American Rivers * American Whitewater * Association of Northwest Steelheaders
Audubon Society of Portland * Audubon Society of Lincoln City * Backbone Campaign
Coastal Trollers Association * Columbia Riverkeeper * Communities for a Healthy Bay
Defenders of Wildlife * Earthjustice * Earth Ministry/Washington Interfaith Power and Light
Endangered Species Coalition * Friends of Grays Harbor * Friends of the San Juans
Grays Harbor Audubon Society * Idaho Conservation League
Idaho Outfitters & Guides Association * Idaho Rivers United * Idaho Wildlife Federation
Institute for Fisheries Resources * Kalmiopsis Audubon Society
National Parks Conservation Association * Natural Resources Defense Council
National Wildlife Federation * Northwest Guides and Anglers
Northwest Sportfishing Industry Association * NW Energy Coalition
Pacific Coast Federation of Fishermen’s Associations * Olympic Forest Coalition
Rivers Without Borders * Salem Audubon Society
Sawtooth Interpretive and Historical Association * Save Our wild Salmon Coalition
Snake River Savers * Spokane Riverkeeper * Solutionary Rail * The Natural History Museum
Twin Harbors Waterkeeper * Washington Wild * Washington Wildlife Federation * Wild Orca
Whale Dolphin Conservation * Whale Scout * Whidbey Environmental Action Network
Wild Steelhead Coalition

July 11, 2022
Jim Kramer
Kramer Consulting, Inc.
6539 57th Ave. S.
Seattle, WA 98118

Mr. Kramer,

Please accept these comments on behalf of the Save Our wild Salmon Coalition (SOS) and the
member and allied organizations signing below. SOS is a coalition of Northwest and national
conservation organizations, recreational and commercial fishing associations, clean energy and
orca advocates, businesses, and citizens committed to restoring abundant, self-sustaining
fishable populations of salmon and steelhead to the Columbia-Snake River Basin and healthy
populations of salmon-dependent Southern Resident orcas, for the benefit of people and
ecosystems.

We appreciate the opportunity to comment on the Lower Snake River Dams: Benefit
Replacement Draft Report. We want to begin by acknowledging the valuable and impressive
work you and your associates have done to bring this synthesis and analysis together for the
information of Sen. Murray and Gov. Inslee, and Northwest Tribes, stakeholders, and the
concerned public. Thank you.

Multiple members of our coalition have, or will, submit their own detailed comments; we feel
little need to repeat what you will hear from them. Rather, we want to share a few big picture
points of emphasis and key things that we feel strongly need to be addressed in your final report
and kept in mind by Sen. Murray and Gov. Inslee and all interested parties.

We will begin by noting that the Draft Report affirms some central facts which we and many
others have pointed to for years:

• ESA-listed Columbia-Snake Basin salmon and steelhead stocks, and salmon-dependent
  Southern Resident orcas, are genuinely in near-term peril of extinction.
• For all listed salmon and steelhead populations that utilize the Snake River and its
  tributaries, the lower Snake dams are a primary source of endangerment.
• There is broad agreement among salmon scientists that restoring a free-flowing lower
  Snake River is one essential component of a larger regional recovery strategy in order to
  prevent extinction and to recover abundant, harvestable Columbia Basin wild salmonid
  runs and support a healthy southern Resident orca population.
  • Replacement of the services these four dams now provide is feasible and affordable, can
  actually improve upon some of the existing services and can create new opportunities
  not available under the status quo approach.
• The status quo is unsustainable. It has proven costly, illegal and inadequate, and it has
  perpetuated an atmosphere of uncertainty for all involved. As the draft clearly says,
  “Change in the Lower Snake River and the Columbia River System Is Inevitable”.

These conclusions cannot be too heavily emphasized in your final report. Nor can the stakes for
Northwest Tribes. The draft report details the heavy reliance of Tribes on salmon, historically and
to the present day. It acknowledges their centrality to tribal cultures. But we are concerned that
it doesn't fully convey the way in which Tribes perceive the extinction of salmon as a genuinely
existential issue. We encourage you to ensure that the final report clearly communicates to nonNative readers the incalculable cost of salmon extinction especially for the People of the Salmon.

At least some aspects of this cost can be captured in existence value or passive use economic
analysis but even these afford only an incomplete picture of the cost of losing salmon for
everyone, but most especially tribes. Where economists have attempted to capture some of the
costs of extinction through passive use valuation, the costs of this loss (and the corresponding
benefits of sustaining healthy salmon) have dwarfed all other factors and made it clear that
keeping the dams will be far more costly than breaching them and replacing their services and
the benefits of restoring the river will far exceed any realistic assessment of dollar costs. Your
Final Report should acknowledge these important facts. The two analyses of passive use value
we are aware of are in the 2019 ECO Northwest Lower Snake River Report and in the technical
appendices of the 2002 Lower Snake River EIS prepared by the Army Corps of Engineers.

This is a key example of the most critical lacunae in the draft report: the lack of a well-structured,
understandable accounting or comparison of all of the costs and benefits of the two possible
paths before us: (i) dam removal and service replacement, and (ii) dam retention. The Draft
Report provides a range of cost estimates drawn from various sources, over 50 years, of
removing/breaching the lower Snake dams and replacing their services. It does not provide a
comparable estimate of the costs of operating and maintaining the lower Snake dams, ongoing,
and probably increasing costs of salmonid recovery programs, and quantification (monetized
where possible) of benefits flowing from recovery of salmon, steelhead, and orca populations,
benefits which would almost certainly not be realized if these four dams remain in place.

Media coverage and regional discussion of the Draft Report since its release have thus tended to
highlight the $10-27 billion figure for dam removal and services replacement. We doubt the
realism of some of the estimates that went into this total, especially at the high end of the range.
But the real problem is that the press, policymakers and the public have no comparable fifty-year
estimate of costs - and benefits not captured - if the dams remain in place, because the draft
does not provide such a figure.

The Report does include some of the specific elements for such a calculation but does not sum
them, consistently translate benefits and new opportunities from a free-flowing lower Snake into
dollar values or recognize the immense value of restored salmon abundance in the context of
costs and benefits. Specifically, the Final Report should provide a summary of both estimated
avoided costs if the dams are removed, and the anticipated value of benefits that would accrue
upon their removal. Some of the more obvious avoided costs would, for example, include:

• Annual operating and capital costs of $134-151 million summed over 50 years, plus major
  capital costs like turbine replacement and generator rewinding.
• Current annual LSRD fish and wildlife costs of $54 -159 million/year (from CRSO FEIS 2020,
  table 3-312) summed over 50 years.
• Costs of additional fish mitigation measures required if the dams remain in place. The draft
  provides an estimate of lost generation for the FCRPS from such measures (“hydropower
  generation could decrease by 1,300 average Megawatts (aMW) under average water
  conditions, and 870 aMW under low water conditions compared to the No Action
  Alternative”), but does not specify what portion of this reduction would occur at the lower
  Snake dams or provide a monetized estimate of the value of that lost generation, summed
  over 50 years.
• Parenthetically, the Report acknowledges the likelihood that climate change-driven
  reductions in river flows will reduce “the ability for the LSRD to produce peak generation
  levels and store water to achieve these sustained peaks.” In other words, at least some of the
  energy services that the dam removal case assumes will have to be replaced will have to be
  replaced in any case. The incremental cost of replacing the dams’ energy services, if
  breached, is thus lower than the estimates in the Draft.

The Draft Report also references multiple benefits of a free-flowing lower Snake that will not be
achievable if the dams remain in place. The available benefits, including the large benefits to the
region, tribes and the whole country of salmon/river restoration need to be added to the
avoided costs discussed above to present a comprehensive and balanced account of the costs
and benefits of both paths. Examples of these benefits from the report include:

• The Report includes an estimate that, with recovery of listed stocks, tribal harvest could
  increase by 29% annually. While this result has great cultural value for the Tribes, commercial
  and subsistence fishing also has quantifiable economic benefits which should at least be
  estimated and accounted for.
• Recreational fishing, and the individuals and commerce it supports, would also benefit. The
  Draft Report estimates that salmon and steelhead recovery “…could generate up to $1 billion
  annually in additional regional personal income benefits and support up to 25,000 new
  family wage jobs”. These annual figures should be summed over 50 years and added to the
  balance sheet for dam removal.
• The report concludes that, “While the overall trend of commercial salmon and steelhead
  harvest has been downward since the 1930s, the losses of these economic contributions can
  be recaptured if efforts to improve abundance, to levels like those laid out in the Columbia
  Basin Partnership, are successful.” This general statement can be quantified in several ways.
  For example, as late as 1978, there were over 3000 licensed commercial salmon trollers
  based in Washington with an average crew size of two (the draft is mistaken in characterizing
  these trollers as “usually employing at most one crew member; crew could hardly be less
  than one and, in fact, ranges from one to three). Today there are barely one hundred
  Washington-based salmon trollers, representing a loss of approximately 6000 jobs in the
  fishing fleet and more in onshore businesses providing services, supplies and equipment to
  the fleet. The value of fish landed by these trollers declined from an average in 1976-1980 of
  $31.4 million annually to $2.75 million in 2014-2018 (in constant dollars; documentation
  attached). Recovering these types of lost jobs and increasing the value of catch landed
  should be summed over 50 years and added to the balance sheet.

We will add several other observations. The first is that the successive “recovery” plans from the
federal agencies have hardly even pretended to aim for recovery; rather they’ve contented
themselves with a considerably lower bar - trying to avoid outright extinction. Even if there were
no imminent danger of extinction, prevention of extinction is only one of the core purposes of
the Endangered Species Act. The second is to recover populations of listed species to the point
where they no longer require the protection of the ESA. The failure to propose plans that have
any real probability of such full recovery has been one of the several reasons the courts have
rejected each and every plan offered thus far.

The second observation we want to share is this: The public debate over the Draft Report has
thoroughly validated Sen. Murray, Gov. Inslee and the Biden-Harris Administration - that only
political leadership can bring this endless wrangle to a conclusion in a manner that meets needs,
solves the impending challenges, and moves everyone forward together. We have spent two
decades demonstrating that the courts and federal agencies cannot develop and implement a
strategy that is legally valid, scientifically-credible, and fiscally-responsible. And, two decades
later, consensus is implausible.

The defenders of the status quo continue to dispute every one of the conclusions in the Draft
Report we highlighted at the beginning of these comments. They deny the fish are in peril,
pointing to slight upticks in still deeply depressed returns over the last couple of years. If the fish
are in any kind of trouble, they claim that the problem is poor ocean conditions, rather than the
quality and condition of freshwater habitat that has been transformed by the federal system of
dams and reservoirs. They ignore overwhelming scientific evidence and suggest that dam
removal would make little-to-no positive difference for salmonids and orcas and the people and
communities that value and benefit from them. You have further received specific comments
denying that change is inevitable. Pacific Northwest Waterways Association (PNWA), in a May 4
letter to you, flatly asserted, “There is no reason to assume the status quo will change if the
dams remain in place.” PNWA and Northwest RiverPartners doubled down on that assertion in a
May 6 letter: “The operations approved in the final EIS are very similar to those approved by the
court and will govern Lower Snake River operations moving forward, absent legislative action. In
that context, there is no reason to assume the status quo will change. If anything, spill is likely to
decrease in the future…”.

The failure to achieve a consensus – if consensus means near-unanimity among stakeholders –
must not, by default, result in the continuation of a failing status quo. There is clearly a critical
mass – a solid majority of Northwesterners – who will support a comprehensive salmon recovery
plan whose twin cornerstones are restoration of a free-flowing lower Snake River and full
replacement of the services and benefits the dams now provide. Such a plan can work for
salmon and orcas, for Tribes and utilities, for farmers and fishermen and for communities in the
Columbia Basin and on the coast.

Thank you for your work that helps show the way forward. Please contact us if you have
questions or we can assist in any way.
Sincerely,

Joseph Bogaard, Executive Director
Save Our wild Salmon Coalition

Nancy Hirsh, Executive Director
NW Energy Coalition

Erin Farris-Olsen, Regional Executive Director, Northern Rockies, Prairies, and Pacific
National Wildlife Federation

Todd True, Managing Attorney
Earthjustice

Liz Hamilton, Executive Director
Northwest Sportfishing Industry Association

Miles Johnson, Senior Attorney
Columbia Riverkeeper

Glen Spain, Northwest Regional Director
Pacific Coast Federation of Fishermen’s Associations
Institute for Fisheries Resources

Rev. AC Churchill, Executive Director
Earth Ministry/Washington Interfaith Power and Light

David Moryc, Senior Director of the Wild and Scenic Rivers and Public Lands Policy
American Rivers

Kathleen S. Gobush, Ph.D, Northwest Regional Director
Defenders of Wildlife

Thomas O’Keefe, PhD, Pacific Northwest Stewardship Director
American Whitewater

Giulia C.S. Good Stefani, Senior Attorney
Natural Resources Defense Council

Leda Huta, Executive Director
Endangered Species Coalition

Rob Smith, Northwest Regional Director
National Parks Conservation Association

Colleen Weiler, Jessica Rekos Fellow for Orca Conservation
Whale Dolphin Conservation

Amy Morrison, Deputy Director
Backbone Campaign

Dr. Deborah Giles, Science & Research Director
Wild Orca

Bill Moyer, Campaign Lead
Solutionary Rail

Aaron Lieberman - Executive Director
Idaho Outfitters & Guides Association

Tom VanderPlaat, Board Co-President
Association of Northwest Steelheaders

Tom Uniack, Executive Director
Washington Wild

Nic Nelson, Executive Director
Idaho Rivers United

Brian Brooks, Executive Director
Idaho Wildlife Federation

Joel Kawahara, Boardmember
Coastal Trollers Association

Erin Dilworth, MS, Deputy Director
Communities for a Healthy Bay

Lee First, Waterkeeper
Twin Harbors Waterkeeper

Arthur (R.D.) Grunbaum, President
Friends of Grays Harbor

Stewart Wilder, President of the Board
Sawtooth Interpretive and Historical Association

Connie Gallant, President
Olympic Forest Coalition

R. Brent Lyles, Executive Director
Friends of the San Juans

William C. Patric, Executive Director
Rivers Without Borders

Bob Sallinger, Conservation Director
Audubon Society of Portland

Gary Piazzon, President
Whidbey Environmental Action Network

Steve Griffiths, Conservation Chair
Audubon Society of Lincoln City

Beka Economopoulos, Director
The Natural History Museum

Rhema Koonce, Co-Leader
Snake River Savers

Mitch Cutter, Salmon & Steelhead Associate
Idaho Conservation League

Greg Topf, Board Chair
Wild Steelhead Coalition

John McGlenn, President
Washington Wildlife Federation

David Harrison, Conservation Chair
Salem Audubon Society

Ann Vileisis, President
Kalmiopsis Audubon Society

Janet Strong, President
Grays Harbor Audubon Society

Jerry White, Jr., Riverkeeper
Spokane Riverkeeper

Whitney Neugebauer, Director
Whale Scout

Grant Putnam, President
Northwest Guides and Anglers