued decline and possible extinction. This policy will accelerate that demise.

Your own scientists recommended that hatchery fish should not be treated the same as wild salmon because this could increase the risk of extinction for these species. Your agency has ignored your own panel of experts, including six of the world's leading ecologists, who warn that this policy could prove disastrous for wild salmon stocks.

The inclusion of hatchery fish will mask the ongoing declines of the wild fish by providing a false sense of security and recovery. Salmon and steelhead and their habitat cannot afford any more mismanagement. I urge you to withdraw your hatchery policy and propose that only wild salmon and steelhead and their habitat be protected under the Endangered Species Act.

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