Senator Crapo, on behalf of the food processing industry in the Northwest, I would like to take this opportunity to thank you for your continued leadership on this issue which is of such great importance to all residents of the Northwest.
The Northwest Food Processors Association is a regional trade association representing the fruit, vegetable and specialty food processing industry in Idaho, Washington and Oregon. Food processing is the largest manufacturing employment sector in the State of Idaho and the second largest manufacturing employment sector in both Washington and Oregon. Food processors in the region operate 257 processing plants, employ 50,000 individuals and realize $7 billion dollars in annual sales. Food processing is the backbone of the rural Northwest economy.
Food processors have a critical interest in the future of the Columbia/Snake system. It is this great system that has allowed our region to become one of the foremost food production areas in the world. Access to adequate irrigation water, the availability of dependable, low cost power and the river transportation system, which helps us reach Asian export markets, are all critical to the continued viability of our industry.
Today, it is apparent that salmon recovery in the Columbia/Snake system is at a crossroads. The draft biological opinion signals the beginning of a shift in direction for the salmon recovery debate. It is a shift away from dam breaching, toward a performance based plan. We believe this shift is long overdue, even though the Bi-Op has many problems and still contains many of the elements of past, failed efforts.
For too long the region has argued over the "big ticket items", dam removal and flow augmentation. These two issues have been the focus of tremendous controversy and have dominated the public discussion. Now, the science is becoming more focused and the debate is shifting. We are now beginning to understand that the science doesn't support either of these strategies, especially as it relates to Snake River stocks.
That is a huge problem for some folks who have staked their reputations on breaching and flow augmentation. Consequently, we now have a rebirth of the debate over who has the "right" science. The current argument is not over Crisp vs. Flush, even though that one was never really resolved. But we still seem to be battling over who has the better black box and which model more accurately reflects reality. Should we rely on PATH or CRI? Does the data include the most recent PIT tag studies or are they ignored? Did NMFS allow for enough collaboration on CRI, or did they manipulate their results?
And on it goes, seemingly forever, with no resolution in sight. And while we argue, spin and debate; viable, proven and effective measures that will really help salmon continue to wait for the region to put its energy into productive recovery efforts. This is not to say that good things are not now being done, they are. But how much more could we accomplish if we really moved beyond these esoteric, self serving debates.
Mr. Chairman, our industry and the residents of the Northwest that depend on the Columbia River system for their livelihoods, have had enough of this endless debate. The uncertainty hangs like a cloud and combined with difficult times in the agricultural sector, it is having a very negative effect on our industry.
For the good of the region, it is time to develop and move ahead with a recovery plan. It is time for reason and common sense to merge with science and produce a plan that can be implemented immediately. For the benefit of the fish, for the benefit of the Northwest.
That is why we agree with the approach taken by the region's Governor's last summer. We believe that the solutions must come from the region. Using the science to inform their decisions, the region's Governors are best situated to develop a comprehensive, balanced plan that will benefit endangered fish.
NMFS and the other Federal agencies have had 10 years since the first listing on the Columbia/Snake system and they still have not produced a recovery plan. In fact, they not only don't have a plan, they don't even have a goal against which to measure progress. The performance standards in the draft Bi-Op are an attempt to set some goals for the operation of the system. However, they mean little outside the context of an overall recovery plan.
In fact, it is our belief that the performance standards, and the subsequent requirement for off-site mitigation, have the potential to significantly damage on-going habitat improvement projects by forcing dam operators to go into tributary habitat areas and find projects which they can credit against their individual survival requirements. This process has the potential to disrupt local planning processes and to limit the willingness of local entities to cooperate in habitat improvement projects.
We are advocates of performance standards. However, they must be developed for the whole system, not just the hydra operations, and this is not possible under the current Bi-Op, since it is outside its legal scope. This further accentuates the need for a recovery plan. We have to eliminate the piece meal management practices we now follow.
Consequently, it is time to end the rancorous debate over flow augmentation from the Upper Snake River and the removal of the four Lower Snake dams. While these two issues continue to polarize the region, the science does not support either alternative. It is this fact that has some people advocating the return to older science that supports their position.
First, let me touch on flow augmentation.
Flow augmentation has failed, yet it is the primary strategy utilized by NMFS to mitigate for the effects of impoundment. The flow program is based upon a set of totally flawed assumptions. The Hydropower Appendix of the All-H paper States the following:
Flow augmentation, or use of water from storage reservoirs to augment natural streamflows, is one of the primary strategies to mitigate the effects of impoundments and the regulated hydrograph on juvenile passage.
Flow augmentation from storage reservoirs is intended to reduce the fishes' trave/ time to more closely approximate that of pre-dam conditions. The hypothesis is that increased water velocities resulting from higher flow rates will decrease juvenile fish travel time, resulting in reduced freshwater residence and earlier arrival at the estuary.
Flow augmentation has virtually no effect on travel time and thereby offers absolutely no benefit to spring migrants. Recent work by Karl Dreher, ID. Dept. of Water Resources, shows that adding 1 MAP annually to existing flows results in less than a 0.1 mile per hour increase in velocity through the Lower Snake reservoirs.
PIT tag data shows absolutely no correlation between flow and survival for spring/summer migrants. NMFS has finally recognized this in the draft Bi-Op. However, their response has been to shift the augmentation period to later in the summer in an attempt to benefit fall chinook migrants. Benefits to fall chinook from increases in travel time are not clear and may not exist.
In the Hydropower Appendix of the All-H paper, the following summary statement is made:
The relationship between flow and fish travel time is somewhat weaker for summer migrants (e.g., fall chinook) than observed for spring migrants. Fall chinook have a more complex migratory behavior than spring migrants, with fish size, feeding, and rearing all affecting their migration.
NMFS science does shows a positive correlation between flow and survival for fall chinook smolt in the free flowing sections of the Lower Snake. However many experts believe this correlation is caused by other environmental factors. A new study by Anderson, Hinrichsen and Van Holmes (2000), concludes that Hells Canyon flow augmentation is detrimental to fall chinook due to the increase in temperature from the warmer upstream flows.
It is difficult to understand, in light of the information presented in NMFS own science discussion, why the Federal agencies continue to rely on this failed recovery measure. The agencies seem to have an irrational attachment to flow. This is again demonstrated in the totally erroneous conclusions drawn at the end of the flow augmentation discussion of the Hydropower Appendix to the All-H Paper. The conclusions stated are:
In summary, research suggests that the spring flow objectives outlined above are reasonable. Flow augmentation not restore historic flow conditions, but survival ratesfor juvenile spring/summer chinook passing eight dams approach the levels observedfor fish passingfour dams. This suggests thatflow management coupled with other passage measures has had a positive effect on juvenile survival.
NMFS own science suggests exactly the opposite conclusion. While juvenile survival in the Lower Snake Is at an all time high, flow augmentation has made no contribution to that survival. And now data shows that it might even be detrimental. Yet, NMFS is advocating for even greater flows from Idaho.
It is time for NMFS and the fish managers of the Northwest to stop advocating flow augmentation as a one size fits all solution. More water does not necessarily mean more fish, and in some cases, such as flows during the summer from the Upper Snake, it may be extremely harmful.
The case for dam breaching is no better. This is not a battle over PATH or CRI, this issue is being driven by the hard data being collected in the PIT tag studies.
However, it seems the discussion of breaching dams causes hearts to race and science to stagger. Advocates of dam breaching have been seriously hindered by the science in the past several years. That is why we believe the controversy over the validity of the CRI analysis is becoming so pointed. CRI is not new science. It is a risk assessment model that uses most of the same data contained in PATH, along with much of the later data from the PIT tag studies.
CRI does not point to dam breaching as a "silver bullet" that will solve ail of our recovery problems. Common sense tells us that there is no silver bullet in an issue this complex. However, even last winter, prior to most of the CRI analysis being completed, NMFS science documents did not support breaching.
Dam breaching does not come close to returning enough benefit to justify the staggering cost. NMFS research shows that the benefits of dam breaching are minimal, will take many years to realize and even then the benefits are speculative. The Anadromous Fish Appendix of the Corps EIS States:
CRI analyses suggest that no single management action is likely to result in sufficiently improved demography for spring/summer chinook salmon. For dam breaching alone to recover spring/summer chinook salmon, it would have to produce improvements in estuarine and early ocean survival as high as 80 to 100 percent, as well as an approximate 30 percent improvement in survival during upstream migration.
In fact, the CRI analysis indicates that the most effective way to help Snake River stocks is to aggressively pursue actions that improve survival in the first year of life and during their time in the estuary and entry into the ocean. The Anadromous Fish Appendix States:
On a more optimistic note, the CRI analyses suggest that a combination of improvements spread throughout the life cycle, and attained by a mixture of different management actions, could promote adequate annual population growth for spring/summer chinook salmon. Numencal experiments that correspond to manipulations of "current demography" indicate that small improvements in estuanne and early ocean survival orin the survival of newly born fish, will yield the greatest rewards in terms of enhanced population
The theoretical benefits of dam breaching are different for fall chinook and spring/summer chinook. For fall chinook, harvest reductions or moratoriums appear to have the same benefit as dam breaching, at a fraction of the overall cost. Fall chinook would also benefit, in a breach scenario, with increased spawning habitat. However, breaching the lower four Snake dams would restore only 7% of the historical fall chinook habitat; 90% of that habitat would remain unavailable.
Benefits of dam breaching for spring/summer chinook are even more speculative. The only way to show any benefit to this stock from breaching is to manipulate the "D" value of the latent mortality calculation. This is clearly outlined in the Anadromous Fish Appendix of the Corps EIS:
For spring/summer chinook salmon, there is no silver bullet that is likely to adequately reduce extinction risks. For dam breaching alone to recover spring/summer chinook salmon, very optimistic scenarios would need to be assumed about how much survival below Bonneville Dam could be improved due to the elimination of latent mortality not measured during inover downstream and upstream migration.
Delayed mortality is a theoretical concept that tries to explain potential survival differences between transported and in-river fish. To justify a breach decision biologically would require the presence of significant latent mortality. The All-H paper Hydropower Appendix States:
Before these fish return to spawn, they may suffer additional mortality that exceeds what would have occurred if they were not barged. This mortality is termed differential delayed transportation mortality (measured by the "D-value'J. This is one of the most important parameters with regard to deciding upon the role of juvenile fish transportation in salmon recovery and assessing the potential benefit of dam breaching.
NMFS own data argues against latent mortality. The All-H Hydropower Appendix contains the following statements:
Breaching the Lower Snake River may be considered if experimental management results find the level of delayed mortality associated with transpoffed fish is significant, particularly if transpoffed survival is less than estimated natural river survival levels.
Overall, direct survival of transpoffed migrants is high, estimated at greater than 98 percent. Behaviorand survival of transpoffed fish following release below Bonneville Dam is similar to that of in-ever migrants. Some people believe that indirect mortality of transpoffed fish is high (i.e., many of the fish that survived during transportation die later; delayed transportation moffalityJ, but this is a subject of ongoing research. Some have also suggested that fish that migrate in-ever and are undetected at dams return at higher rates than those that were transpoffed. While some differences in SARs exist between transpoffed and undetected in-river migrants, no sianiRcant differences have been observed. (emphasis added)
Since survival of in-river and transported migrants is "similar", and since NMFS sees "no significant difference" in the SAR's of transported and undetected in-river migrants, then there is absolutely no evidence of latent mortality. Without latent mortality, there is no biological justification for breaching the Lower Snake River dams, even without considering the enormous costs.
Additional factors argue strongly against breaching the lower four Snake River dams.
The Corps of Engineers estimates that 50-75 million cubic yards of sediment will be released into the river when the dams are breached. This majority of this sediment will be deposited in Lake
Wallula. The impact of this action on resident and anadromous stocks will be long term and severe.
In December of 1999, the Northwest Power Planning Council issued a report that estimates the need for 3000 MW of new electric power production by the year 2003. The four lower Snake dams produce 1,195 MW of power for the Bonneville system. Breaching these dams would increase the projected regional power deficit by 40%.
Breaching four dams on the Lower Snake River is not a viable option and should not be pursued.
Summary
Now is the time for action, not for continued argument over the nuances of science. The science will never be complete. However, between the controversial issues of breaching and flow augmentation, there is general agreement on many practical, achievable and productive salmon recovery measures. Actions such as:
Act immediately to limit pinniped, avian and pikeminnow predation Continuing to improve mainstem passage through by-pass improvements and surface collectors Continue to improve transportation methods Target funding to improving critical habitat areas where opportunities exist to significantly increase smolt production Limit in-river harvest to tribes and work on developing terminal fisheries Adopt hatchery practices that encourage conservation Research the effects of ocean conditions on specific stocks Enforce the Pacific Salmon Treaty
Now is the time for the region to step up to the challenge and implement these practical measures. We believe the best place for that to happen is in a regional forum led by the four governors. We need a recovery plan and the federal government needs to work with the region to develop one.
Now is the time for action on things we can agree on, not for continued argument over esoteric issues that are intended to support a biased political position.