An Open Letter to Economic Interests involved in the Framework Process
March 18, 1999
Having now reviewed the March 15th Framework Alternatives, and listened to the March 15th Framework Committee meetings, I reiterate my advice that nothing good will come of this process, and that the continued involvement of economic stakeholders is counterproductive, for reasons further explained below. I reiterate my advice that we devise an "exit strategy".
The Alternatives Are Illegitimate
Recall that the Framework initially promised economic interests a full evaluation of "their" alternative(s) and an effort to require, for the first time, some sort of internal consistency to goals and strategies. We are now faced with a suite of alternatives generated by Staff with very little left of a vision to which economic interests ought to subscribe.
This is a classic tactic of our opponents: develop a "range of alternatives" that is heavily weighted on the dambusting side and includes no real "bookend" on other side. As far as I know, no economically-reasonable alternative has emerged in any of the many salmon processes since the SOR's "load-following" alternative.
A central thesis of economic interests is that mainstem mitigation measures ought to be assessed for cost-effectiveness, and that salmon decisions should be based on real data, not unsupported hypotheses. Focusing on Alternatives 4-7, which have the apparent virtue of avoiding immediate dam breaching, we see that neither of these concepts has survived Staff review:
All of the alternatives call for very extensive habitat efforts, which history suggests are remarkably expensive and lacking in effectiveness.
All would reduce or eliminate smolt transportation in the service of developing more "natural" bypass systems.
All declare that the hydrosystem should continue to "provide spill . . . up to the point that dissolved gas levels exceed 120%".
All declare that hatcheries should "mimic to the extent possible the population's structure, growth and behavior of natural populations"rejecting even the concept of breeding better salmon.
None call for the outright elimination of spring flow augmentation; and although some would reduce flow augmentation, none proposes to return the savings to the ratepayers.
None call for the elimination of mixed-stock fisheries, though some would make efforts to focus on a few mixed-stock fisheries.
We all ought to be offended by this development, which mocks the participation of economic interests. For Staff to continue to insist on achieving a specific level of water pollution without regard to economic and biological costs and benefits betrays a hopeless bias and allegiance to salmon politics, not salmon science. Staff now takes the position that there will be no "tweaking" of alternatives until another "phase" of the project.
The Proposed Analytical Process Is Illegitimate
The Region is beset by a locust-like plague of "conservation biologists" bent on binding us all to a futile attempt to restore 1850s conditions in the Columbia River Basin. Underlying their approach is another time-honored environmentalist strategy: set environmental standards that are impossible to meet, so that the pressure to limit human action never ceases. The further development of the Framework process promises to reach new frontiers in this regard.
Charles Darwin observed that many biologists fall into "the deeply-seated error of considering the physical conditions of a country as the most important" (all "conservation biologists" do). He declares that "it cannot be disputed that the nature of the other species with which each [species] has to compete, is at least as important, and generally a far more important element of success".
On March 15th, Lars Mobrand confirmed that the Framework's "conservation biologists" will attempt to build a habitat-based model for assessing the effectiveness of Framework Alternatives, expressly based on comparison to conditions imagined to prevail in the 1850s. As I understand it, someone will attempt to assemble 8,000 data sets associated with "sixth order hydrologic units", collecting the shopworn attributes of "riparian condition", "blockages" and "spawning gravels". From these "obvious" attributes, opines Mobrand, we will have a "good picture of what goes on in watershed". Quite apart from the fact that any data of this detail will necessarily consist of interpolations and reconstructions of the sort that have undermined the credibility of the PATH process, the whole approach is bogus.
There is no indication that the "conservation biologists" will attempt to assemble 8,000 datasets concerning local populations of avian and aquatic predators, species competing on a less direct level (e.g., hatchery fish and nonanadromous introductions), and the degree of localized competition from man, e.g., the extent of local fishing pressure. The data does not exist.
What we are seeing here is the same superficial and slipshod approach to environmental protection that prevails with the assessment of water quality, where thousands of streams are listed as "out of compliance" with little or no data. Quasi-scientific efforts to predict the future trajectories of species of interest based on habitat conditions do nothing but feed the propaganda mills of our opponents.
We can also expect that the PATH approachearlier declared by Mr. Palensky to be the "primary analytical tool" for the Frameworkwill be used to assess the effectiveness of mainstem actions with which we are most concerned. Having now finally listened to the entire tape of the February 25th meeting, I am even more convinced of my earlier view that this process is a fraud whose results are the product of imaginary "delayed mortality" and dozens of contra-factual assumptions hardwired into the structure of the analysis. It may well be "ubiquitous" in conservation biology to rely upon 100-year forward projections based on simplistic and mis-specified models, but this merely illustrates the intellectual bankruptcy of the field.
Three virtues have been offered for continued participation in the Framework process. First, it has been thought that the process will somehow resolve internal contradictions in the goals of our opponents (e.g., "back to nature" except commercial harvest). I see no evidence that this will ever happen, because the harvest interests remain in control of the process.
Second, it has been thought that participation in this Forum will provide a means to influence Federal decisionmaking. We now know that the Federal agencies have formed a "caucus" with several committees that frankly look like where most of the action is going to really behence the strident demands for tribal participation at the meeting today. Wouldn't it make more sense to demand direct participation in these committees? Can't economic interests also make hay by raising questions as to why they must be excluded from these committees?
Finally, we have been told that the Framework process is the only forum in which we can participate meaningfully. While it is true that we can all go to these meetings (unlike many other secret processes), our participation has to date accomplished nothing, because those running the process are privileged, and apparently disposed, to ignore everything we say.
This is not meaningful participation, and it is not without costs: we can all be very sure that anything that emerges from the process will be deemed to have the blessing of the economic interests participating. And we can also be sure that pulling out after the analysis is in will be regarded as a reaction to the results, rather than a principled objection to the process. Mr. Grace's "wait and see" approach has potentially large costs.
Lyndon Johnson once explained why he appointed an opponent to his Administration: "I'd rather have him on the inside pissing out than the outside pissing in". I continue to believe that we can accomplish more on the outside pissing in, by making a very active effort to discredit this discreditable process with the delegation and the public.