Comment from Olson , Phillip

Re: NOAA-NMFS-2026-1585, Five Hatchery and Genetic Management Plans for the Puyallup River Basin I support approval of these Hatchery and Genetic Management Plans and appreciate the continued use of hatchery production to support fisheries, mitigation responsibilities, salmon recovery efforts, and Southern Resident Killer Whale prey objectives. However, I believe the Proposed Evaluation and Pending Determination leaves important questions unanswered regarding Chinook production capacity within the Puyallup Basin hatchery system. NOAA’s review identifies the primary purposes of these programs as providing fish for harvest, mitigating for historic losses of natural production, supporting treaty obligations, assisting recovery efforts, and providing prey for Southern Resident Killer Whales. NOAA also notes that the Puyallup Chinook population remains well below recovery objectives and that hatchery production plays a significant role in the basin. At the same time, NOAA’s review references substantial hatchery infrastructure improvements at Clarks Creek Hatchery and Voights Creek Hatchery, including new raceways and expanded rearing facilities. The review does not explain whether these facilities are currently operating at production capacity, whether additional Chinook production was evaluated, or what constraints prevent further increases in production. Before making a final determination, NOAA should disclose: • The maximum Chinook production capacity of Clarks Creek and Voights Creek Hatcheries. • Whether the recent hatchery expansions were intended to increase Chinook production capacity. • Whether additional Chinook production was evaluated during development of these HGMPs. • Any biological, ecological, operational, water supply, broodstock, or ESA-related constraints that limit additional Chinook production. • The estimated adult return benefits associated with potential increases in hatchery Chinook production. Because these programs are intended to provide fish for harvest, support mitigation responsibilities, and contribute to Southern Resident Killer Whale prey availability, the public deserves a clear explanation of whether existing hatchery infrastructure is being fully utilized and whether opportunities exist to increase Chinook abundance while remaining consistent with ESA requirements. I encourage NOAA to provide this analysis as part of the final decision record and to evaluate whether additional Chinook production can be achieved without appreciably reducing the likelihood of survival and recovery of ESA-listed populations. Thank you for the opportunity to comment.