Rec. 03 - Save Our Salmon
June 15, 2001
Dear Mr. Crow:
The Save Our Wild Salmon coalition appreciates the opportunity to comment on the proposed changes to the NWPPC's Columbia River Fish and Wildlife Program. We take the Council's charge to put energy and fish and wildlife benefits on equal footing seriously, and we hope that this opportunity is taken to implement that duty.
The current energy situation in the Northwest has caused endangered salmon to bear the brunt of the pain caused by our region's lack of planning. We incorporate here, by reference, the comments submitted by the NW Energy Coalition. These comments specifically incorporate ways that the Bonneville Power Administration and the NWPPC can take the burden of producing power off the backs of salmon. Any alternative proposals in those comments that would increase fossil-fuel energy use, and therefore, CO2 emissions, would need to mitigate for those CO2 emissions. Both the drought and this region's overcompensation for its potential effects are endangering salmon. The region has many ways of producing power, but the salmon have only one river.
In addition to the comments related to the reliability of the power system, we would like to offer the following comments related to the biological requirements of salmon.
- Flow augmentation for juvenile migration and mainstem spawning- improve inriver survival and production by implementing modified Biological Opinion and other operations to meet flow targets in the Snake and Columbia rivers; seek additional water to consistently meet flow objectives for all fish species.
- Spill- maximize fish passage efficiency and survival at all projects in the Snake and Columbia Rivers by implementing modified Biological Opinion spill including 24 hr spill at all projects.
- Juvenile fish transportation- implement "spread the risk" transport policy where no more than 50% of juvenile migrants are transported; improve in-river conditions by providing recommended flow and spill and improvements to bypass systems; bypass fish as needed to manage the proportion of fish transported.
- Planning for breaching the lower Snake River dams if non-breach options fail to meet ESA requirements- conduct necessary planning and evaluations to ensure that alternative actions including breaching of Snake River dams can be implemented on a timely basis if non-breach alternatives fail to meet performance standards.
In addition to the above comments, the Columbia River Inter-tribal Fish Commission has submitted recommendations on the proposed mainstem plan amendments. The Save Our Wild Salmon coalition would also like to incorporate their comments by reference.
The NWPPC has a unique role among the federal agencies involved in the region's salmon recovery programs. It is the role and duty of the NWPPC to make sure that the other agencies are fulfilling their obligation to restore and recover endangered salmon. We ask that your obligation remain foremost in your agenda, especially in this year.
Pat Ford Executive Director
Save Our Wild Salmon