STATEMENT GLEN SPAIN, OF THE PACIFIC COAST FEDERATION OF FISHERMEN'S ASSOCIATIONS (PCFFA)
TO THE SENATE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS,
SUBCOMMITTEE ON FISHERIES, WILDLIFE AND WATER
Washington, DC
September 14, 2000

My name is Glen Spain. I am the Northwest Regional Director of the Pacific Coast Federation of Fishermen's Associations (PCFFA), the west coast's largest organization of commercial fishermen and fishing families, which represents the interests of thousands of small and mid-sized family-owned commercial fishing operations working in ports from San Diego to Alaska. We are also America's oldest industry. Our members provide this country with one of its most important and highest quality food resources as well as a major source of exports. Our efforts provide tens of thousands of jobs in coastal communities supported by the bounty of the sea. PCFFA is a federation of 25 different port and small to mid-sized vessel owners' organizations coastwide, representing a combined vessel asset investment in excess of $1 billion.

Thank you for the opportunity to testify on this very important issue of salmon restoration in the Columbia Basin -- a subject that means life or death to many west coast fishing-dependent communities. The mainstay of our industry has always been Pacific salmon until recent salmon declines, particularly in the Columbia, have made that impossible. Decades of serious declines in salmon runs from the Columbia, once the most productive salmon river system in the world, have dramatically affected the commercial fishing-dependent economies of California, Oregon, Washington and Alaska as well as devastated the recreational fishing economy of Idaho. The current Biological Opinion (BiOp) under consideration by this Committee is the latest and most important effort to reverse those declines and help restore our industry.

Fishermen are family food providers, but in order to be able to produce high quality seafood and maintain tens of thousands of jobs in coastal communities, we must have something to catch! Most of our people are now, or have been, salmon fishermen. However, every year for decades now there have been fewer and fewer fish coming out of damaged west coast watersheds. Widespread habitat loss and the destruction wrought by the multitude of west coast dams, many no longer cost effective or even needed, has now pushed many once abundant wild salmon runs to such low numbers that NMFS has had to put 25 separate and distinct runs of Pacific salmon and steelhead on the Federal Endangered Species list. Twelve of those listed runs -- among them runs historically among the most important to the existence of a west coast commercial salmon fishing industry -- are now in the Columbia Basin.

COLUMBIA RIVER DECLINES HAVE DEVASTATED THE WEST COAST FISHING INDUSTRY

Once the most productive salmon-producing river system in the world, wild salmon runs in the Columbia Basin are now at less than 2% of their historical run size. As we speak, nearly every salmon run in the Columbia River has been listed under the Endangered Species Act. However, the current depressed status quo does not come cheaply. Salmon mean business. Fewer salmon mean fewer jobs, less cash flow and fewer tax dollars to every coastal and many inland communities. Salmon declines have cost money a lot of money in the form of lost economic opportunities, shrinking tax bases and lost jobs.

In fact, the mismanagement of the Columbia and Snake River Federal Hydropower System that has plunged these runs toward extinction has cost the regional economy at least 25,000 fishing-dependent family wage jobs, and drained more than $500 million/annually from the west coast economy in the form of lost economic opportunities. At least a fifth of these losses 5,000 jobs and $100 million/year are directly attributable to declines in the Snake River which in turn are clearly linked to high salmon mortalities caused by the lower Snake River dams (Ice Harbor, Lower Monumental, Little Goose and Lower Granite Dams), a system of four dams completed in 1975. Once booming downriver fishing ports such as the Port of Astoria are now in serious economic decline. In recent years, since Snake River chinook and sockeye can migrate widely both north and south, the Pacific Fisheries Management Council (PFMC) has had to impose salmon fishing restrictions to avoid their accidental bycatch all the way to Central California and well up into Southeast Alaska at a cost to these ports of many tens of millions of dollars annually in lost harvest opportunities. Columbia River stocks are thus 'key stocks' in the whole west coast salmon fishery management. In other words, even though there may be millions of healthy wild and hatchery-produced fish out there in the ocean, our people are foreclosed from catching them for fear of even accidentally impacting these weakest (and now ESA listed) stocks. The Columbia salmon are also the key to meeting the US allocation commitments to the Pacific Salmon Treaty with Canada, and past Columbia declines lead directly to the Treaty's collapse in years past..

The positive side of all this is that the economic return on your investment in Columbia and Snake River salmon restoration efforts, if done properly, will be very large. And I want to emphasize that salmon restoration efforts in the Columbia are an investment, not a cost. If properly done, much of the $500 million/year now lost to the regional economy because of salmon declines could be recaptured in perpetuity as part of a sustainable west coast fishing industry. Our priority -- as a major economic interest in the Columbia Basin as well as in the coastal economies of California and Alaska -- is in restoring the salmon, and in so doing restoring the lower river and coast economies that depends upon those salmon. If the best available science says that this means that some of the Lower Snake River dams must be decommissioned, then we support those measures and will work with upper river users to mitigate and manage these changes. However, if Columbia River salmon recovery can truly be accomplished without decommissioning the lower Snake River dams, obviously this would be far better as well as far more politically feasible.

IMPORTANCE OF COMPLETING THE COLUMBIA RIVER BIOLOGICAL OPINION (BiOp) In general, we support the Administration's current BiOp approach: "Let's really try whatever we can do right now to offset and mitigate for losses in the dams, including major efforts to improve flow and restore critical estuary and tributary habitat now, and carefully monitor the results to see if we can achieve recovery short of decommissioning Snake River dams." In other words, this BiOp sets up a test of the easiest to achieve options first. We believe that this is by and large a sound and rational strategy.

However, if that effort does not work, other necessary measures must then be taken, up to and including selective dam decommissioning in the Snake River. In the meantime, on the possibility that these non-dam measures may not work, we must also plan for that alternative just as a matter of insurance. Otherwise we are committing all our eggs to a single basket which may not hold them. If the BiOp Plan fails, and we do not make what would then be the only other possible decision, the only other alternative would be to plunge the whole Northwest hydrosystem, and the whole region, into political and economic chaos.

The importance of completing this Biological Opinion on the operation of the Columbia River Power System (now out for public comment) as soon as possible cannot be overstated. The whole Columbia federal hydrosystem teeters on the verge of chaos. The states have shown themselves incapable of coming to any lasting consensus on the management of the system (through the Northwest Power Planning Council or otherwise) and the federal government is now faced with serious and pervasive ESA conflicts, Clean Water Act conflicts, and potential litigation by Treaty Tribes for the abrogation of their treaties. Postponing decisions will not make them cheaper, it will make them much more difficult to achieve and therefore much more expensive.

In addition there are continuing calls for the federal government to divest itself entirely of the Bonneville Power Administration (BPA) by taxpayer watchdog groups and Congressional budget hawks outraged by the massive and pervasive federal subsidies that are now propping up the system, and those arguments will only be proven correct if BPA and the region continue to be unable to solve these problems. These problems are not getting any easier either as time goes by.

THE BIOLOGICAL OPINION FRAMEWORK IS WORKABLE

Though it has serious flaws (as outlined below), and the BiOp is clearly a first draft, the overall framework of the Biological Opinion is, we believe, the correct one. In fact, there are twelve (12) major salmonid ESU's within the basin with declines that must be reversed, only four (4) of which are in the Snake River. Though most of the controversy has revolved around the Snake River, obviously breaching the Snake River dams alone will do little to help the other eight (8) runs. The BiOp recognizes that something more needs to be done to benefit all the runs.

Many of the measures (such as increased flow augmentation and estuary habitat protection and restoration) are clearly going to benefit not only the most seriously depressed runs in the Snake River, but all the other runs as well. Many of these measures are necessary to salmon restoration. What remains to be seen is whether these measures, alone, will be sufficient for actual recovery, and if so for which of the twelve (12) listed runs? In order to ascertain whether these measures work, the BiOp requires: (1) specific performance standards and specific measures to be taken; (2) a clear and ongoing monitoring mechanism to see whether performance standards are in fact being met and take appropriate actions is they are not. The BiOp clearly is designed to provide both, though details are so far sketchy.

However, in addition, there are consequences for inability to meet performance standards. This includes the failure of Congress to fund the required measures. This BiOp is the only scientifically and legally viable plan available to avoid the necessity of decommissioning the lower Snake River dams. Without Congressional support particularly full funding so that all its measures can be implemented in a timely way this Biological Opinion will fail, and Snake River dam decommissioning will then be left as the only available option. Failing to act would plunge the region into political and economic chaos. The status quo is not working, so doing nothing is also not an option.

However, this Plan must be taken and funded as a whole. The BiOp is like a fine tapestry removing the warp from the woof will yield nothing but an unconnected pile of threads. Efforts by certain members of Congress to 'cherry pick' what provisions of the whole plan they wish to implement will inevitably crash the plan.

THE FLAWS IN THE BIOLOGICAL OPINION THAT NEED TO BE FIXED

That said, there are still a number of serious systemic flaws in the Biological Opinion that need to be fixed if it is to constitute a valid recovery effort. These flaws include:

(1) Lack of Specific Performance Standards: The agencies admittedly are still developing both biological and implementation performance standards by which to assess whether the plan is working or not. Obviously there must be ascertainable recovery targets in the BiOp. Many of these performance standards still need to be worked out, and the lack of any detail on most of those standards is a serious problem in the current Draft. The Administration admits this problem and is attempting to develop specific performance standards at this time.

(2) Lack of Detailed Measures: Again, lack of detail in terms of what specific measures will be required makes it difficult to assess precisely what actions will be done under the BiOp, who is going to perform them or to weigh their likely effectiveness. Again, these details must be filled in before the BiOp constitutes a legitimate recovery pathway.

(3) Lack of Cost Estimates of Measures: Obviously, if it cannot be ascertained what the recovery targets are nor what specific measures must be undertaken to achieve them, then it becomes impossible to estimate either the costs of the measures or their economic impacts on other industrial sectors such as ours. It also becomes impossible to accurately weigh those costs against the known costs of Snake dam decommissioning, or against the enormous ongoing costs to the economy of the current failed status quo. Clearly we need to know as soon as feasible just how much these non-breach options will cumulatively cost as the alternative.

(4) Check-ins Too Infrequent or Too Late: Currently the BiOp contains only year five (5) and year eight (8) check-ins to see how the plan is being implemented and whether it is effective. These check-ins need to be annually, with a major 'decision-point' check-in at year three (3). By year three (3), we will know whether the required recovery measures are being scheduled and funded by Congress. By year three (3) we will know pretty well whether the Plan is going to even be implemented. There will also likely have to be occasional changes to the BiOp as we implement adaptive monitoring. Long check-in time frames work directly against flexibility and efficient implementation and will likely cost us all a lot more in the long run. Annual report cards avoid this problem.

(5) Lack of 'Hard-wired' Decision Points: At some point, if this Plan fails, there will have to be some very serious decisions made. This Plan is, frankly, the best and likely the only option for recovery short of decommissioning at least some dams (those in the lower four Snake River). Biological or political failure of this 'in-lieu of breaching' strategy would leave no choices remaining but to decommission some or all of the Snake River dams. This should be acknowledged up front. The laws of nature are very unyielding, and the options available are becoming increasingly limited not by policy considerations, but by basic rules of hydrology, biology and physics.

IT'S TIME TO PUT UP OR SHUT UP The Northwest ratepayers and federal taxpayers have already expended more than $4 billion on Columbia River salmon recovery efforts, relying for three decades very heavily on artificial salmon collection and barging and trucking programs which were never thoroughly tested and which clearly have not worked. The BiOp also relies much too heavily on those failed programs, but also includes habitat and estuary restoration, hatchery reforms and fish passage modifications that are all long overdue, and likely will benefit not only the Snake River runs but all twelve (12) listed subspecies. While we (as do most scientists) remain highly skeptical about whether all the measures in the BiOp combined will, in and of themselves, be enough to offset the up to 88% mortality inflicted by the whole gamut of dams culminating in the Snake River dams, we believe there is good logic in giving it the best possible try to see if we can achieve recovery.

A number of political leaders have stated that they believe that all other feasible measures throughout the whole system should be tried before resorting to decommissioning Snake River dams. Both politically and administratively this makes sense. However, we believe the time is now here for opponents of dam decommissioning generally to 'put up or shut up.' The Biological Opinion now on the table is their only viable alternative to dam decommissioning.

Legally the BiOp is a 'jeopardy' finding, subject to an integrated set of mandatory mitigation and recovery measures which, if implemented, may overcome jeopardy. Any effort by members of Congress to 'cherry pick' only the elements they like or to eliminate funding for options they may not like (through the appropriations process or otherwise) creates the huge risk that the BiOp as a whole will fail. Failure would inevitably lead once again into chaos, a huge potential Treasury liability and probable takeover of the whole system by the Courts. Personally I do not consider that kind of chaos a viable alternative.

This is why we are greatly concerned about various efforts by some of these same Members of Congress to impose riders and other budget limitations that would defund major portions of this overall Plan. The most important implementation element of this restoration Plan is Congress itself. If Congress does not fully fund its part, the BiOp's Plan will most surely fail.

The BiOp is a single tapestry, and it will not hold together legally or politically unless all its required treads are woven together and funded in a timely fashion. Plunging the region into widespread chaos, and plunging our own major industry into further economic disaster, are not 'plans' and cannot be considered viable political or economic options.

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THE PACIFIC COAST FEDERATION OF FISHERMEN'S ASSOCIATIONS

The Pacific Coast Federation of Fishermen's Associations (PCFFA) is the United States west coast's largest organization of commercial fishermen and is a non-governmental, non-profit corporation organized in 1976. As a federation, its membership is composed of 25 U.S. west coast commercial fishermen's port associations and vessel owner's associations spread from San Diego, California to northern Alaska. Fishermen belonging to PCFFA member organizations engage in a variety of fisheries, including those for salmon, crab, pink shrimp, albacore, rockfish, shark, halibut, swordfish, sea cucumber, sea urchin, squid and herring.

PCFFA provides its member associations with a full time staff to address fisheries education, communications, habitat protection, and legislation. PCFFA represents its member associations at the local, state, regional and national levels on all fisheries issues before many commissions, councils and legislatures throughout the Pacific region, and before the U.S. Congress. PCFFA also has fishermen's health care programs for fishermen belonging to its member associations. PCFFA is involved in fisheries enhancement and publishes print and electronic newsletters to alert the fishing industry to current issues that should concern it.

Since the health of our industry depends on healthy marine and anadromous fishery resources, much of PCFFA's efforts are directed at habitat protection. This includes issues dealing with water quality and quantity, wetlands protection, offshore oil pollution, ocean dumping, water pollution and maintaining the healthy watersheds and estuaries which are the nursery grounds for the many species upon which our industry depends. Our INTERNET WEB SITE IS:

http://www.pond.net/~pcffa

This site contains Internet links to our member groups, other fisheries organizations and many other useful resources for commercial fishermen throughout the world. It also links to our sister organization, the Institute for Fisheries Resources, which is dedicated to ocean and anadromous resource protection throughout the Pacific.

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THE MEMBERS AND BOARD OF DIRECTORS OF THE PACIFIC COAST FEDERATION OF FISHERMEN'S ASSOCIATIONS

The Board of Directors of PCFFA is composed of 25 major commercial fisheries organizations on the U.S. west coast from San Diego to Alaska. Each group is represented on our Board by that group's President, Executive Director or designated Representative. The current Board membership is as follows:

Commercial Fishermen of Small Boat Commercial Salmon Santa Barbara, Inc. Fishermen's Association

Commercial Fishermen's Trinidad Bay Fishermen's Organization of Morro Bay Marketing Association

Crab Boat Owners' Association Southern California Trawlers Association Del Norte Fishermen's Marketing Association Golden Gate Fishermen's Association Fishermen's Marketing Association of Salmon for All Bodega Bay Federation of Independent Salmon Trollers' Marketing Seafood Harvesters (FISH) Association United Fishermen of Alaska Half Moon Bay Fishermen's Marketing Association Ventura Commercial Fishermen's Association Humboldt Fishermen's Marketing Association Central California Longline Association Moss Landing Commercial Fishermen's Association Washington Trollers Association

Port San Luis Commercial Western Fishboat Owners' Association Fishermen's Association Monterey Fishermen's Marketing Santa Cruz Fishermen's Association Marketing Association Shelter Cove Commercial Fishermen's Golden State Trollers Association Association PCFFA is by far the largest and most politically active organization of commercial fishermen on the U.S. west coast, and is active on all local, regional and national issues affecting our fisheries.