In a letter dated May 28, 1999, from Mike Schiewe, the National Marine Fisheries Service (NMFS) requested that the Independent Scientific Advisory Board (ISAB) review the scientific adequacy of the April 14, 1999 draft document, "An Assessment of Lower Snake River Hydrosystem Alternatives on Survival and Recovery of Snake River Salmonids," prepared as an appendix to the US Army Corps of Engineers (COE) document, the "Lower Snake River Juvenile Salmonid Migration Feasibility Study." The NMFS document, generally referred to as the Anadromous Fish Appendix (AFA), attempts to evaluate a set of hydrosystem management options for their likely effects on listed stocks of Snake River Salmon.
The charge to the ISAB, in the letter from NMFS, stated a list of eight questions to help guide the review. These were:
- Are the analytical approaches and methods appropriate?
- Are data complete and of high quality?
- Do the results support the conclusions?
- Does the report accurately and fairly capture the degree of uncertainty in the projected outcomes?
- Are the uncertainties adequately described? Is the degree to which research can resolve these uncertainties clearly identified?
- To what degree did the failure of the PATH models to consider extinction affect the projected outcomes? Does this issue warrant further analytical attention?
- Although the analytical focus of the A-Fish Appendix is the evaluation of whether specific breach or non-breach alternatives would meet survival and recovery criteria, did the analysis adequately consider other factors affecting salmon recovery?
- Is the report balanced in its treatment of risks and uncertainties?
ISAB Responses
The ISAB found much to praise in the clarity and conciseness of the AFA, but our answers to many of the NMFS questions are not affirmative. Briefly,
- The analytical approaches and methods suffer from:
- Use of peculiar measures of performance (poorly related to survival, and recovery, as we understand these terms) in evaluating the consequences of each action,
- Insufficient NMFS ownership of the analysis,
- Over-reliance on optimistic scenarios, and
- Isolation of hydrosystem decisions from other management decisions.
- Some important inputs to the modeling were derived quantities, but were used as if they were data; and the data themselves had serious gaps that in fact account for much of the uncertainty in the analysis.
- The three main qualitative conclusions -- (1) that dam breaching would probably make a greater contribution to salmon recovery than would leaving the dams in place and maximizing transportation; (2) that there is great uncertainty; and (3) that the uncertainty could be reduced in the future with further data collection -- are easy to agree with, but the attempts in the AFA to quantify the first two of these conclusions are unconvincing. We suspect that the uncertainties have been understated, and we are very concerned that insufficient attention has been paid to trying to quantify analysis of the third conclusion, advancing a delay option.
- The implicit argument in the AFA in favor of delaying the hydrosystem decision does not adequately evaluate the biological costs or benefits of delay, and does not specify the substantial commitments and investments that would be necessary in order for the benefits of delay to be realized.
In subsequent sections of this report we elaborate on these brief comments, explain our answers to each of the NMFS questions, and present our own perspective on how the scientific support for the upcoming decision on hydropower operation might be better marshaled.
