Mr. Frank L. Cassidy, Jr, Chairman May 12, 2000
Northwest Power Planning Council
851 S.W. Sixth Avenue, Suite 1 100
Portland, Oregon 97204-1348

RE NPPC Fish and Wildlife Amendment Process

Dear Mr. Cassidy:

On behalf of the members of the Columbia River Alliance, we submit the following amendment requests for inclusion in your Fish and Wildlife Program.

1) To re-evaluate the extent to which the hydrosystem, as presently configured and operated, has an adverse impact on salmon and steelhead stocks in the Columbia River Basin.

2) To assess the success and accomplishments of past mitigation efforts against the effects of present dam operations to determine whether and to what extent additional efforts to protect, mitigate and enhance fish and wildlife are appropriate.

3) To consider calls for a "normative" river and dam breaching as inconsistent with past mitigation efforts, and may represent an unlawful attempt to impose new and substantial remedial obligations on federal dam operators.

4) To assess the fish and wildlife protection efforts of other entities in the Columbia River Basin, in order to avoid supplanting those efforts in violation of the Northwest Power Act.

5) Adopt proven and cost-effective measures with verifiable and quantifiable benefits to salmonids; conduct experiments on proposed measures to quantify benefits; and abandon measures whose benefits cannot be quantified. That includes strategies to:

• Quantify the benefits and costs of existing and proposed measures to protect Columbia Basin salmon and steelhead populations, taking account of adverse impacts and costs to other species of interest, if any.
• Select fish and wildlife measures for implementation based on cost-effectiveness analysis to maximize the public benefit from expenditures of finite salmon recovery funds.
• Improve measurements of survival through all salmonid life stages to identify high mortality areas and reduce mortality.
• Use and improve computer models to assemble existing data and relationships to predict effects on salmon and steelhead from management actions.

Use computer metapopulation models to predict extinction probabilities for listed stocks, and annually reassess extinction probabilities to reconsider listing decisions.

• Focus research efforts on identification of survival through alternate passage methods at dams to reduce "hot spots" for mortality (e.g., excessive spill at The Dalles).
• Abandon all spring flow augmentation and real-time management of flow, because it serves no purpose, wastes fishery management resources, and creates conflicts with the needs of resident fish.
• Experiment with late summer/fall flow augmentation in low water years, because there is a good chance of benefits to returning fall adults, and possible benefits to juvenile salmon at very low flow levels.
• Use BPA Fish Contingency Fund monies for operational experiments with flow augmentation in low flow years. Increase program beyond experimental level only after data demonstrate survival improvements caused by flow augmentation.
• Maximize smolt transportation by eliminating spill at all collection facilities, because all available scientific evidence demonstrates substantial benefits. Improve transportation by experimenting with release strategies (i.e., further downstream) to avoid substantial estuarine mortality
• Adjust spill on a project-by-project basis to optimize passage survival at non-collector projects (e.g., reduce spill at The Dalles and Ice Harbor), taking care to balance potential positive effects on juveniles against negative effects on adults.
• Reactivate sluiceway passage at available projects, as available studies demonstrate substantial passage benefits, and expand surface collector efforts
• Ensure that "fish-friendly" turbines are available in time for renovation of mainstem facilities.
• Assess natural mortality levels to gain understanding of when human-induced hydrosystem and other effects are fully mitigated.

• Unify and standardize hatchery reporting obligations to single funding entity and require reporting concerning success in generate returning adults to applicable watersheds.
• Mark all hatchery fish, so as to facilitate selective harvest. Highest net economic benefits will come from non-tribal recreational harvest, which can select for hatchery stocks.
• Use central entity to serve as clearinghouse for successful approaches to artificial production, such as spawning channels and egg boxes.
• Fund applied genetics research unit to restore lost size of salmonids, improve disease resistance, and improve tolerance for warmer habitat, as well as other genetic improvements that will increase salmonid abundance.
• Install irrigated spawning channels below dam tailraces and elsewhere to increase mainstem spawning habitat; survey reservoir habitat for extant spawning locations and focus on expanding areas with existing populations.
• Allow hatchery operators to share revenue from salmon and steelhead tags in hatchery watersheds, to establish feedback loop for hatchery success.
• Move hatcheries to tribal management, because tribes may have longer-term management focus, and will reap 50% of harvestable fish pursuant to Supreme Court Treaty interpretations, again establishing feedback loop for hatchery success.
• Declare specific tributaries "off-limits" to hatcheries (e.g., John Day River) to provide buffers against asserted genetics problems with hatchery production.
• Designate tributaries with extensive hatchery influence as "production/supplementation" tributaries and abandon efforts to protect existing wild stocks in such tributaries.

• Place a moratorium on harvest of wild stocks in the mainstem, with tributary-by-tributary escapement goals for protected wild stocks. Mainstem harvest can be allowed only to the extent that the weakest wild stock subject to protection has adequate spawning escapement for adequate seeding.
• Work toward elimination of ocean salmon harvest, including treaty negotiations with Canada. If each country catches "its own" salmon, search, production and management costs of commercial salmon harvest will decrease, along with political friction. Fishery managers have long recognized that ocean commercial harvest of Columbia Basin salmon makes little economic sense when the fish will return at maturity.
• Redirect lower river mixed-stock commercial harvest to terminal harvest away from mainstem migration corridor. No improvement in upriver stocks is possible with present high levels of mixed stock harvest.
• Redirect tribal mixed-stock commercial harvest to selective harvest at fish ladders and terminal harvest in tributaries. Tribal share of harvestable fish can be caught without indiscriminate harvest through hundreds of inriver gillnets.
• Conduct one-time purchase of replacement selective harvest gear for affected harvest interests with monies saved through operational changes at dams. Unify policing functions under United States v. Oregonto gain accurate harvest counts, using aerial or satellite-based estimation techniques to corroborate self-reporting by fishermen.

• Abandon regional government supervision of habitat restoration. Repeated costly failures demonstrate that state and local entities will produce more effective efforts, particularly if improved harvest management rewards localities that invest in habitat restoration by allowing salmon and steelhead to return to the improved habitat.
• Limit regional governmental role to clearinghouse for information about successful habitat restoration strategies.
• Abandon regional approach to wildlife restoration. Effects on wildlife from dam development have been mitigated for many years through land purchase and dedication, including creation of many wildlife refuges. Centralized planning offers no advantages to mostly single-State wildlife populations, and has the disadvantage of superfluous governmental layers, creating additional coordination costs.
• Liquidate and cap current habitat mitigation efforts funded by BPA and substitute Bonneville Environmental Foundation or other vehicle for habitat grants. Create one-time endowment of funding vehicle monies saved through mainstem operational changes. Focus habitat improvement funds on "wild reserve" rivers.
• Evaluate comparative cost effectiveness of improved habitat/wild reserve tributary production vs. production/supplementation tributary production.

• Prioritize research funding to document project-specific effects on anadromous fish, and effects of operational changes. Make decisions based on best available quantification of effects of operational changes.
• Use new and existing information to expand salmon passage models to cover entire salmon lifecycle. Without a model of effects on adults from flow and spill changes, managers cannot make a rational assessment of the effects of operational changes.
• Use new and existing information to construct metapopulation models of salmon and steelhead population dynamics. Preliminary information suggests that extinction risks are much lower than generally supposed, which if confirmed could remove ESA listings and eliminate significant management constraints.

• Introduce mammalian predators to control bird populations on Rice Island and elsewhere. The rise of such colonies in the 1990s, which may consume a third of the smolts making it downriver, has depressed recent salmon runs.
• Allow limited hunting for marine mammals to control populations; turn over percentage of license revenues to habitat restoration projects. High percentages of returning adults show evidence of marine mammal attacks.

 Sincerely,

Bruce J. Lovelin
Executive Director

Attachment - July 16, 1997 memorandum from James L. Buchal
 
 

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