Wasted Tax-dollars. Science and Climate Change Ignored.
Salmon and Communities on the Brink.
SUMMARY
On October 31, 2007, the federal government released its draft plan for how it intends to operate the federal dams on the Columbia and Snake Rivers to protect and restore salmon and steelhead. This federal salmon plan, or Biological Opinion (BiOp), attempts to address the significant harm the federal dams cause 13 Endangered Species Act (ESA)-listed salmon and steelhead species. Although federal agencies tout the plan as offering 73 separate salmon protection measures, the actions called for by the plan are almost indistinguishable from those proposed in 2000 and 2004 plans that were rejected by the courts. It includes almost no genuinely new measures; 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.
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BACKGROUND
Pacific salmon are an important economic, cultural and ecological resource for states from California to Alaska and inland to Idaho and Nevada, but these fish are in serious trouble. Twenty-six Pacific salmon and steelhead runs are protected under the ESA. Half of these imperiled fish runs are found in the Columbia-Snake River Basin and are harmed by the federal dams in the Columbia and Snake Rivers. As a result, federal agencies are required to produce plans to address those impacts. Courts have rejected the last two federal salmon plans. If the October 31st draft is not significantly strengthened, this new plan may meet the same fate.
There are five urgent concerns with the 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 proved insufficient. Furthermore, several key salmon protection measures (e.g., water spilled at the dams and additional river flow) are 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. Climate Change Science Ignored—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, NOAA Fisheries’ analysis should reflect the scientific consensus that warmer, drier climate conditions will make things worse for Northwest salmon—and then make decisions appropriately.
3. Best Available Salmon Science Ignored—At least three significant pieces of salmon science are ignored in this plan. First, NOAA Fisheries 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 include. 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. Finally, the plan ignores the best available salmon science by reducing levels of spill and river flow for salmon currently in place under court order. NOAA Fisheries must follow the science, not politics, when it finalizes this plan.
4. A Faulty Framework—The federal courts rejected the 2004 Salmon Plan because it relied on a framework that found that the federal dams were immutable parts of the environment. While the 2007 plan claims it takes a new and different analytical approach, the result is the same—it leaves these fish at a high risk of extinction for the foreseeable future. The various “metrics” included in the plan 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, NOAA picks the metric that will achieve specific results.
5. Less Protection for More Money—While this plan outlines relatively few changes from current salmon management obligations and even rolls back important salmon protection measures, it will cost an additional $100-$150 million more per year than current operations. So ratepayers and federal taxpayers would be spending more on a plan that actually does less for the salmon it is meant to protect. One year of paying for this 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.
SUMMARY OF THE DRAFT COLUMBIA-SNAKE RIVER SALMON PLAN’S ELEMENTS
Specific Actions—The draft BiOp presents 73 separate actions, spanning the four areas known to harm salmon and steelhead in the Columbia-Snake Basin:
1. Hydropower Operations—Hydro operations on the Columbia and Snake Rivers will remain largely the same as those currently in place. 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 or providing more river flow for fish. “Spill” is a proven way of helping young salmon migrate to sea more safely. Additional flow helps reduce the amount of time young salmon spend in warm, predator-filled slackwater reservoirs. This plan offers less of both.
2. Habitat Actions—Currently, federal agencies spend $36 million on specific habitat projects. Under this plan, that level of spending will continue in 2008 and 2009. Starting in 2010, the federal agencies propose to increase habitat restoration and protection measures by $9 million per year. Specific projects have not yet been identified for this spending increase.
3. Harvest Practices—The draft plan does not affect the current level of harvest (i.e. tribal, sport or
commercial fishing).
4. Hatchery Reform—The draft 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.
Reporting Requirements—In addition to specific actions, the plan establishes an annual reporting process where the federal agencies must report on their progress toward implementing the 73 actions. NOAA Fisheries will produce two “check-in” reports to determine whether the implementation of the 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 will be no different than they have been over the last 22 years.
Federal Analytical Framework Used—NOAA Fisheries 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.
