[3] American Fisheries Society Review Flunks Latest Hydro Biop
The 2004 hydro BiOp isn't just "legally flawed," it's also scientifically flawed, according to a review of the document released last week by the American Fisheries Society.
The anonymous AFS reviewers delved into issues that U.S. District Court Judge James Redden stayed away from in the ruling he made several weeks ago, when he threw out the BiOp more on procedural grounds, and ruled all the scientific issues moot.
The AFS review says the BiOp doesn't pass scientific muster. "As demonstrated," says the document, "the predicted outcome of the remand for the majority of the ESUs [Evolutionarily Significant Units] does not appear to avoid an appreciable reduction in the likelihood of both survival (i.e., there is no change) and recovery."
In fact, the report says it's not clear whether recovery could even be achieved by removing "most" hydro projects in the Columbia watershed, but it said benefits to Snake River stocks would be "assured" by removal of the four lower Snake dams.
The review said that even using optimistic population trend data, nine of the 13 ESUs are expected to go downhill in the short term. As for the long term, the new BiOp estimates that eight ESUs will have no change or possibly some improvement, which the reviewers said implied an "acknowledged and acceptable risk" to most stocks from the proposed actions, which includes both hydro operations and non-hydro offsets. But that much risk provides "little certainty that these actions will avoid an appreciable reduction in recovery."
The new BiOp puts too much emphasis on predator control (like the pikeminnow bounty program), according to the AFS reviewers, who say its success is "fraught with uncertainty," and should be more "holistic" to focus on non-native predators as well.
The review said the value of fish transportation is not clear, and provides only marginal benefits to some stocks.
Recent improvements in stocks are likely due to better ocean conditions coast-wide, rather than from mitigation within the basin--so larger fish numbers shouldn't be used to justify such mitigation efforts, the report said.
The reviewers said random adverse events like this year's drought imperil recovery efforts--mitigation proposed in the latest BiOp should be "more aggressive and focused" to ensure survival and begin recovery of the listed stocks.
Since the 2004 BiOp put the dams' existence in the environmental baseline, the AFS reviewers said it must be recognized that the environmental degradation from the dams puts more emphasis on mitigation assumptions to ensure that NMFS carries out its mandate to protect and recover the stocks.
However, by putting the dams in the baseline, they say, the agency's latest opinion accepts more degradation to the environment and population declines, and assumes that such losses will be made up in the future by predator control and removable spillway weirs.
On the other hand, the reviewers appreciated the ESU focus in the 2004 BiOp, and the effort to relate each action to specific ESUs, which should allow for a more comprehensive assessment of each ESU than the earlier BiOp provided.
The AFS review was a hurry-up affair requested last October by the tribes, who wanted to know if the findings in the new BiOp "significantly departed" from past assessments. They also wanted to know whether "sufficient technical capacity" had been demonstrated to differentiate between the effects on fish from the dams' existence and from dam operations.
They further wanted to know the limiting factors for fish recovery in the Columbia Basin and whether the dams have a limiting effect.
The tribes asked a couple of real puzzlers in their request--whether the proposed hydro actions adequately spread the risk for "unknown consequences," and if these were enough to prevent further fish declines.
The AFS reported that five reviewers responded in time, and represented expertise in salmonid fisheries, water quality aquatic ecology, hydrology, and hydropower policy. Three of them were PhDs, two had Master degrees, with some having done previous research on salmonids, while others came from outside the Northwest.
The AFS sent a letter to President Clinton in 1999 signed by 200 scientists that supported removing the four dams before the last BiOp came out. - B. R
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