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News from the Front #29:
The Downward Spiral Continues: NMFS Releases Draft Biological Opinion on Columbia Basin Water Projects
On July 27, 2000, the National Marine Fisheries Service issued a draft biological opinion on the operation of the Federal Columbia River Power System, 31 projects operated by the U.S. Bureau of Reclamation, and the juvenile salmon transportation program. The full opinion, including all appendices, takes more than a ream of paper to print.
As a utility lawyer told me last week, "this thing is going to make dam breaching look cheap by comparison". While the Clinton/Gore Administration may be taking a "no breaching until after the election" approach for now, the entire design of this biological opinion is to push dam breaching. We can only hope that this Administration goes down in November, and someone sensible will be appointed to run NMFS. Below are the four major failings of NMFS that someone sensible could fix. (Parenthetical references are to the draft Biological Opinion, which can be downloaded here.)
Problem #1: NMFS is an unguided missile, shooting down economic activity all over the Columbia River Basin without regard to any reasonable interpretation of the Endangered Species Act.
The Endangered Species Act (ESA) directs NMFS to prepare biological opinions to help other federal agencies ensure that their actions do not "jeopardize the continued existence of any endangered species" (16 U.S.C. § 1536(a)(2)). In other words, once a species is listed, agencies should not take actions to exterminate it from the face of the earth. In a breathtaking innovation, NMFS declares that any mortality to listed species must be at "a level equal to and no higher than that which would occur in the absence of the action (i.e., full mitigation)" (1-10). In other words, NMFS has declared that the ESA prevents any agency action that kills any fish whatsoever, unless those fish are somehow replaced. Congress would never have passed a law like that, but with the collapse of judicial review, there may be no law governing NMFS; the law is what NMFS says it is.
Naturally, this jeopardy "standard" only applies in the context of NMFS' efforts to seize control of Western water. Imagine trying to apply the same standard to pulling the fish out of the the water with nets and killing them: you can catch and keep just as many fish as you put back in the water alive. By contrast, NMFS' latest draft All-H paper articulates the standard for fishing: "limit harvest to current levels" and "seek opportunities to reduce harvest impacts on listed fish where necessary and effective" (emphasis added). That standard, if applied to dam operations, would eliminate nearly everything NMFS is proposing.
Notably, the Endangered Species Act does not direct NMFS to "consider the effects of the existing configuration" (1-1) of the dams. The laws require NMFS to assist agencies in making discretionary choices, called "agency action", that affect salmon. Since the agencies don't have discretion to re-configure the dams, NMFS' advice is the product of a political decision to push dam removal, not a product of the duties Congress entrusted to NMFS under the applicable statutes. So we shouldn't thank NMFS for not taking a dam breaching position; dam breaching was never part of what they were supposed to be doing in the first place.
NMFS continues to worm its away around this little legal problem by declaring that
"NMFS finds that currently available information and analysis cannot distinguish between the mortality attributable to the action under consultation and that attributable to existence of the [dams]. Therefore, one method of ensuring that the [jeopardy] standards are met is to require the [dams] to reduce mortality of listed species to no more than the level of mortality that would occur if the hydrosystem were not in place, unless and until a less level is identified through recovery planning." (1-12)
In other words, NMFS claims, falsely, that it can't do what Congress told it to do--estimate the effects of agency action--so it will simply require the dam operators to meet contrived mortality standards (more on this below).
The ESA does require NMFS to prepare recovery plans for listed species, a task NMFS deep-sixed long ago when the blue-ribbon panel of experts NMFS was required by the statute to appoint didn't come up with the politically-correct answers. Having failed miserably to do the job required by the statute, NMFS claims that it will simply try and recover the species using the biological opinion, and declares that agency action may also jeopardize salmon if the agencies don't act in accordance with its draft All-H paper (see 1-9), the unlawful substitute for the recovery plan required by statute.
Another example of NMFS' desire to undertake tasks not conferred by Congress is found its its declaration that each of the twelve "evolutionarily-significant units" (ESUs) of salmon covered by the opinion "may contain multiple independent populations" (1-7), and that "all currently defined populations should be maintained to ensure adequate genetic and life history diversity, as well as the spatial distribution of populations within each ESU" (1-8; emphasis added). In simple terms, NMFS is saying that the "Noah's Ark" mission of the ESA is essentially irrelevant; instead, NMFS asserts authority to protect all salmon everywhere, without regard to the risk that any species, subspecies, or "ESU" of salmon will go extinct. Some efforts to protect salmon everywhere may well make sense, but to apply the draconian provisions of the ESA to provide absolute protection for each and every stream in the Pacific Northwest distorts the ESA beyond recognition.
Given these outlandish interpretations of the ESA, it is easy for NMFS to conclude, as it does, that the "proposed operation and configuration of" Columbia Basin dams and water projects "jeopardize the continued existence of" every stock of salmon it analyzes that swims through them (8-2, 8-4, 8-6, 8-8, 8-10, 8-12, 8-14, 8-18, 8-19) If the judiciary had not abandoned any responsibility to make federal agencies conform their conduct to law--instead of making up the law to conform to their conduct--any judge could tell that NMFS failed even to provide an opinion on agency action. Instead, NMFS has provided an opinion about the state of the Columbia River Basin, and finds it wanting.
Under the ESA, these "jeopardy findings" provide NMFS with an opportunity to set aside the plans of the dam operators and offer what it calls a "reasonable and prudent alternative" to those plans. The statute requires that a "reasonable and prudent alternative" (RPA) be one that "can be taken by the federal agency . . . in implementing the agency action" (16 U.S.C. § 1536(b)(3)(A)). NMFS admits that dam breach is not an action the agencies can take:
"NMFS recognizes that breach is a major action requiring NEPA compliance, congressional authorization, and appropriations before it can be implemented. This RPA, therefore, calls for the [dam operators] to conduct or continue analyses preliminary to seeking authorization from Congress, such as impact and mitigation studies . . . [to] reduce the time needed for possible implementation . . ." (9-5)
There is a very fundamental logical problem, sure to be exploited by the environmentalists in forthcoming litigation, with the idea that agency action determined to jeopardize the continued existence of listed species avoids jeopardy merely because the agencies produce reams of additional paper. Most of the RPA consists of a "wish list" for NMFS that has no immediate impact on fish, or projects yet to be determined that might help fish (see 9-26). The ultimate intent is to grease the skids for dam removal; NMFS even demands "an economic and cultural mitigation plan . . . including roads, rail, utilities, pumps, diversions, embankments, and bridges . . . to mitigate disproportionate impacts to communities, industries and Indian Tribes" (9-109). Congress told the federal agencies to put human needs first but mitigate impacts on fish; the agencies ignore Congress, put fish needs first, and propose to tell Congress it should mitigate human impacts.
Looking at the complex decision flowcharts contained in the biological opinion (9-20 to 9-21), I was struck with nostalgia for the simpler, cruder approach NMFS took in an earlier biological opinion: it simply demanded (and got) a multi-million slush fund as the price for a no-jeopardy opinion. Now NMFS demands control of the other Federal agencies and their entire research programs. Centralization of research and reporting is particularly depressing, because it means that truths about salmon recovery remain submerged beneath the politically-correct positions dictated by the environmentalist cabals in control of NMFS.
Under the RPA, NMFS also proposes to make the dam operators guarantee future salmon population increases: "If lambda values [productivity, roughly speaking] are still below 0.95 in 2008 [as most are based upon the 1980-1994 analysis], ESUs would be considered at risk of exinction and the RPA will be considered to have failed." (9-8; see also 9-12). In that case, "NMFS shall propose a specific plan for changes to avoid jeopardy, including breaching one or more dams as appropriate." (9-22) NMFS declares that the plan may involve "the breach of dams other than the Lower Snake projects". (9-24)
This means that unless wild adult returns to the spawning ground continue to increase, NMFS will declare that dams must go. This is utterly irrational, since adult returns are largely driven by factors that have nothing to do with dams.
Problem #2: NMFS has a obsessive fixation on "mainstem flows" as the One True Path to salmon recovery
Somewhere, somehow, a Bureau of Reclamation (BOR) project's operations could probably be modified to improve salmon survival, but the amount of water such projects contribute to flows in the mighty Columbia matters not one whit to salmon. Yet the biological opinion "focuses on the effects of BOR's projects on streamflow in the mainstem Snake and Columbia Rivers" (6-27). Any effects on salmon from changes in mainstem river flow are vanishingly small, but NMFS continues to rely substantially upon the same discredited studies and bogus reasoning to find flow benefits that it has used throughout the 1990s, as amply documented elsewhere (see, e.g., Chapter 7 of The Great Salmon Hoax). NMFS does admit that it "has not detected a relationship between flow and survival for yearling chinook salmon in the Lower Granite to McNary reach" (6-51), but responds to the lack of evidence by relying upon speculation that flow provides benefits somewhere we haven't measured yet.
The wide-ranging speculation verges on the ridiculous. NMFS even argues that "salmon appear to have a preference for low surface-salinity waters, as the abundance and distribution of juvenile salmon are higher in the plume as compared to adjacent non-plume waters. These findings support the notion that the plume is important habitat for juvenile salmonids." (6-10). Of course, salmon leaving the Columbia spread out, so naturally there will be fewer of them found farther from the mouth of the river. (NMFS has such a bad case of plume envy that it demands big new research program to prove the benefits of a bigger plume (9-133 to 9-136), and even declares that dam operations "may adversely affect designated "Essential Fish Habitat" for ocean groundfish by affecting the plume (12-12)).
NMFS ultimately retreats to the position that recent high salmon survivals "suggest that flow management, in conjunction with all other fish protection measures, has had a beneficial effect on salmon survival" (6-36). In fact, most of the improvement results from (1) errors in older estimates that understated survival and (2) putting screens on turbines. Generally speaking, NMFS continues to flail about requiring fish programs first and figuring out what works later--and ignoring the results when politically-correct fish programs (like flow augmentation) don't work.
Interestingly, NMFS recognizes that higher flows it believes benefit juveniles "may hinder" adults (6-24), a proposition about which there can be no doubt. Yet NMFS makes no effort to figure out whether claimed positive effects to juveniles from flow augmentation outweigh adverse effects on adults. Nor does NMFS consider adverse effects from particular types of flow augmentation.
For example, on March 15, 2000, three University of Washington scientists released "Effects of Flow Augmentation on Snake River Fall Chinook", which was the most thorough analysis of that subject ever conducted. Their conclusion? Contrary to NMFS' speculative benefits, "flow augmentation from Brownlee Reservoir is detrimental to fall chinook. The highest Snake River fall chinook survivals were predicted with no Brownlee Reservoir flow augmentation." In short, the only reason to take water away from Idaho farmers is to enjoin the heady experience of exercising power. It probably kills fish. NMFS' continuing and willful blindness to adverse effects of flow augmentation seems to confirm that it's not about the fish--it's about controlling the water.
The "control" emphasis is apparent with NMFS' obsession with injury to compliance with NMFS' "flow targets", rather than injury to fish. In fact, as data presented in the biological opinion (6-37) demonstrate, the targets are wildly unachievable, particularly in the summer months. Setting unachievable objectives, and declaring them to be mandated by law, is a favorite tactic of the new class of environmentalist overlords, particularly since the alleged failure to comply with "the law" has strong overtones of immorality, and puts the regulators on a higher moral plane.
Consistent with these themes, the very first "improvement" for salmon that NMFS articulates in its RPA is to dedicate more water to fish, over and above the enormous amounts required in prior biological opinions (9-36). NMFS will even require drafting reservoirs below project operating limits, requiring, for example, that the U.S. Army Corps of Engineers to draft Dworshak Reservoir 20 feet lower (9-54).
To avoid using the released water to serve human needs, NMFS will require even greater quantities of water to be spilled, again producing no tangible benefit to salmon. (9-65 to 9-69) In prior biological opinions, NMFS at least purported to offer biologically-based targets for spill, declaring, for example, that sufficient spill should be provided so that 80% of juvenile salmon avoid the turbines. In fact, far higher percentages avoided the turbines at most projects, so now NMFS simply dictates the hours and amounts of spill without reference to any biological goals.
To its credit, NMFS has finally directed that spill levels at The Dalles be trimmed after three years of studies showing lower salmon survival from higher spill. (9-73) But since no one has conducted similar studies at other projects, spills will be increased at many of these projects. Any rational approach to planning dam operations would start with such studies, but spill is politically-correct because it does tend to increase survival (in moderation) and costs dam operators lots of money; research that might reduce spill is somehow the research that just doesn't get funded. Rational planning would also require NMFS to balance juvenile gains from spill with adult losses, but NMFS does no more than speculate, without any quantitative evidence, that effects on adults are small (e.g., 9-74)
NMFS is so eager to avoid deriving any economic benefit from the dams that it even orders BPA to build new transmission lines so that Northwesterners can buy their power from California or thermal plants instead, and more water can be spilled. (9-74) NMFS even suggests that if it wants more spill "BPA will limit future reservations for transmission capacity" (9-75), expanding its no-growth policies from water-using activities to power-using activities.
The biological opinion treats BPA as a cash cow that, in addition to achieving no net impact from dams, must fund every fashionable eco-notion, from paying for "long-term protection for 100 miles of riparian buffers per year" (9-112) to buying 10,000 acres of tidal wetlands in the Lower Columbia River Estuary (9-114 (the "initial goal"--BPA's duties are unbounded)). All these actions promise to be enormously costly, but no cost estimates are included in the biological opinion. BPA finished its rate case in June, and just announced last week that it must raise rates again. Perhaps the next biological opinion will require that BPA pay people in the Northwest not to have children, which would probably have more benefits for salmon than most of the programs NMFS demands.
Northwesterners are already losing their jobs from this nonsense, as energy-dependent businesses close their doors, but it will probably take big blackouts before our public servants wake up and begin to figure out that refusing to let BPA sell power, and requiring it to pay for everything in sight is not a workable long-term strategy. In the meantime, the clueless politicians are still in the "blame the greedy participants in the free market" phase.
The biological opinion also leaves no doubt that farmers are a special target of NMFS: "Flow depletions caused by BOR-based irrigation activities are a major impediment to meeting NMFS' flow objectives." (6-28) The BOR can no longer enter into "any agreement to commit currently uncontracted water or storage space in any of its reservoirs covered by this Biological Opinion to any other use than salmon flow augmentation", or enter "into any new contract or contract amendment to increase the authorized acreage served by any irrigation district receiving BOR-supplied water" unless there is "zero net impact from any such BOR commitment on the ability to meet the seasonal flow objectives established in this biological opinion". (9-50 to 9-51) BOR will also be required to pursue unspecified water conservation activities, report to NMFS on actions to shut down water spreading, and engage in further, project-specific consultations, including studies to allow the BOR to drop Banks Lake five feet lower in August, releasing 137,000 acre feet more water downstream (9-54).
And, again in the service of gaining tiny increases in Columbia and Snake River flow, the U.S. Army Corps of Engineers will be required to "identify opportunities to bring more connectivity to some areas of active flood plain (e.g. undeveloped land and farmland) and more effective flood protection to others (e.g. communities)" (9-56). In plain English, NMFS wants to increase the chance of putting farmland under water, but avoid flooding the places where most voters live.
Problem #3: NMFS continues to push junk science.
As noted above, expanding its tradition of establishing impossible targets, NMFS has declared that it will require the dam operators to achieve target levels of mortality it claims are equivalent to having no dams at all. Thus NMFS declares, based upon an Appendix it has yet to disclose, that the dam operators must achieve 82% survival for spring/summer chinook (1-14). NMFS later discloses that it is assuming natural river survival of roughly 0.9997 per kilometer. (9-198) NMFS takes a tiny subset of the available data--a favorite trick--and then apparently substracts out exaggerated dam and reservoir mortality to leave exaggerated natural survival. (See id.) NMFS also continues its long-standing trick of pretending that each and every fish that dies in the river is "incidental take resulting from [dam operations]" (10-3).
Dr. William McNeil has analyzed dozens of datasets measuring survival per mile for spring/summer chinook in the Snake River above the dams--precisely the comparison NMFS admits is appropriate (see id.). Survival per kilometer above the dams is nowhere near 0.9997, and, indeed, Dr. McNeil was unable to determine any statistically significant effect of the dams on survival per kilometer at all. While there are reasons that the data cited by Dr. McNeil may overstate mortality, by all appearances NMFS is still nowhere near a reasonable estimate of natural mortality.
To its credit, NMFS acknowledges that "with transportation, combined transport and inriver survival to below Bonneville Dam is estimated at 78%" (6-49 (yearling chinook)). Thus the agencies have already produced salmon survival almost the same as NMFS' overstated "natural survival" targets, and by NMFS' own reasoning, the dams should not jeopardize the continued existence of salmon. Indeed, using more reasonable figures, with smolt transportation the dams can probably enhance salmon populations a little..
NMFS has two responses to this little problem. First, it adopts a new and astounding innovation in junk science, invented by state and tribal scientists. NMFS speculates that fish die of unknown and unknowable adverse effects from dams that only materialize weeks or even months after the fish have left the river (e.g., 6-54, 6-73). We have measured survival as far as saltwater, where the radio transmitters fail and it gets too hard to track the fish, and find no such effects, which is why I ridicule this hypothesis as the "recovered memory/I was abused as a smolt" theory. But for purposes of fashioning computations rigged to show jeopardy from the dams, this creates a whole new class of mortality to be blamed on dams, called "indirect" injury or "delayed mortality".
Second, NMFS baldly ignores transportation benefits in discussing the "full mitigation component of the jeopardy standard" (6-77 (Snake River spring/summer chinook; same approach for other stocks)). In other words, only "natural", in-river survival counts, so that according the NMFS, what the law really requires is that dams eliminate all adverse effects, and then substantially improve net salmon survival through transportation. (It is true that after finding "jeopardy", NMFS establishes "performance standards" that do give credit for transportation--but only after adding in the bogus "delayed mortality" (9-10)).
As usual, computer modeling is the prime breeding ground for junk science, and is the source of the bogus estimates of "indirect" mortality. After the Federal government spent millions of dollars hiring University of Washington scientist James Anderson to build a competent model of juvenile survival, NMFS cast it on the ash heap in favor of its "SIMPAS" model (2-3), which makes simplifying and bogus assumptions to produce the politically correct results.
For example, the SIMPAS model assumes that turbine mortality at most dams is 10% per dam, roughly twice what reasonable professional judgment should produce (B-10; B-11; but cf. 6-14). NMFS reached these conclusions through the common trick of citing an incomplete review of the turbine mortality studies, rather than citing the studies themselves (6-11), and then going on to misrepresent the conclusions of the review.
Specifically, NMFS cites a number of very old studies, and downplays the newer ones on the ground that "lower [older] survival estimates probably included some level of mortality associated on predation with disoriented smolts after turbine passage. That is, turbine mortality not only causes direct mortality but may cause indirect mortality by increasing susceptibility to predation." (6-11) The review, however, cites the one study that tested this hypothesis, and found the same lower survivals when we release smolts in the tailrace as control groups, which are not "disoriented" from turbine passage at all. In other words, there are simply a lot of predators below the dams, just as there used to be lots of predators below rapids and waterfalls. Blaming turbines for this is bias, not science.
Again, any competent approach to planning dam operations would begin with careful measurement of turbine mortality (as well as bypass and spillway mortality) at each project, but after decades of salmon crises we have yet, for example, even to measure turbine survival at The Dalles (9-73).
All that being said, there is considerable progress in this biological opinion with respect to the parameters put into SIMPAS (though one can't turn a sow's ear into a silk purse). In older model runs, NMFS ignored newer experimental evidence entirely. Now NMFS has actually made slight adjustments at the dams where a new measurement was made, but refuses to extrapolate the results to other dams or even other salmon "species" not used in the experiment. This is an example of the incremental process, slowly playing out over dozens of dam passage parameters and dozens of years, that has gradually decreased the mortality NMFS blames on dams--but NMFS has a long way to go before it gets close to the truth. The incremental process also allows NMFS to claim survival improvements result from its programs, when in reality most of what has changed is the assumptions in computer models.
Another area of junk science involves the "base period" for assessing the status of salmon populations. NMFS uses a base period of 1980-1994 (4-2), a period during which ocean conditions probably deteriorated to the worst in 500 years, and a period which ignores the recent upturns. Also constituting junk science are confident assertions about minimal harvest impacts (5-8), in the absence of any reliable data. And NMFS continues to blame dams for substantial reductions in adult survival (6-2) based on the disappearance of radio-tagged fish (see 6-20, 6-23), which probably were caught illegally. NMFS does this even though it recognizes that "the net effect of delay at dams combined with faster passage through reservoirs is a median travel time through the Lower Snake River the same or faster with dams in place than with no dams" (6-21), a fact that suggests, along with other evidence, that dams provide easier adult migration with higher survival.
A favorite NMFS tactic is to misrepresent the science by omission. One of the first sections of the new BiOp I read was the references, finding that, as usual, NMFS continues to ignore scientists who disagree with its conclusions. The work of Dr. McNeil, discussed above, is nowhere to be found, along with much other work refuting NMFS' conclusions. Scientists who explain positive effects of the dams, such as better rearing areas and more food for fall chinook, are simply ignored.
Ultimately, the opinion is riddled with so many misleading citations to scientific literature, and outright misrepresentations that I cannot include them all in this already-overlong piece.
Problem #4: NMFS' position on hatchery fish combines unfounded hostility to all hatchery fish with inconsistent promotion of politically-correct hatchery fish.
NMFS observes, correctly, that "the role of hatcheries in the future of Pacific Northwest salmon is presently unclear; it will depend upon the values humans place on fish production and biological diversity" (5-7). But NMFS' "save every single stream of wild fish" policy implements its own human values under the guise of legal requirements: the politically-correct concept of "diversity" trumps the general public desire for more fish.
NMFS provides the usual extensive general litany of theoretical adverse effects on wild stocks (§ 5.3.3), but waffles as to whether hatchery fish have had significant impact on particular wild stocks. NMFS seems to take the position that hatcheries have little or no adverse effects on wild chinook stocks (4-2, -5, -6), except perhaps with respect to Oregon's Willamette River chinook (4-9) and Lower Columbia chinook (4-11). NMFS finds more adverse influence with respect to steelhead stocks (4-12, -14, -16, -18, -20). But, as usual, NMFS is unable to identify quantitative adverse impacts; the only numbers are percentages of wild fish vs. hatchery fish. As NMFS admits, evidence that hatchery fish have low reproductive success when producing the wild is "largely lacking" (9-4). That does not stop NMFS from presented detailed quantitative computer model results based on quantitative assumptions that "estimated productivity of wild fish increases with decreases in the assumed effectiveness of hatchery spawning in the wild" (9-189). Running unsupported assumptions through a computer model proves nothing; garbage in, garbage out.
The opinion adopts whatever political view is fashionable with respect to any particular group of fish. Thus NMFS requires the expenditures of hundreds of thousands of dollars to protect a tiny colony of hatchery strays below Bonneville Dam (6-38; 9-39), an exercise that appears to have been advanced by state biologists for the express purpose of punishing the Bonneville Power Administration. This exercise stands in stark contrast to recent NMFS directives seeking extermination of other hatchery stocks that stray and spawn in the wild.
More generally, decades of Congressional action established hatcheries as a prime means of mitigating dam impacts, particularly where dams blocked salmon passage entirely (unlike the eight mainstem dams). But the biological opinion gives the dam operators no credit whatsoever for this mitigation. Its "analysis does not consider the effects of ongoing habitat and hatchery recovery efforts" (6-104). The largest portion of the salmon tax imposed on citizens through their electric bills goes to fund an enormous hatchery program ostensibly required to mitigate effects on dams, yet according to NMFS, the dam operators have to eliminate all adverse effects without regard to hatcheries. If the dam operators had any courage, they'd tell NMFS if they don't get credit for hatcheries, they'll simply shut them all down; perhaps the resulting public outcry would get Congress to set policy on hatcheries, instead of ducking responsibility.
Moreover, NMFS' so-called "Reasonable and Prudent Alternative" calls for millions of dollars of increases in hatchery funding (9-120 to 9-25), including unspecified "reform" of existing hatcheries, building new ones, and huge new research, evaluation and reporting obligations for hatcheries. Yet NMFS acknowledges that "the effects of hatchery-origin fish on the survival and productivity of naturally produced populations are critical research areas" (9-120). This is Federal government business as usual: huge new programs with conflicting goals and objectives. In essence, NMFS orders the dam operators to mitigate their dam operations and their Congressionally-mandated mitigation strategy, without any coherent evidence that there is anything to mitigate at all.
Once again, NMFS demonstrates that it's not about the fish. It's about an agency that is out of control, and the spineless leaders who keep it that way, while bringing home the bacon to keep the voters fat, dumb and happy--at least for a while. Until the lights go out.
© James Buchal, August 7, 2000
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