Obama Administration's Science Checklist for the Columbia & Snake Rivers Salmon Plan
If you had the opportunity to chart a new and prosperous course for wild salmon, Northwest communities, and American taxpayers, would you take it?
For the better part of two decades now, the federal government has answered that question with a "No". It has repeatedly failed to do what is necessary to recover imperiled salmon in the Columbia-Snake River Basin. The last two administrations have avoided making the right choices for salmon and salmon-based communities, harming both fish and people along the way.
Today, the Obama administration is on the cusp of deciding whether it will opt to craft a new, lawful, science-based plan or stick with the current federal salmon plan, a plan that it inherited from the Bush administration. If President Obama’s Commerce Department is serious about salmon recovery, here are the Top 10 actions it must take to repair the deeply flawed Bush plan in order to restore salmon and meet the needs of the people of the Northwest and nation.
The Salmon Plan should include these actions:
#1 Prepare for Lower Snake River Dam Removal – Thousands of scientists have supported a call for removal of the four lower Snake River dams. In 2000, the Clinton administration identified lower Snake River dam removal as the surest and best way to ensure the survival and recovery of Snake River salmon and steelhead. The Obama administration should move forward today to seek Congressional authorization for dam removal, commence the engineering and economic studies for dam removal, bring stakeholders together to address any impacts of dam removal, and be ready to implement that action within the next five years unless salmon and steelhead are exceeding specific biologically-based performance standards (see below). It is an unacceptable risk to salmon — and to salmon-related jobs up and down the West Coast — to continue to avoid an action that the science so clearly says is necessary to protect and restore these fish. Removing the four lower Snake dams is the quickest way to bring back the salmon, salmon jobs and salmon dollars that have been lost in the last several decades.
#2 Create Salmon Standards that Measure Real Progress – Current “performance standards” in the 2008 salmon plan are set at levels that the federal agencies’ own 2005 progress report says they are already meeting — meaning that under these standards, salmon are already saved even at their current very low numbers. This “lowest common denominator” approach is obviously not enough to restore salmon and steelhead throughout the Columbia-Snake River Basin. We need to set biological performance standards that mean something and will actually require greater salmon survival at the dams and elsewhere, not the same or less. If salmon populations were exceeding adequate scientific standards, removal of the Snake River dams might not be necessary. Without such rigorous standards, however, the plan is inadequate both legally and for the future existence of salmon.
#3 Increase Spring and Summer Spill Over the Dams – Spilling water over the dams is the safest means of getting young salmon past the dams and out to the ocean. The 2008 Bush salmon plan rolls back court-ordered spill in both the spring and summer even though this spill has resulted in the highest in-river survival levels the region has seen since we began to document such results. A new and improved salmon plan from the Obama administration would increase both spring and summer spill above court-ordered levels to help restore more natural river conditions and increase salmon survival. In addition, the plan should include provisions to work with the State of Washington to better protect salmon by increasing the Total Dissolved Gas limits in the state’s water quality standards to the levels set by the State of Oregon. Setting this more salmon-friendly standard is actually legally required and will ensure more spill to help salmon move through the gauntlet of dams more safely. This is one of the most important steps we can take immediately to keep salmon in our rivers and oceans and fishermen at work.
#4 Increase River Flows in the Snake & Columbia Rivers — An Obama salmon plan should follow the Court’s advice and secure more water from the upper Columbia and upper Snake River Basins to improve spring and summer flows for migrating young salmon while also cooling river temperatures to help both young and adult salmon survive. In addition, the new plan should require the drawdown of large dam reservoirs, such as the one behind John Day Dam, during salmon migration. If and when the lower Snake River dams are removed, we may be able to reduce or end some of these measures.
#5 Strengthen, Do Not Weaken, the Endangered Species Act – The 2008 Bush salmon plan incorporates a supposed new ESA standard — “Trending Toward Recovery” — that gives the federal dams a pass on ESA requirements as long as at least one more fish returns each year. This “one more fish” standard is neither scientific nor legal and could set a negative national precedent for what the ESA can and should do to protect imperiled species. Judge Redden stated in a guidance letter to the parties that he had “serious reservations” about this anomalous standard. A legal Obama salmon plan would completely delete this standard and the analysis that goes with it.
#6 Acknowledge that Habitat Improvement Is Not a Silver Bullet for Snake River Salmon — The Bush 2008 salmon plan relies almost exclusively on habitat measures to make up for the huge harm caused by the federal dams. However, for the Snake River Basin, the plan does not identify specific on-the-ground actions that serve as the basis for those benefits. Peer-reviewed, published literature by federal government scientists makes clear that habitat measures alone will not protect and restore Snake River salmon and steelhead that spawn and rear in largely pristine habitat in central Idaho. While a legal plan would continue to invest in important tributary and estuary habitat restoration, it also would recognize that the biological benefits of such restoration efforts are uncertain and will take a long time to accrue. Moreover, without dam removal and restoration of the river migration corridor for juvenile and adult salmon, the benefits of habitat measures will be undercut. The current Bush salmon plan improperly relies extensively on very large hoped-for survival benefits from habitat actions; an adequate plan would not do this.
#7 Discard the Bush Salmon Plan’s flawed Scientific Model — The Bush salmon plan uses a model that U.S. Fish and Wildlife Service scientists, along with various state agency scientists, found to be seriously flawed for the use made of it in the Bush analysis; the model is filled with overly optimistic assumptions that render its conclusions unreliable. President Obama’s pledge to restore science to “its rightful place” in his administration will be tested by his willingness to discard this model, adopt the one suggested by the USFWS biologists, and include assumptions that are protect imperiled salmon and are neither, overly optimistic nor exceptionally uncertain.
#8 Tackle the Impacts of Climate Change on Columbia-Snake Salmon – The Bush salmon plan – contrary to the scientific literature – assumes that future climate change impacts on Columbia-Snake salmon will not exceed those of the past 22 years. A scientifically sound Obama plan would acknowledge the large volume of science indicating that climate change impacts in the future will indeed be harsher for these salmon, and would include those assumptions in its analysis. Such an improvement to the Columbia-Snake plan would bring it more in line with the Obama salmon plan for the Sacramento River, in which the administration acknowledged the significant impacts climate change will have on salmon and addressed those impacts in deciding which actions to take.
#9 Acknowledge Harm to Imperiled Puget Sound Orcas — The Bush plan dismisses the impact Columbia and Snake river dams have on ESA-listed Puget Sound orcas by reducing the supply of salmon – the orcas’ main food source. The Obama administration’s Sacramento River salmon plan acknowledges these impacts and requires that more be done to protect salmon to address the effects on orcas. Orca scientists and renowned ocean champion, Jean-Michele Cousteau, have called for the removal of the four lower Snake River dams in order to help protect imperiled Puget Sound orcas. A scientifically-sound Obama salmon plan for Columbia and Snake river salmon would acknowledge the interconnection of imperiled orcas and these salmon, take the advice of these respected biologists, and include measures to increase wild salmon populations quickly to protect orcas.
#10 Develop an Integrated Plan for Salmon & Clean Energy — The Bush administration went to great lengths to pit salmon against clean energy. This is a false and misleading conflict. Many expert analyses show that we can build a clean energy future for the Northwest, remove the salmon-killing dams on the lower Snake River, and bring back our wild salmon throughout the Columbia-Snake Basin. The Obama team should welcome the opportunity presented by salmon restoration as an integral part of building a clean energy future, not an obstacle to it. The Obama salmon plan should include steps to develop an integrated plan for salmon recovery and a reliable supply of clean energy. Both actions will generate sustainable, family-wage jobs. The Obama salmon plan can do this by recognizing that investment in energy efficiency and renewable energy sources can both provide a clean energy future and replace power production lost by removal of the four lower Snake River dams, all at affordable costs that create new and expanded economic opportunities.