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Glen Spain, PCFFA NW Regional Director
The political fix appears to be in, and once more commercial fishermen are getting the short end of the deal. In a stark break with past federal administrations and the prevailing science, on 9 September the federal government formally proposed a new Columbia River Salmon Plan and NMFS Biological Opinion (BiOp) that: 1) avoids any major modifications to the Columbia River hydropower dams; 2) entirely ignores the impact of the dams themselves on salmon; 3) eliminates any discussion of decommissioning Snake River dams (among the worst for salmon as well as the least cost-effective dams), and; 4) declares there is “no jeopardy” from hydropower operations to the numerous salmon and steelhead runs in the Columbia-Snake River system already listed as threatened or endangered, in effect shifting the conservation burden to the backs of fishermen in order to keep the dams intact.
The Columbia and Snake River salmon runs have been in trouble for decades, with nearly all of them now listed under the federal Endangered Species Act (ESA). These runs were once the most abundant in the world, but salmon declines in the Columbia have accelerated to the point where today nearly every mile of the Columbia River is impacted by dams. Wild salmon runs from the Columbia River, once 10-16 million strong, have been reduced to only about 2-3 percent of those numbers today (less than 400,000 wild fish).
Even recent so-called “strong” returns are mostly hatchery fish, not wild, and still only amount to an upward blip of only a few percent of historic numbers. Nearly half of this historical production was in the Snake River, now most of it lost behind the four lower Snake River dams – dams which even the Corps of Engineers originally said should never be built, and which have devastated incredibly valuable west coast salmon runs.
The west coast salmon fleet once freely ranged the coasts from mid-April until at least the end of September. Unfortunately, those kinds of seasons are no more. Conservation measures necessary to protect weakened Snake River fall chinook increasingly constrain salmon fishing all the way south to below San Francisco. Columbia-driven fishing constraints have also hit the Southeast Alaska salmon fishery hard, with severe closures in some past years. Columbia Basin-origin salmon harvested in Southeast Alaska still account for as much as 30 percent of the total salmon harvest in that region. Washington State has also been particularly hard hit. In 1994, 1995 and 1996 there was no non-treaty troll season at all on the Washington coast, since this fishery depends in part on a mix of Columbia and Snake River stocks, and only a short spring fishery in the years 1997 and 1998. These constraints, made necessary by the continuing destruction of these Columbia-Snake River runs from loss of habitat and loss of river flows, have cost our entire west coast salmon fleet much of its economic viability.
Fishermen today have a hard time even visualizing how much of the salmon resource we have lost. Historically, the Columbia Basin produced an escapement estimated at 11 to 16 million adult salmon each year, with an average of 13.5 millions adults. Past federal administrations have been much more honest about what the loss of these fisheries has meant to the Northwest economy. The total personal income impacts value of these historic runs, assuming a 50 percent harvest rate, was conservatively estimated as part of the analyses associated with the 2000 Federal Columbia River Power System (FCRPS) Biological Opinion at approximately $500 million/year. This bounty could have supported as many as 25,000 family wage, fishing-based jobs, added to the economies of communities all the way from Central California to Southeast Alaska. However, during the 1990s, the economic value of Columbia-based salmon fisheries dropped to as low as $2 million, only slightly improved today. The difference between those two numbers -- nearly $500 million/year and 25,000 jobs -- is what the industrialization of the Columbia River has truly cost our industry, our fishing communities and the Northwest and Southeast Alaska economies.
The Columbia River declines are also everybody’s problem, causing closures and restrictions all up and down the coast. As we discussed in our July Fishermen’s News article, “Why the Columbia River Matters to West Coast Fishermen,” (www.pcffa.org/fn-jul04.htm), Columbia dam-driven declines of salmon have affected nearly every salmon port on the west coast, and unfortunately will continue to do so until problems with the Columbia River dams are truly addressed.
However, no fishery has been as hard hit as the once prosperous Lower Columbia gillnet fleet. The five year annual average of salmon landings in the Columbia River gillnet harvest for the time period 1920-25, for instance, was 29,771 pounds. By 1994 it was down to a mere 25.2 pounds (a whopping 99.999 percent loss), reflecting a “season” only open for a few hours. Though slightly improved since, thanks to better ocean conditions, no industry can survive intact with that kind of instability. Since the 1920’s the once booming fishing industry in the Port of Astoria has collapsed almost entirely, and the number of fish processors in Astoria has gone from more than two dozen to one, that one working only part time, and getting most of its product from outside the region. The impact on that community, of course, has been reflected in massive unemployment, stressed social services, an abandoned city center, massive population out-migration and devastated fishing families – problems we all know far too well.
For months the National Marine Fisheries Services (NMFS) and other federal agencies have been under a court order to rewrite their 2000 Salmon Plan. Much of that plan was invalidated as “arbitrary and capricious” in a 7 May 2003 ruling by Federal Judge James A. Redden in the case National Wildlife Federation, et al.,vs. NMFS (USDC OR, Case No. CR01-640-RE). Both IFR and PCFFA are co-plaintiffs in that case, as is PCFFA member association Salmon for All. The agencies also ran afoul of the law when they attempted to curtail “spill” at the dams (i.e., waters released over spillways to guide juvenile salmon around the turbines). Summer spill was legally required under the 2000 Plan as an obvious way to decrease turbine-related mortality, but is opposed by the Bonneville Power Administration (BPA), which wants to use more trapping and hauling as a “cheaper” alternative, using the “saved” water for power generation, even though curtailing the spill program would result in tens of thousands of additional adult fish deaths and just add to already major economic losses to downriver and coastal fishing communities. So far the federal courts have seen through that ruse and prevented the cancellation of what most biologists believe to be an effective salmon protection measure.
When the Court ordered the agencies to rewrite the 2000 salmon plan, the hope was that the next version would be better than its predecessor. Unfortunately, politics has interceded. The end result is more an election year political ploy to garner eastern Washington and Idaho votes than a scientifically valid plan.
Ignoring the science, the Administration has simply categorically ruled out major modifications to the Columbia River dams, regardless of their impact on salmon. In order to justify this position, the current party line is that rivers with dams and devastated salmon runs, not an undammed river with healthy salmon runs, will for the first time be the new “environmental baseline” by which all other actions are measured. It is as though the dams were something dropped in the river by Ice Age glaciers, and not by the U.S. Army Corps of Engineers.
This analytical slight-of-hand allows the agencies for the first time to utterly ignore the fact that the dams continue to push salmon toward extinction, and to analyze instead only very minor tweaking of a failing system. It’s reasoning is that it cannot (or more correctly, will not) change the dams, says the Bush Administration, and thus it can legally ignore their impacts. This is circular reasoning of the worst sort, as well as a disservice to the region.
Yet just four years ago, under the prior plan, the same federal agencies responsible for enforcing the ESA had said, “Breaching the four lower Snake River dams would provide more certainty of long-term salmon survival and recovery than would other measures.” The US Environmental Protection Agency (EPA) also stated that the Snake River Dams could not, under their current configuration, meet Clean Water Act requirements for salmon recovery. Several studies since have shown that the Snake River dams could be decommissioned and all their benefits cost effectively replaced, while recovering economically valuable salmon runs. But now, according to Bob Lohn, NMFS Northwest Regional Director, and a former BPA official, “recovery can be achieved without removing dams.”
Many of the same problems identified by Judge Redden as flaws in the 2000 Plan remain in the new draft BiOp, though in disguised form. The new plan also raises additional new problems, including the following:
Depleted Runs as the New “Environmental Baseline”: As discussed above, for the first time the existence of the dams as they are currently operated is considered the God-given “environmental baseline” against which all other options are measured. The Administration gets there by using the theory that changes in the configuration of the dams are beyond the discretion of the agencies to make – a fact that conveniently ignores the fact that these same agencies built the dams to begin with, and that they are an artificial barrier to salmon production with real and ongoing economic impacts.
Ignoring Current Dam Impacts: Setting the baseline artificially low to begin with also allows the agencies to entirely ignore current dam impacts, including the fact ESA-listed salmon runs are still not recovering and the dams are responsible for their demise. Thus the new NMFS BiOp does not even begin to analyze the true impact of the dams, which cause upwards of 85 percent of all human induced salmon mortality in the Columbia (as compared to about 5 percent by all commercial, sport and Tribal fishing combined). By simply assuming dam operations today as the immutable environmental baseline, these impacts are simply ignored, even though these are the very impacts that drove nearly every Columbia River run onto the endangered species list in the first place.
This is nothing more than a slight of hand card trick. Once you assume all the damage to date as the unchangeable norm, then comparisons throughout the draft BiOp become between the dams as they exist today (the “reference operation”), versus the dams plus some minor additional remedial actions -- a situation virtually guaranteeing that otherwise minor remedial measures show up as a positive impact and put the Administration the best possible light politically, while ignoring the real problems.
Lowered Standards Mean No Recovery, Only Status Quo. Throughout the draft Plan, NMFS has likewise abandoned its prior recovery standard, setting the bar much lower at merely continued existence (i.e., basest non-extinction) – in other words, a goal effectively only of “not making it worse.” However this is a far cry from making it any better or achieving anything that could be called recovery, as mandated by the ESA.
A “recovery standard” goal would require much more benefit from the proposed operations of the hydropower system than could ever be shown from NMFS’s current biased analysis. Only by shifting the bar far downward (plus ignoring current dam impacts altogether) was NMFS able with a straight face to present the plan as “non-jeopardy.”
However, this last bit of slight-of-hand is of questionable legality. Recent U.S. Ninth Circuit Court of Appeals rulings have stated that recovery standards must be applied in Biological Opinions, not mere non-jeopardy. Not surprisingly, there are rumors of an effort sponsored by the Administration to overturn these cases by “riders” in the Interior Appropriations bill. If so, this would mark a formal Administration abandonment of recovery as a goal of the Endangered Species Act, not just in this draft salmon plan, but nationwide.
Taking Credit for Mother Nature’s Good Works. The Bush Administration is likewise taking credit for recent run improvements nearly all attributable to extremely good oceanic conditions rather than any actions by the Administration. This is because it takes chinook and most other salmon an average of four years to go from egg to adult spawner.
However, the Bush Administration came into office less than four years ago, and most elements of the current salmon plan have been in play for only a year or two. Only extremely favorable ocean conditions could have been the cause of most of the recent run size improvements, not any of these imposed protection measures. Yet the Administration is, in effect, declaring victory as a result of recent favorable, but unfortunately very transient as well as highly unusual, ocean conditions. Stressing salmon runs to the maximum during the best of times is a recipe for disaster come the next major El Niño or drought.
Selective Use of Statistics to Mislead: NMFS’s selective use of statistics in the draft Plan seems intentionally designed to make the Administration look better, but gives a very false picture. Calculation of recent run “improvements” looks good only if you do not use data dating back before 1994. This is because from 1994 to the present, ocean conditions were improving, resulting in better ocean survival rates and higher returns that had little to do with dam operations.
Using a baseline back to 1980 or earlier, however, would show a deep dip as these runs spiraled toward extinction during times of poor oceans conditions, and would force the Administration to take a much more precautionary approach. Using a longer time frame also puts the recent “high runs” into perspective as only a very small fraction of historic run size, with far to go before any real recovery.
Agency “Best Judgment” Substituted for Rigorous Scientific Analysis: Throughout the draft, NMFS substitutes its own “best judgment” for rigorous, measurable scientific analysis. In other words, the fishery agency uses guesswork and judgment calls instead of relying on the vast body of scientific literature available to it. Many of its judgment calls are speculative, however, some are contradicted by the science, and several are based on highly optimistic assumptions (such as continued good ocean conditions) that have little justification and are likely to be flat out wrong.
Flexibility to Lessen Salmon Protections Whenever Convenient: The Draft BiOp also contains a “flexibility provision” that would allow NMFS to terminate any protective measure whenever it finds equal or more fish benefit from alternative measures that are less costly, but without any independent analysis.
NMFS would have sole discretion over how this loophole would be used, and apparently intends to use that discretion to curtail summer spills (getting around the current court order) and to rely much more heavily on a trap and haul program that has never proven successful as a recovery strategy.
Yet More Reliance on Non-Dam Measures: Since NMFS has pre-emptively ruled major changes in the dams as out of the question, this leaves only habitat restoration, predator control, trap and haul barging and trucking of salmon and other non-dam measures to rely upon to improve conditions for salmon within the river. In other words, NMFS will ignore up to 85 percent of the salmon mortality (i.e., mortality by or related to the dams) and instead seek to squeeze out enough benefit from the remaining 15 percent to make a difference between extinction and survival. Not only is this unlikely, even if successful this still fails to address the major impacts – the dams themselves.
Fishermen to Carry the Conservation Burden: Even though all sport, commercial and Tribal fishing impacts combined are much smaller than impacts from the dams (about 5 percent as compared to 85 percent), under this draft plan, conservation constraints on the fishing industry to avoid ESA listed stocks would remain in place or be further tightened in order to compensate for allowed salmon losses in the dams.
Columbia River-driven fishing constraints have already cost the west coast fishing industry hundreds of millions to billions of dollars in lost fishing opportunities on otherwise healthy stocks whenever and wherever depressed Columbia River stocks intermingle, restrictions required by “weak stock management” under the Magnuson-Stevens Act. Salmon fisheries all the way south to San Francisco and Southeast Alaska are affected by these weakest stocks. Under this draft Plan, fishing communities would continue to be sacrificed so these dams can remain as they are. Major closures up and down the coast and well into Southeast Alaska will be the price our industry has to pay for keeping fish-killing dams untouched.
Taken together, these changes to the framework and analysis of the new salmon plan are a huge departure from the previous Columbia River Salmon Plans and from the manner in which the federal government has interpreted its obligations under the ESA for the last 30 years. Unfortunately, this is yet another example of the Bush Administration’s abandonment of both sound science and the commercial fishing industry.
You should not be shy about letting the federal government know that they need to do better than this deeply flawed plan. Follow the instructions in the clip out box for how to find out more about the plan, and to comment either in writing or electronically.
The voice of the fishing industry is important. Make sure it is heard. Let people know how Columbia and Snake River salmon declines have affected fishing industry livelihoods and communities from California to Alaska. As America’s oldest industry, we deserve better from this Administration. Let’s demand that the federal agencies who got us into this mess move forward on fair, effective and lasting solutions, not political fixes that ultimately leave our fleets without fish and our communities without jobs.
Here are some specific things you can do to help work for a Columbia and Snake River salmon recovery plan that improves coastal fishing opportunities, and which rebuilds the future for salmon fishing dependent communities that need abundant, healthy and harvestable salmon populations from the Columbia Basin:
Glen Spain is the Northwest Regional Director of the Pacific Coast Federation of Fishermen’s Associations (PCFFA), the west coast’s largest organization of commercial fishing families, and has been working for more than 17 years on west coast salmon protection issues. The PCFFA Northwest Regional Office can be reached at: PO Box 11170, Eugene, OR 97440-3370, by email to: fish1ifr@aol.com or by phone to (541)689-2000. PCFFA’s web site is at: www.pcffa.org.