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Under Court Order in a lawsuit brought by PCFFA and others, on October 31, 2007, the Bush Administration finally issued its latest draft plan to avoid salmon extinctions in the once-mighty Columbia River. Unfortunately, the proposed new plan appears dead on arrival. There is little new in it, and in some ways it represents a retreat from measures that do work that are currently in place.
As a draft plan, it is also right now out for public comment. This is your chance to weigh in, in support of a much more aggressive salmon restoration effort than is being proposed – one that will actually address the devastating impacts of the Columbia River dams.
This is the fifth federal effort at crafting a legal and scientifically credible Columbia River Salmon Plan (or “Biological Opinion”). The worst plans are all from this current Administration, though it is not alone in its failures. All four previous plans went down in flames as failures in the Courts, and in the peer reviews of scientists, all the way back to 1993. In the meantime, things in the Columbia have only gotten worse for its beleaguered salmon runs, in spite of literally billions of dollars spent in patch-work tinkering around the edges of the problem – but never addressing the real problem of the federal power dams themselves, which are by far the largest impact.
Today, nearly every salmon stock in the Columbia and Snake River is now ESA listed, with the sole exception of the stocks that spawn in the Hanford Reach – the only undammed portion of the Columbia still left. Wild salmon populations in the Columbia are down to less than 10% of their historic numbers all across the board – with some once-abundant stocks in the Snake River down to mere dozens of adult spawners and termed “functionally extinct.”
More than 50 percent of the historic productivity of the Columbia River – once the largest salmon-producing river in the world – is now blocked by the Snake River Dams, even though they provide little economic benefit and little power. This is why so many fish scientists have said removal of the Snake River Dams is the best – and in the long-run the cheapest – recovery option.
Unfortunately, the Bush Administration just cannot seem to get it right. In May of 2003, when U.S. District Court Judge James Redden threw out the prior Columbia River salmon plan as “arbitrary and capricious,” he ordered the Bush Administration to redo it entirely. In response, in November 2004 (conveniently released just days after the last election), the Bush Administration proposed an even worse salmon plan than the one just tossed out.
The flaws of the final 2004 plan were many. First, the 2004 plan tried to slide around having to analyze the impacts of the Columbia River power dams on salmon entirely, using the slight-of-hand trick of simply reclassifying the dams as natural objects (i.e., “part of the environmental baseline”), as though they had been dropped there by Ice Age glaciers and not the Army Corps of Engineers.
Second, the Administration’s 2004 plan utterly abandoned any effort to actually recover ESA-listed salmon stocks. Instead, the Administration adopted a much lower standard of simply avoiding, through federal actions, making the stocks already headed for extinction get to extinction any faster – a “do no additional harm” standard instead of the recovery-based principle of stopping the harm you are already doing.
Third, the Bush Administration distorted the science (as it has often been accused of doing) by using only the most optimistic assumptions about the effectiveness of its protective measures. When most of these measures failed, there was no backup plan. And finally, the Bush Administration did not even push for funding of its own plan, dooming it to failure even on its good points.
The 2004 replacement plan (the fourth failed plan) made the Bush Administration a laughing stock among salmon scientists, and was again thrown out as “arbitrary and capricious” by Judge Redden in May 2005. Judge Redden then ordered the federal agencies to redo it once again – but this time under Court supervision and subject to periodic reporting, with strict deadlines and clearer instructions. In that ruling, Judge Redden also took partial control of the federal power system itself and ordered the federal agencies to guide more water through the spillways to flush juvenile salmon around the turbines rather than through them. Not surprisingly, more juvenile salmon survive to adulthood when they travel only through the river via “spill” (i.e., water going through the spillways) and not through the turbines.
Judge Redden also ordered the federal agencies to craft and release their fifth salmon plan by Oct. 31, 2007. This fifth plan is what is now out for public comment, which you can comment on by going to PCFFA’s Home Page (www.pcffa.org) or going directly to www.giveadamforsalmon.org. Here are some of the failures of this current plan.
This draft Columbia River salmon plan attempts to address the significant harm the Columbia federal power dams have caused to 13 Endangered Species Act (ESA)-listed salmon and steelhead runs in the basin. Unfortunately it fails to seriously consider the main reasons these stocks are endangered in the first place – the Columbia River hydropower dams. This is the same problem that caused the 2004 plan to fail.
Although federal agencies tout the new draft plan as offering 73 separate salmon protection measures, the actions called for by the plan are also almost indistinguishable from those proposed in 2000 and 2004 plans that were rejected by the Courts as inadequate. It includes almost no genuinely new measures; in fact, it allows for “rollbacks” of important protections now in place and will cost an additional $1 to 1.5 billion over the next ten years on measures that have never yet been shown to work.
While this “new” plan outlines relatively few changes from current salmon management obligations, and even rolls back important salmon protection measures like spill, it will still cost an additional $100-$150 million more per year than current operations. So in the end ratepayers and federal taxpayers would be spending more on a plan that actually does less for the salmon than previously.
In fact, merely one year of paying for this draft plan, which is uncertain to protect and restore Columbia-Snake River salmon, is equivalent to the one-time cost of removing the four lower Snake River dams -- an action the Western Division of the American Fisheries Society has said is “certain” to recover Snake River fish.
The 2007 draft Biological Opinion presents 73 separate actions, spanning the four areas known to harm salmon and steelhead in the Columbia-Snake Basin, the so-called “Four H’s,” as follows:
Hydropower Operations -- Hydro operations on the Columbia and Snake Rivers would, under the new draft plan, remain largely the same as what is currently in place. These are, however, the same hydropower dam impacts that led to the near extinction and ESA-listing of these stocks in the first place. Yet the draft plan barely acknowledges these impacts exist, and fails to deal with them by omission.
Six new actions, excluding new studies, are anticipated under the draft plan. At least three of them include efforts that would roll-back the practice of spilling water over the dams to provide more river flow for fish. “Spill” past the turbines is a proven way of helping young salmon migrate to sea more safely. Putting additional flows in the river is another tool that makes the system operate more like a river should, and thus helps reduce the amount of time young salmon must spend in warm, predator-filled slack water reservoirs. Yet this draft plan offers less of both in-stream flows and spill than past plans.
Also, the allowed “incidental take” of juvenile salmon in the turbines and in the slack water reservoirs behind the dams will still be at very high levels. In one instance, the “incidental take” allowed by the eight mainstem federal power dams combined could be as high as 93 percent. This gives a whole new meaning to the word “incidental” under the ESA, and is way too high to assure recovery – much less, to prevent extinction.
Habitat Actions -- Currently, federal agencies spend $36 million/year on specific habitat restoration projects. Under this draft plan, that level of spending will continue in 2008 and 2009. Starting in 2010, however, the federal agencies propose to increase habitat restoration and protection measures by an additional $9 million per year. Specific projects have not yet been identified for this spending increase.
Habitat restoration is much needed in the Columbia Basin, of course, but unfortunately much of what needs to be restored – such as lower river salt marshes where juvenile salmon live and grow as smolts in order to adapt to life at sea – cannot be restored through these programs. Other programs, such as the ongoing dredging and deepening of the Columbia River from Portland to the sea, actually work to undo these restoration projects.
Also, providing little bits of habitat restoration, while a good thing, can only take small bites out of the massive mortalities caused by the dams themselves. Habitat loss results in about 15 percent of all human-induced salmon mortality in the Columbia, while collective mortalities in the dams of more than 80 percent routinely occur. Habitat restoration cannot in itself reverse the extinction trend in the Columbia without addressing these much larger dam-related mortalities as well. But that is precisely what this draft plan fails to do.
Harvest Practices -- The draft plan does not affect the current level of harvest (i.e. tribal, sport or commercial fishing). Nor could further harvest restrictions make much difference to salmon survival in-river anyway, since harvest is now a very small impact compared to everything else.
In fact, all sport, Tribal and commercial fishing combined accounts for only about 5 percent of all human-induced mortalities on Columbia River stocks. All the rest is caused by the dams (80 percent) or by habitat loss (15 percent).
Hatchery Reforms -- The draft 2007 plan allows for generally the same hatchery practices that have been in place in the Basin since the 2004 BiOp. Of the four items that might be considered “new” in this area, the most noteworthy is an effort to significantly expand the Snake River sockeye hatchery program to release up to 1 million juvenile salmon into the river annually.
Increasing hatchery stocks, however, can not make up for the losses of the wild salmon populations and blockage of wild spawning and rearing habitat. Even hatchery fish die in the river when the river is too stressed, and it is the wild fish that are the best survivors.
Reporting Requirements -- In addition to specific actions, the draft plan establishes an annual reporting process where the federal agencies must report on their progress toward implementing the 73 actions. NMFS will also produce two “check-in” reports to determine whether the implementation of the draft plan is having the intended impact on imperiled salmon. Those check-ins are scheduled for 2012 and 2015.
Climate Change Assumptions -- The federal agencies assume that climate conditions in future years will be no different than they have been over the last 22 years. In other words, they completely ignore the overwhelming evidence that the Northwest is getting dryer and will have less snowpacks in the future.
Biased Federal Analytical Framework Used -- NMFS has put together an analytical framework that asks three basic questions about salmon survival and uses several quantitative metrics -- in addition to qualitative considerations -- to answer those questions.
Whether NMFS will be asking the right questions is debatable. For instance, little effort will be made to assess the impacts of the dams, as those impacts are largely assumed to be unchangeable. This is little more than what NMFS did in 2004 to assume the dams away by classing them as part of the “environmental baseline.”
The salmon fishing industry has five basic concerns associated with the draft plan:
1. The Draft Plan Rolls Back Current Salmon Protections -- Although the federal agencies tout 73 separate actions in the plan, few of these actions are actually new. Indeed, the vast majority of the actions identified are actions that have been in place for years, and have proven insufficient.
Furthermore, several key salmon protection measures (e.g., water spilled at the dams and additional river flow) are scheduled to be either greatly scaled back or eliminated from this plan. Doing less for these increasingly imperiled fish defies common sense and does not meet the spirit or letter of the ESA.
2. The Draft Plan Ignores Climate Change Science -- The federal agencies assume that the climate conditions in the Northwest will get no worse than the conditions experienced in the late 20th century. Instead, NMFS’ analysis should reflect the scientific consensus that warmer, drier climate conditions will likely make things worse for Northwest salmon -- and then make decisions appropriately.
3. The Draft Plan Ignores the Best Available Salmon Science -- At least three significant pieces of salmon science are ignored in this draft plan. First, NMFS completely ignores the one option that federal, Tribal, and state fisheries biologists have determined is the surest way to protect and restore Snake River salmon and steelhead – removing the four lower Snake River dams. While dam removal is not a silver bullet for all imperiled runs in the Basin, it is a key measure that any science-based salmon plan must at least analyze.
Second, the plan’s only non-study action to assist endangered Snake River sockeye is to produce more juvenile sockeye in a hatchery and release them into the river. Long-term reliance on this so-called captive broodstock program has received significant criticism from both the Courts and scientists -- with mounting scientific consensus that such life-support hatcheries cannot succeed without addressing the problems that led to the decline of the fish in the first place. Unless conditions in the river are improved, whether the fish come from the wild or come from hatcheries, they will still die in the reservoirs and in turbines at the dams.
Finally, the draft Columbia River salmon plan ignores the best available salmon science by reducing levels of spill and river flow for salmon currently in place under court order. NMFS must follow the science, not politics, when it finalizes this plan.
4. The Draft Plan Uses a Faulty Analytical Framework -- The federal courts rejected the 2004 BiOp in part because it relied on a framework that found that the federal dams were immutable parts of the environment. While the 2007 draft plan claims it takes a new and different analytical approach, the result is the same – and it leaves these fish at a high risk of extinction for the foreseeable future.
The various “metrics” included in the draft plan also allow the agency to choose whichever metric gives it the best shot at justifying the ineffective status quo. Instead of letting the science determine the outcome, in several places NMFS simply picks the metric that will best show it to be achieving specific results to a pre-determined outcome.
5. The Draft Plan Offers Less Protection for More Money -- In the end, this plan will be very expensive for very little return because it will not address the main problem for salmon in the Columbia – the Snake River dams. It simply perpetuates the stance the Bush Administration has always taken to keep the dams in place regardless of impacts or alternatives that make more sense. This is the major flaw which has resulted in all its prior plans being thrown out of court.
The most cost-effective and the best biological alternative still remains the removal of the four lower Snake River dams. In the end, it would be far cheaper for taxpayers and power customers to simply remove these four dams than to just keep throwing more money down the same rat hole of ineffective alternatives.
The draft plan has not been finalized, and there is still time to register your comments. However, the “official” deadline for those comments is December 14th, 2007. If you cannot make that deadline, however, send your comments anyway, as the deadlines are flexible and all comments will have an impact.
To make comments you can go to: www.giveadamforsalmon.org.
You can also make comments by going to the PCFFA web site at: www.pcffa.org. A two-page Fact Sheet containing most of the information above is also downloadable from the PCFFA Home Page, as well as a link to this Article.
Comments may also be submitted directly in writing to FCRPS Biop Comments, National Marine Fisheries Service (NMFS) Portland Office, 1201 NE Lloyd Blvd, Suite 1100, Portland, OR 97232; or by e-mail to: Draft.FCRPS@noaa.gov.
Above all – send your comments. Do your part to discredit the NMFS Draft Plan, and force the federal agencies to improve it in response to your comments, or face yet another defeat in Federal Court.
If this fifth Columbia River Salmon Plan also fails, the loss of yet more of the Columbia’s already seriously depressed salmon populations will only lead to more lost jobs and more lost fishing opportunities. Already the declines in the Columbia have cost the regional economy at least $500 million a year and 25,000 jobs.
However, a good Salmon Plan will bring those jobs back. Even further depletion of what was once the most abundant salmon river system in the world – the Columbia – is unthinkable. Failure is only going to lead to our own extinction as an industry.
As Gandhi once said: “It may seem a small and insignificant thing that you are asked to do, but it is vitally important that you actually do it!” So do your bit today!
Glen H. Spain is the Northwest Regional Director for the Pacific Coast Federation of Fishermen’s Associations (PCFFA), the west coast’s largest organization of commercial fishing families. He can be reached at the PCFFA Northwest Office at PO Box 11170, Eugene, OR 97440-3370, (541)689-2000, or by email to: fish1ifr@aol.com. PCFFA’s Home Page is at: www.pcffa.org.