Federal officials this
week said that a better scientific understanding of the fish
and their needs, and an infusion of resources to meet those
needs over the next 10 years, will lift 13 threatened or
endangered Columbia River Basin salmon and steelhead stocks
Two draft NOAA Fisheries Service biological
opinions released Wednesday describe specific actions to be
taken – hydro system operations, hatchery and harvest reforms
and/or habitat improvements -- for each of the 78 populations
that make up those listed stocks.
Implementation of the entire package represents an increase
in federal spending on Columbia Basin salmon recovery over the
next 10 years of at least $1 billion, according to federal
Analysis of those separate sets of actions indicates they
will push population curves upward, though at different rates
because the status of some is more dire. The BiOps were
produced to judge whether federal Columbia/Snake River
hydropower and irrigation projects jeopardize the 13 stocks.
NOAA's draft says the plans not only avoid jeopardy but raise
hope for recovery.
"Our focus has been on what you need" to do to avoid
jeopardy and spur recovery, Bonneville Power Administration
CEO Steve Wright said in answer to a question about the
potential costs of the BiOps' implementation.
As marketer of the power generated in the federal system,
BPA has an obligation to pay fish mitigation costs, which
include changed hydro operations such as spill for fish
passage – which represents foregone generating opportunity.
BPA and the dam operators -- the U.S. Army Corps of Engineers
and Bureau of Reclamation -- built the action plans that were
judged in the BiOps, including in their biological assessment
long lists of actions intended to improve salmon and steelhead
The costs estimates were based on measures described in the
"action" agencies plans, which were released in late August
The cost estimates are "fairly ballparky, but also
conservative, I would say," according to BPA's Sarah McNary.
A big chunk of that increase will fund capital improvements
at the dams and research to improve fish survival up and down
the system. Full implementation would lift spending to $1.6
billion over the period, as opposed to about $1.1 billion over
the past 10 years, according to the Corps' Rock Peters. That
program is funded through congressional appropriations but the
expenditures are reimbursed to the U.S. Treasury by BPA.
"The other big increase is the habitat program. The level
of effort there will double" to about $45 million in BPA
funding annually for work in tributaries and the estuary,
McNary said. The Corps and Bureau will fund additional habitat
McNary said the ESA-focused habitat funding increase would
be in addition to that spent by BPA through the Northwest
Power and Conservation Council's fish and wildlife program.
"Hundreds of individual habitat actions" are outlined in
the NOAA documents, according to the agency's regional
administrator, Bob Lohn.
Almost $35 million will be spent over the BiOp period to
fund new hatchery facilities and another $5 million per year
to fund new, hatchery facility-related expenses, according to
the August estimates. Those measures include construction of a
Nez Perce Tribe supplementation facility -- the Northeast
Oregon Hatchery -- and an expansion of the production
capability for Redfish Lake sockeye. Expenditures also target
the implementation of hatchery reforms at existing hatcheries,
Accompanying the newly released draft BiOps is a
"Supplemental Comprehensive Analysis" that charts individual
fish populations' abundance trends and projects improvements
resulting from proposed hydro system operational and
configuration changes, hatchery reform, habitat improvements
and other actions.
The proposed actions over the next 10 years "will not only
prevent harm to threatened and endangered salmon, but will
ultimately move the species towards recovery," according to a
NOAA Fisheries press release announcing the release of draft
biological opinions for the Federal Columbia River Power
System (727 pages with appendices) and for multipurpose Bureau
of Reclamation projects on the Upper Snake (564 pages).
The BiOps and associated documents can be found at
The draft documents call for "hundreds of millions of
dollars of research" to affirm the projected gains in salmon
and steelhead abundance, according to the press release.
The BiOps include analysis far more detailed and tailored
to individual fish populations than has been used before.
"Through this process, our understanding of the salmon
lifecycle has increased dramatically," Lohn said. "This
rigorous scientific review provides us with a great degree of
certainty that these actions will lead to salmon recovery."
The BiOps, replacing documents declared illegal in 2005 and
2006, "spell out an aggressive and comprehensive series" of
actions aimed at mitigating for negative impacts on fish
stemming from the Columbia/Snake hydro system and Upper Snake
River projects, used primarily to provide irrigation.
The BiOps were built following a collaboration with
Northwest tribes and states aimed at narrowing areas of
scientific agreement on the course of action for reviving
diminished Snake and Columbia salmon and steelhead stocks.
"There is no single cause for salmon population declines
and there will be no single solution," Lohn said. "The only
course of action is a comprehensive plan coordinated with
state, local and tribal partners. These BiOps lay the
foundation for restoration."
The collaboration group worked exhaustively to resolve
issues, holding more than 300 technical and policy meetings
over the course of nearly two years, according to the press
"This process taught us that the commitment and resolution
for salmon recovery have not diminished," added Lohn.
The new BiOps "raise the bar for determining jeopardy" in
answer to a Ninth Circuit Court of Appeals ruling that NOAA
must judge whether the listed stocks have an "adequate
potential for recovery," Lohn said.
"By the end of the decade we want to point at all of the
ESUs and say they are significantly improved," according to
Lohn. Some, such as Snake River sockeye and Upper Columbia
steelhead, represent stiffer challenges, he said.
The analysis also takes into account ocean conditions and
climate change. For example, survival rates are judged on the
assumption ocean conditions will follow the same pattern over
the next 22 years as they did the past 22 years, four years of
ocean conditions that are favorable and 18 that are
unfavorable for salmon survival. That assumption ignores the
fact that the past 50 years show an even split.
"In other words, the analysis of benefits expected under
the proposed action is based on a deliberately conservative
approach," the executive summary says. "While neither the
federal action agencies nor NOAA Fisheries are in a position
to predict what future weather and ocean conditions will occur
over the next ten years, if conditions are more consistent
with the historical average, then the results obtained from
the proposed action are likely to be considerably better than
those estimated in this analysis."
"We think it's important that we don't assume the best"
ocean conditions in calculating overall lifecycle survival
improvement needs, Lohn said.
The new strategy's mix of action agency proposals and NOAA
additions includes numerous changes, from the 2004 BiOp. They
includes changes to hatchery operations, such as a requirement
that the Winthrop National Fish Hatchery in central Washington
adjust its broodstock management to produce fish more closely
resembling historic patterns of Upper Columbia steelhead.
There is more prescribed spill in some cases, and less in
others. Daytime spill at Bonneville Dam, as an example, will
jump to 85,000 cubic feet per second as compared to the
current 75 kcfs formula to test for juvenile survival
improvements, according to the Corps' Witt Anderson.
The agencies also plan to curtail spill in August at four
lower Snake dams after the number of migrants has dwindled.
And if numbers pick up, the plan calls for a resumption of
spill. Court orders have required spill at the dams through
August during the past three summers.
Transportation regimes may be changed in spring, to reflect
the most recent data regarding the survival of fish barged
downstream as compared to being allowed to proceed in-stream.
The proposed action and analysis submitted by the Corps,
Bureau and BPA in August reached the conclusion that operation
of the FCRPS projects, without further mitigation, would
jeopardize listed species. That proposal included additional
measures designed to benefit listed species and tilt those
abundance trends away from jeopardy and toward recovery.
"NOAA Fisheries has included in its analysis the additional
mitigation proposed by the Federal Action Agencies, as well as
other mitigation measures that NOAA Fisheries believes are
needed to avoid jeopardizing the listed species," according to
an executive summary of the draft documents.
"Collectively, these additional actions are called, in the
language of the ESA, a "reasonable and prudent alternative.'
The reasonable and prudent alternative for the FCRPS
operations contains 73 detailed sets of additional mitigation
actions that are required to avoid jeopardy and adverse
modification of critical habitat," the 83-page summary says.
The cost estimates produced in August have yet to be
refined to include the modifications and additions encased in
the draft FCRPS BiOp's "reasonable and prudent alternative,"
The BiOps are based on a much broader, more comprehensive
and more rigorous method of analyzing salmon-population
changes than has ever been attempted before, according to the
NOAA Fisheries analyzed a wide variety of measurements and
factors for each of the individual salmon populations that
make up the 13 listed "evolutionarily significant units.
Measurements included a species' current abundance trends, its
likelihood to rebound from low population levels, and the
geographical distribution of the population.
U.S. District Court Judge James A. Redden's May 2005 order
listed the flaws of the 2004 FCRPS Biological Opinion, and
ordered NOAA Fisheries to correct:
-- its improper segregation of the elements of the proposed
action NOAA Fisheries deems to be nondiscretionary;
-- its improper comparison, rather than aggregation, of the
effects of the proposed action on the listed salmon and
-- its flawed determinations as to whether the proposed
action destroys or adversely modifies critical habitat;
-- its failure to consider the effects of the proposed
action on both recovery and survival of the listed species in
determining whether the proposed action is likely to
jeopardize the continued existence of listed salmon and
-- its past reliance on mitigation measures that are not
reasonably certain to occur and/or have not undergone Section
A year later, the judge ruled that a 2005 BiOp for the
Upper Snake BiOp was based on the same analytical flaws.
NOAA Fisheries says it has addressed these flaws directly
in its draft 2007 Biological Opinion for the FCRPS. In
"-- NOAA Fisheries' analysis aggregates the effects of the
FCRPS proposed actions as modified by NOAA Fisheries'
reasonable and prudent alternative, the Upper Snake basin
proposed actions, the transportation permit (all together
referred to as 'Prospective Actions', with the continuing
effects in the environmental baseline and anticipated future
state and private actions (termed Cumulative Effects) on the
listed salmon and steelhead, as reported in Chapter 8 of the
Supplemental Comprehensive Analysis for each species.
"-- NOAA Fisheries revised its analytical treatment and
effects of the proposed action on critical habitat, as
reported in Chapter 8 of the Supplemental Comprehensive
Analysis for each species.
"-- NOAA Fisheries addressed both the prospects for
recovery and survival in evaluating the effects of the
proposed action, reported as the Recovery Prong and the
Survival Prong for each species in Chapter 8 of the
Supplemental Comprehensive Analysis.
"-- NOAA Fisheries' determination relies on measures
included in the Reasonable and Prudent Alternative, which is
the subject of the Section 7 consultation. Actions outside of
this Reasonable and Prudent Alternative, Federal, state, and
tribal measures that are already taking place or are
reasonably certain to occur, are considered as part of the
environmental baseline or, on a qualitative basis, as part of
a cumulative effects analysis."
The Upper Snake draft BiOp is "analytically based on the
same set of facts" as the FCRPS, Lohn said, taking into
account cumulative effects and including the FCRPS' effects in
its environmental baseline.
Lohn said that the BiOps' production represented an unusual
situation. Normally NOAA proceeds from draft to final
documents in consultation with the other federal agencies but
without a public comment period. In this case, states and
tribes and others involved in the lawsuit will be allowed to
comment, though not the public at large.
He said Judge Redden would likely dictate the length of the
comment period, and when a final BiOp must be completed.