This proposal rests on insufficiently tested assumptions about the efficacy of carcass and carcass analog enrichment. Whether or not carcass analogs will provide the anticipated benefits awaits further field-testing, and the technology deserves a fair and thorough evaluation prior to widespread implementation. Most of the technical background section consists of verbatim quotations from existing reviews (e.g., Winter et al.) coupled with a lengthy response from Dr. Stockner to a set of questions. There was a very strong advocacy tone throughout the background section. However, little attention was given to those studies that have not demonstrated a sustained growth or survival response to carcass related nutrient enhancement in the Columbia River Basin (e.g., Pearsons et al. paper; S. Claeson, MS thesis at OSU). Nearly all of the case studies cited in the proposal have taken place in Alaska and British Columbia, and extension of those findings to the Columbia River Basin should not be assumed without careful research. It is quite possible that the proposed nutrient enhancement program might work, but the methods and technology have not matured nor have they been properly evaluated in this area.

The suggestion that hatchery fish treated with antibiotics or other chemicals can be used to produce carcass analogs that can be widely deployed will require careful evaluation by water quality agencies. The occurrence of unwanted antibiotics in public waters has become an important environmental concern.

The technical background section argued for a broad-scale nutrient enhancement program, but the real purpose of the proposal was to secure funding to develop a business plan to stop federal and state hatcheries from selling hatchery salmon carcasses to private buyers and instead form a regional cooperative that would pool fish from different locations and make the carcasses (or carcass analogs) available throughout the Pacific Northwest. This seems less like a science issue than a policy and economics question. The proposal argues that carcass additions are consistent with regional programs and subbasin plans, but the rationale for building a regional non-profit entity which would essentially broker carcass products to watershed councils and other enhancement groups is not explicitly related to those same programs. Would having such a non-profit entity make more carcasses available (what is the evidence for this)? Would it really be self-funding through food grade carcass and egg sales (what is the evidence for this)? The proposal lacks hard evidence that such an entity would be more efficient or more effective than existing arrangements.