Mr. Chairman and members of the Subcommittee, thank you for this opportunity to appear before you today on behalf of PNGC Power, an energy services cooperative owned by 16 Northwest rural electric cooperatives, including six from Idaho. Our comments on the draft Biological Opinion and Basinwide Salmon Recovery Strategy are summarized below.
Goals -- The Bi-Op and Recovery Strategy take significant steps forward in trying to look at species recovery in a comprehensive fashion. However, the goals in the Bi-Op and the Recovery Strategy fail to address a weakness that has continually hampered fish management in the Northwest: lack of prioritization and lack of reconciliation among conflicting goals in areas such as fish harvest and production.
Integration -- The two documents should make more aggressive strides to ensure that priorities, goals, and implementation of strategies are coordinated with the Northwest Power Planning Council's program, the four Governors outline, and Tribal programs.
Standards -- While the inclusion of the concept of performance standards for measuring results is worthy, many of the standards are incomplete and unevenly applied. In some areas there remain questions as to whether the measures are achievable at all.
Dam Breaching -- The best new science continues to deny the value of breaching as a salmon recovery tool. We object to the inclusion in the draft Bi-Op of a vague set of triggers towards breaching dams, including requests for preliminary design work. With limited scientific or legal basis behind this drastic action, we fail to see how references to it deserve treatment alongside reasonable and prudent alternatives in this Biological Opinion.
Getting the Best Value for the Investment -- The hydro system will continue to be a major focus of recovery efforts in this Bi-Op, and will continue to fund the bulk of the mitigation in the region. But, because science, as indicated by recent NMFS Science Center studies, shows that progress has raised hydro fish passage close to the point of diminishing retums, real success for recovery will require looking into other areas of the lifecycle. Efforts in the first year of life and in the estuary appear to be very promising in this respect.
Balancing Effort and Costs -- We are concerned that we have yet to see a comprehensive budget for the Bi-Op and draft Recovery Strategy that contains commitments from the many relevant Federal agencies and regional entities. A viable plan can not be a large blank check funded by the region's electricity customers.
Power System Reliability -- While curtailing fish and wildlife operations during power emergencies should not take the place of good resource planning, language should be included in the Bi-Op that recognizes the need to ensure human safety.
Introduction
Mr. Chairman and members of the Subcommittee, I appreciate this opportunity to appear before you today to discuss the National Marine Fisheries Service (NMFS) Draft 2000 Biological Opinion (Draft Bi-Op) on the Federal Columbia River Power System (FCRPS), and the Draft Basinwide Salmon Recovery Strategy. Thank you for showing the leadership to hold this hearing to scrutinize these issues. Clearly, they will have enormous impact on both the environment and the economy of our region.
I appear today on behalf of PNGC Power, an energy services cooperative owned by 16 rural electric cooperatives throughout the Northwest. Our Idaho members include Clearwater Power Company, based in Lewiston, Fall River Rural Electric Co-op, based in Ashton, Lost River Electric Co-op, based in Mackay, Northern Lights Inc., based in Sandpoint, Raft River Electric Co-op, based in Malta, and Salmon River Electric Co-op, based in Challis. We are a Northwest- based company that manages wholesale power supply and provides other technical services to our members and clients.
Our interest in the Bi-Op and other processes impacting salmon and the river system stem from two primary concerns. The first relates to maintaining the delicate balance between the environment and the agricultural economy. As electric cooperatives, our member utilities answer directly to their owner/customers. These customers have a genuine concern for the environment and enjoy our Northwest way of life. Whether they are hikers, campers, fishing enthusiasts, or hunters, they have a personal interest in responsible conservation of our natural resources. In addition, many of these customers make their living off of the land. They understand the need to protect the delicate balance that allows utilization of natural resources in a renewable manner. In fact, this understanding, and the desire of cooperative customers to create new environmentally friendly power sources, led our members to develop a landfill methane gas plant outside of Corvallis, Oregon that provides an innovative source of renewable energy.
The second primary concern these customers have is that degradation of our low-cost hydra resources will increase power rates and decrease the reliability of the West Coast power system.
Before commenting on the Bi-Op and the Recovery Strategy, I would like to highlight two important salmon management positions that will need to be filled in the next few months. From the perspective of the energy industry, the positions of Regional Director of the National Marine Fisheries Service (NMFS) and Administrator of the Bonneville Power Administration (BPA) play critical roles in the creation of balanced approaches on fish and wildlife issues. We would encourage you and your Senate and House colleagues from the Northwest to become involved very early as potential replacements are considered for these positions. Their importance to the region can not be overstated.
Goals, Integration, and Standards
Goals Viewed together, the Bi-Op and Basinwide Salmon Recovery Strategy ("Recovery Strategy") make significant steps forward in trying to look at species recovery in a more comprehensive fashion than previously attempted. The Recovery Strategy even sets out general goals for the region, an important step towards coordinating recovery efforts among the many regional entities.
However, the goals apparent in the Bi-Op and the Recovery Strategy fail to address a weakness that has continually hampered fish management in the Northwest: lack of prioritization and lack of reconciliation among conflicting goals. For example, it is not clear whether the region should be managing to optimize protected fish or whether it is attempting to optimize catchable, "hatchery origin" fish. Indeed, some have suggested that trying to manage for two types of fish may not be possible in the final analysis. This dilemma may loom large next spring with huge fish returns expected.
Senator Crapo's statement from the hearing this Subcommittee held on September 13th of this year posed the question: "what sense does it make to have a policy where we spill fish over dams then club them to death when they come back?" This hits the nail right on the head. And, one might add to this quandary the fact that we have spent large amounts of money at each of these steps, including creation of the hatchery fish in the first place. This begs for a clarification of the true goals, or a rethinking of the puzzling manner in which the government has chosen to define the particular stocks they wish to protect.
Need for Integration and Coordination -- The policy conflicts surrounding harvest and hatchery management create a good example of the need for increased integration and coordination of the region's fish and wildlife policies. Currently, there are nine Federal agencies and numerous State and local agencies actively involved in issues relating to salmon recovery in the Northwest. Even within NMFS itself there are dual roles associated with managing fish for harvest and protecting them for purposes of the ESA. To give you an idea of the growth of the salmon recovery industry, the directory of the fish and wildlife community created by the Columbia Basin Fish and Wildlife Authority contains around 1800 names from dozens of Federal agencies, State agencies, tribal agencies, regional entities, educational institutions, industry groups, and advocacy groups.
Integrating the myriad efforts underway in the region will be absolutely critical not only to ensure progress in species recovery, but also to attempt more efficient use of resources. Coordination on the funding, administration, and implementation of a recovery plan is absolutely crucial.
Those managing the Bi-Op should more aggressively seek to coordinate on goals, priorities, and timing not only with the Northwest Power Planning Council as it recreates it's own fish and wildlife program, but also with the four Governors who have outlined their priorities in a document released last summer, and with the Columbia River Basin Tribes.
Standards and Measures -- Once goals are established and integrated, one of the ways to create accountability is with specific and measurable performance standards. The Bi-Op and Recovery Strategy have some work to do in this respect. While we appreciate that they seem to embrace the concept of performance standards, the standards appear at times vague and unevenly applied.
If the intention is to develop the performance measures as time moves on, it will be important that they balance the need for flexibility (as further scientific and programmatic information is received) with the need to set targets that action agencies can rely on as they create their one and five year plans. This will not be easy.
Indeed, there are at least two concerns with these performance measures clearly evident from the start. One is that there does not seem to be any clear way to measure real performance in the hatchery and habitat areas, a problem compounded by conflicts in goals as discussed above. This is worrisome to ratepayers who will be asked to fund some of the efforts in these areas.
The second concern is that, as the performance measures develop, it is difficult to know whether standards set for the hydro system will be achievable at all by the five and eight year check-in times. It will be difficult to create regional agreement on this plan if these measures are impossible to meet. For example, the draft Bi-Op at 1.3.1.2.3 floats the concept of "Full Mitigation", a standard intended to reflect the level of fish survival that would have occurred had the dams never been built. Obviously, this raises serious questions about how such a theoretical set of measurements could be created with accuracy, and whether legal authority exists for demanding a standard that goes well beyond prospective "agency actions" and into reviewing the very existence of a facility.
Breaching Dams The triggers towards breaching the dams on the lower Snake River found in the draft Bi-Op at 9.1.8 and the call for funding to begin the process to breach dams found at 9.6.1.9 are problematic. For instance:
-- It is acknowledged today that breaching dams alone will not recover the lower Snake runs. We have no reason to expect it would work 5 years from now. Further, breaching will not assist the other 8 listed salmonid runs in the Columbia River System.
-- If the lack of clear unified management goals among Federal, State, and tribal fish managers makes improvements in other Hs difficult by the 5 or 8 years check-in point, the hydro system would be penalized for their failures.
-- The false hope of a silver bullet of breaching dams will be furthered even if passage through the hydro system continues to improve because targets might not be met through failures in harvest/hatchery policies, bad ocean conditions, or a host of other factors. Evidence of oceanic impacts is clear in studies by David Welch, Bruce Finney and others, and should be Pursued further.
-- In light of the newest and best available science, the logical and legal basis for a default to breaching dams is severely lacking. As discussed below, passage through the hydro system has improved almost to the point of diminishing returns.
-- Regardless of one's view of the science, a promise to move towards breaching dams in the future will not assist fish recovery in the present or during the time period of the Biological Opinion.
-- Certainly, because of the points raised above, preliminary engineering and design studies to breach dams are not warranted at this time.
Accountability
This hearing is focusing primarily on scientific issues with the Bi-Op. But, these are closely tied to management and accountability issues. For example, there is much debate about whether causal relationships exist with respect to salmon survival and flow augmentation. We are skeptical about the existence of this relationship, and would highlight the valid questions relating to turbidity, velocity, temperature, flow rates, and release of hatchery fish raised in a study released September 2000 by Karl Dreher of the Idaho Department of Water Resources. Likewise, there is fervent debate over nascent theories about relationships between hydro projects and mortality occurring later in the life of salmonids. By contrast, there is not much debate about the lack of a causal relationship between money expended on this issue and recovery of protected species. Each of these issues begs for more accountability.
Getting the Best Value on Investments -- Highlighting the amount spent on fish and wildlife does not imply that all of these funds have been wasted. Progress has occurred in specific areas. But, the lifecycle of salmonids being complex and geographically diverse, progress in one arena does not necessarily lead to progress overall.
This seems to be a theme echoed in the newest science to come from the NMFS Science Center in Seattle. And, this makes logical sense. Science shows that progress has been made in the hydro system that has raised survival close to the point of diminishing returns. Yet, some stocks continue to suffer. Real success in recovery will require looking into other areas.
According to NMFS White Papers relying on PIT (Passive Integrated Transponder) tag data, survival of Snake River spring/summer chinook through the hydro system have increased from the 30% range to around 60%. This is about the level of survival before the four Lower Snake dams were in place.
"Attachment A" contains an Oregonian newspaper editorial from last Saturday about the NMFS paper published in the November 3, 2000 issue of Science Magazine. In this paper, well- respected scientists Kareiva, Marvier, and McClure note that "dam passage improvements have dramatically mitigated direct mortality associated with dams." They go on to say that even if main stem survival were 100%, Snake River spring/summer Chinook salmon would continue to decline. And, they note that declines could be reversed with improvements in first-year survival or estuarine survival.
Large losses are natural within the first year of salmonid life. However, when one compares survival through the hydro system of 40-60% with survival in the egg to smolt period of 3-4%, it is easy to see how the first couple of years of life may provide broad possibilities for efforts in the habitat and hatchery arenas.
These findings by Kareiva et. al. should not surprise anyone. Other papers in recent years have indicated that this analysis was forthcoming, and the NMFS Science Center has held workshops in order to brief the public on their progress in this area. It is evident that there is a lot of bang for the buck to be found by looking at measures focusing outside of the hydra system. This effort should also include reevaluating some of the assumptions surrounding presumed benefits of the very expensive spill and flow regimes currently used.
Hydro Still on the Hook -- The improvements in fish passage referenced above came about because the FCRPS has undergone significant changes to improve fish survival during the last decade. Now, within flood control and safety requirements, the system is operated to maximize fish passage. Hundreds of millions of dollars have been invested in intake screens, surface by- pass systems, fish friendly turbines, transportation, gas abatement measures, and spill programs.
Northwest ratepayers are currently paying over $400 million per year for fish and wildlife efforts. As explained above, this amount may increase in this draft Bi-Op by another $100 million or more depending on market prices. Fish and wildlife expenditures currently comprise a whopping 20% of the BPA costs, a percentage that will increase in the rate period starting next year. For rural systems where distribution costs typically account for half of the retail rate, this means a full 10% of customer fills go toward fish and wildlife mitigation.
We've heard the view expressed that the hydro system is somehow let off of the hook in this Bi-Op because the Bi-Op does not immediately call for drastic actions such as breaching dams. This is not how we read this Bi-Op and Recovery Strategy.
The draft Bi-Op calls for increased effort in the river system including: continued and possibly enhanced flow augmentation; possible enhancement of spilling water for fish; and, enormous infrastructure investments in items such as spill deflectors and bypass systems. BPA estimates that the draft Bi-Op will demand at least another 70aMW of lost power generation added to the amount lost through previous Bi-Ops. This creates a total loss to the Federal system of 991aMW, or about the amount of energy it takes to provide electricity to a city the size of Seattle for a year. The cost of that lost energy depends on the market rates for power during the year. In addition, we have seen proposals for close to $50 million of additional ratepayer costs for BPA's direct Fish and Wildlife program, and another $40-50 million for increases in capital costs and reimbursements to other agencies.
During a short period in August, with prices for power skyrocketing, BPA lost approximately $40 million to fish operations. This begs two questions: First, do these spill operations always help fish? In the last spill agreement reached among river managers, spill was reduced at The Dalles Dam because studies there showed that the higher rate of spill was harming fish. The Bi-Op and Recovery Strategy should not automatically assume benefits from spill, and should promote continued study and reconsideration of this practice.
Second, should there be a cost/benefit decision-making process associated with these operations. If spilling water is going to cost $40 million of ratepayer funds in the span of a few days, the potential benefit of that operation should be weighed against other assistance for fish that might be purchased with that large sum of money. What benefits to fish or to the regional economy are lost in these scenarios? A regional salmon recovery strategy should consider these cost/benefit questions.
Balancing the Costs -- The draft Bi-Op also calls for a balancing of the effort into other areas in order to respond to what the science is telling us about the progress in hydra system passage to date, and about the potential for gains in other areas of the salmon lifecycle. We suspect that BPA ratepayers will be asked to fund a significant portion of those non-hydro efforts. However, ratepayer funding can not be the exclusive source of Endangered Species Act (ESA) funding for the region. In fact, the Northwest Power Act does not permit BPA funds to be used "in lieu" of fund responsibilities of other entities.
We are concerned because we have yet to see a comprehensive budget for the Bi-Op and draft Recovery Strategy. While we suspect that ratepayers will be asked to pick up a large portion of the tab, we have yet to see budget commitments from other Federal agencies or regional entities. The Endangered Species Act is a national law with national implications. Salmon and steelhead listed under this act are species that are impacted by myriad factors well beyond the reach of the hydro system. This effort should call for specific budgets and extensive funding commitments from the various Federal agencies, especially the U.S. Fish and Wildlife Service, the Army Corps of Engineers, the Bureau of Reclamation, the Forest Service, and the National Marine Fisheries Service. To be viable, this plan can not become a very large blank check funded on the backs of the homeowners, farmers, and ranchers who are contractually obligated to buy power from the FCRPS over the next 10 years.
Power System Reliability and the draft Bi-Op
The Northwest Power Act States that the Northwest Power Planning Council should create a program to mitigate for impacts to fish and wildlife while assuring the Pacific Northwest an adequate, efficient, economical and reliable power supply.
Operation of the hydra system for fish is inextricably tied to reliability of the West Coast power system. This is especially true when power supply is short. As alluded to above, power costs skyrocketed to as high as $700 MWh this summer when supply was short. And, there is good reason to be concerned about potential power supplies this winter and next summer.
Ironically, in the same issue of Science Magazine in which Dr. Kareiva's article appeared on November 3, 2000 there was an article entitled "Decreasing Reliability of Energy" by editor Philip Abelson. This article notes the greatly increasing demand for electrical power in the United States, potentially rising from 40% of all power usage now to 70% by 2050. Demand is expected to grow by 20% in the next decade alone, while planned growth of the transmission system is only expected to be around 3.5%.
At the same time that demand for power is increasing, there is continued movement to discourage use of fossil fuels. Last week, President Clinton called for Federal regulations limiting power plant emissions of carbon dioxide. This forces some very difficult questions about how we will prioritize our sources of power in the future.
In our region, the Northwest Power Planning Council has estimated that we will have a one in four chance of not getting through the winter without a supply interruption over the next few years. This is five times worse than the normally accepted standard. In order to bring our region up to standard, it would require almost 3,000 megawatts of new generating resources by 2003.
To address the potential for trouble with power supply in relation to the salmon recovery effort, the Northwest Power Planning Council has requested that language be included in the Bi-Op to address several concerns. We concur with their request to include the following:
-- In emergency situations, fish and wildlife operations can be curtailed. (This is simply a no- nonsense issue relating to human safety concerns).
-- The option of curtailing fish and wildlife operations during emergencies should not be used in lieu of establishing and adequate and reliable power system. (Certainly, power supply concerns in the Northwest go far beyond operations for fish and should be planned for as such).
-- The option of curtailing fish and wildlife operations should be viewed as a last-resort action. An emergency protocol should be developed that incorporates not only curtailment of fish and wildlife operations but also whatever other actions could be helpful to alleviate the situation.
-- Proposed new resources (whether generating or demand-side) that integrate more effectively with fish and wildlife operations should be given priority.
Conclusion
This Subcommittee knows well that the Endangered Species Act can not be implemented in a vacuum. Because it coexists with many other laws and priorities, reasonable and balanced solutions are needed to meet it's mandates. The draft Bi-Op and Salmon Recovery Strategy take some important first steps towards creating a balanced scientifically based recovery plan. But, there is a lot of room for clarification and improvement.
Success in this challenge will be extremely difficult unless increased efficiency of effort can be achieved, including accountability not only for results across all Hs but also for each dollar spent. Without clearer goals and better accountability we will succeed only in continuing to create the sense of crisis that ensures increased expenditures without real results to show for our effort.
It is our hope that your interest in this issue, including your continued demand for the best scientific knowledge possible, will help lead the region to a coordinated approach to real recovery of these precious species. Again, thank you for your efforts, and thank you for this opportunity to testify today.
Peer-reviewed article in journal Science makes strong case that breaching dams is not best way to save salmon
No matter who winds up winning the White House, it's quite clear that neither the next president nor Congress will recommend breaching four dams on the lower Snake River anytime soon.
Those who have campaigned so vigorously to remove the Snake dams no doubt will be disappointed, and may charge that a decision to leave the dams intact is politically motivated.
But the truth is dam-breachers are losing the fight on scientific grounds.
Recently, the Federal Government's top salmon researchers, in an article published in the respected journal Science, an arm of the American Association for the Advancement of Science, concluded that breaching dams probably isn't an effective way to save salmon from extinction.
The article by Peter Kareiva, Michelle McClure and Michelle Marvier of the National Marine Fisheries Service lays out a solid case for leaving the dams. It argues that increasing salmon survival in the early life stages before the smolt reach the four dams -- and later in the Columbia estuary, below all eight dams in the Snake River salmon's path -- would have the greatest impact.
Under some of article's assumptions, the improvements in survival from removing dams would be too little to save Snake River spring/summer chinook. The article drives this point home by saying. "Remarkably, even if every juvenile fish that migrated downstream survived to the mouth of the Columbia," the salmon would continue to decline.
Put another way, breaching the four Snake River dams isn't likely to benefit the Snake River-bound fish as much as earlier scientific opinions suggest.
The fisheries service's monitoring studies, in which salmon are collected and tagged before they make the trip to the sea, not only give us information about where fish go, they also tell us a lot more about where and how they die.
As a result, some of the salmon deaths that have been blamed on the dams -- speculative estimates that have tilted computer models in favor of dam breaching -- are probably caused by other factors, such as predation and declining habitat for rearing salmon.
The Science article adds credibility to the fisheries service's findings. The agency is expected to complete its policy paper next month, likely recommending that the region forego dam breaching for now and take other actions to help salmon.
Those actions include restoring the Avers and streams where salmon spawn, restoring the Columbia River estuary where young salmon feed and grow before heading out to sea, reducing harvest, improving fish passage around the dams and overhauling antiquated hatchery practices.
As we learn more about what happens to the salmon in their various fresh water stages, the science is tilting away from dam breaching. Perhaps we don't know enough yet to take dam removal off the table, but the current is running against it.