Scientists: Please Support Sound Science for Columbia & Snake River Salmon
The Save Our Wild Salmon Coalition, along with scientists from across the country, is circulating a scientist's sign-on letter to Dr. Jane Lubchenco, NOAA Administrator. The letter voices concerns about the scientific deficiencies of the 2008 Biological Opinion for Columbia Basin salmon and steelhead.
Scientists of all persuasions (active or retired) are invited to sign the letter.
*** Deadline: Due to a one month extension granted to NOAA by federal Judge James Redden, the deadline has been extended to Tuesday, September 8th, 2009 ***
If you or any scientist you know is interested in signing on, please send the following info to email@example.com by close of business on September 8th:
- Field of expertise/profession (eg, "Conservation Biologist" or "Wildlife Ecologist")
- City, State
- Email (for our records only, in case signers would like to receive a copy of the final, signed letter; won't be included in the signature block of the letter)
*Also please note: Your agency or organizational affiliation will not be listed on the letter, so you will not be representing any organization.
If you have any questions at all, please contact:
Gilly Lyons - 503.230.0421 x17 - gilly [at] wildsalmon.org
Documents and Links for More Context:
PDF of the 2009 Scientists Letter (text also posted below)
Judge Redden’s May 18th Guidance Letter to NOAA & Action Agencies RE: 2008 BiOp
1-Pager on the BiOp from the Save Our Wild Salmon Coalition
2009 Scientist's Letter Text
August XX, 2009
Dr. Jane Lubchenco, Under Secretary and Administrator National Oceanic and Atmospheric Administration
U.S. Department of Commerce 1401 Constitution Avenue, Room 5128 Washington, DC 20230
Re: Federal Columbia River Power System Biological Opinion
Dear Dr. Lubchenco:
We, the undersigned scientists, are writing to voice our concern regarding the 2008 Biological Opinion (BiOp) for the Federal Columbia River Power System. We applaud the Obama Administration’s decision to review all aspects of the BiOp prior to determining how it will proceed on this complex issue. We would like to take this opportunity to share with you our perspective on the BiOp’s scientific content.
Many of us and our colleagues wrote in 1999 and 2000 to then-President Bill Clinton, and again in 2004 to then-President George W. Bush, cautioning that federal efforts were off course and unlikely to recover Endangered Species Act-listed salmon and steelhead populations. By failing to adequately address a primary source of salmon mortality – namely, the dams on the Columbia and Snake rivers – those federal plans were unlikely to avert extinction, much less restore abundant, self-sustaining, harvestable populations of these species. We now find ourselves repeating that warning, but with much less sand in the hourglass.
After a federal court invalidated the 2004 BiOp, the judge overseeing the remand of that plan urged the Bush administration to prepare an effective, scientifically-defensible plan that adequately addressed the effects of the federal hydropower system on listed salmon and steelhead. Unfortunately, the result of that remand, the 2008 BiOp currently under your agency’s review, does not meet this objective.
In our opinion, the 2008 BiOp suffers from several scientific deficiencies:
First, NOAA failed to employ the best available science in its jeopardy analysis. NOAA’s own recovery planning process confirmed the need to link the jeopardy analysis to the basic survival and recovery needs of the species, yet NOAA instead adopted a never-before-used “trending toward recovery” benchmark as its jeopardy standard. For the purposes of the 2008 BiOp, “trending toward recovery” could be satisfied if only one additional fish survives the journey back to its natal waters when compared with the previous year. The BiOp does not actually measure the chances that federal dam operations will allow the species to recover, nor does it include a timeframe in which to achieve recovery, nor does it recognize the increased risk associated with populations that remain at very low abundance over time. This flaw is compounded by the BiOp’s use of a time series that generally begins during poor ocean conditions and ends with more favorable ocean conditions. Using this approach, a population can be deemed to be recovering in the near-term while actually heading toward extinction over a longer time frame. This overly optimistic assumption veers sharply from the Endangered Species Act’s precautionary principle and is at odds with sound conservation biology.
Second, like the 2004 BiOp, the 2008 BiOp continues to rely on unproven, speculative benefits from expensive technological fixes at the federal dams and projected future benefits from undefined habitat mitigation actions to make up for the massive harm caused by the dams. The vast majority of these hoped-for gains come from actions proposed to be undertaken between 2011 and 2018 – actions that are not even identified in the BiOp. Further, like its predecessors, the 2008 BiOp relies heavily on truck and barge transportation of juvenile salmon and steelhead, despite growing scientific evidence that this practice harms juvenile fish in some years and in most years provides little or no benefit. Though it may be easier on some level to continue avoiding restoration obligations by transporting fish around the dams (therefore minimizing the need to provide suitable in-river conditions), a science-based, risk-averse management strategy should focus instead on keeping salmon in their natural habitat wherever possible, while making that habitat healthy and safe.
Third, the BiOp rolls back certain in-river protections that have been shown to help young salmon better survive their ocean-bound migration. The 2008 BiOp approves a set of dam operations that curtails both flow regimes mandated by past BiOps and spill measures required by court order since 2005. While these protections may not be enough to restore key populations, they have helped buy some additional time for Columbia and Snake salmon. Instead of being decreased, interim spill and flow measures should be bolstered to further reduce harm to fish while the measures necessary to assure salmon survival and recovery are developed and implemented.
Finally, the 2008 BiOp adopts what can perhaps best be described as a reckless approach to the impacts of climate change on Columbia Basin salmon and steelhead. While the BiOp acknowledges climate change’s likely effects on Columbia Basin salmon, it also assumes that the Pacific Northwest’s climate conditions will not differ significantly from the regional warming experienced over the past 22 years. As you know, this assumption runs counter to the conclusions of scientific bodies ranging from the United Nations Intergovernmental Panel on Climate Change to the Northwest Power and Conservation Council’s Independent Scientific Advisory Board, as well as those highlighted in the recent report, Global Climate Change Impacts in the United States. It also contrasts sharply with the approach NOAA used in its Central Valley Project Biological Opinion (June 2009). Based on the scientific consensus that the Columbia Basin will become even warmer and drier over the next several decades, resulting in significant threats to coldwater fish such as salmon and steelhead, any responsible plan for protecting and restoring the Basin’s most imperiled fish must adopt a more realistic approach to addressing these conditions and ensuring that salmon populations are robust enough to withstand anticipated changes in habitat.
Federal salmon recovery strategies must start with a commitment to restoring abundant, self-sustaining, harvestable populations of wild salmon and steelhead. The approach outlined in the 2008 BiOp is unlikely to bring the Northwest any closer to achieving that goal, and may instead take us much further away from it. As federal district court Judge James Redden wrote in a recent letter to parties involved in litigation over the 2008 BiOp, “Federal Defendants have spent the better part of the last decade treading water, and avoiding their obligations under the Endangered Species Act…We simply cannot afford to waste another decade. All of us know that aggressive action is necessary to save this vital resource, and now is the time to make that happen.” We share Judge Redden’s sense of urgency, and believe that meaningful progress on Columbia Basin salmon recovery will require significant changes to the 2008 BiOp.
As you and your agency review the 2008 BiOp, we sincerely hope that you will carefully consider the predominance of scientific evidence pointing to the harmful biological impacts of the federal dams on the Columbia and Snake rivers. All scientifically sound actions to protect and restore salmon (including, but not limited to, the removal of the four lower Snake River dams) must receive equal and impartial consideration in any comprehensive plan to restore wild salmon and steelhead to the Columbia Basin.
Thank you very much for your time and consideration of our views.