[1] Feds Downplay Fundamental Disagreements In Remand Report
In their latest status update, federal agencies say they are on track to develop a BiOp for the Columbia hydro system that uses the "best available science" to fill any gaps between current fish survival and recovery goals with improvements in the other H's-habitat, hatcheries, and harvest.
But they may have even more significant gaps to overcome, namely, the lack of scientific expertise from the bench, and the absence of any real collaborative spirit with state and tribal fish agencies.
"There is no way that states and tribes are going to agree on the science," said one participant in the remand process, who did not want to be named.
In their April 3 update, the feds reminded the judge that if disagreements over science can't be resolved, they get to make the final call.
Twelve technical groups are churning through the analyses, with meetings "on nearly a daily basis." The meetings are privy only to sovereign parties, with other parties to the case allowed in on "observer" status only. However, that doesn't mean the collaboration is really working. According to several other sources involved in the process, another legal quagmire appears in the not-too-distant future.
The April 3 update said that if tough issues aren't resolved at the technical level, they will be elevated to a policy group, per the court's directive for clarification, where agreement is reached or differences over scientific and technical information "narrowed."
Federal District Court judge James Redden may be just as hard to convince that the feds are using the best science as states and tribes, even though he has a science advisor in the case.
The judge certainly wasn't wowed by the federal proposal that agencies floated last winter to change this spring's hydro operations. They wanted to spill a lot of water at lower Snake dams through April 20, then cut it back and maximize the fish transportation strategy.
The Corps of Engineers had based the proposal on recent NMFS research that showed barged fish did better overall (returning as adults) than inriver migrants after April 20. NMFS said it would add thousands of fish to returning numbers of chinook and steelhead above the base BiOp operation, boosting wild spring chinook runs by 15 percent, hatchery chinook by 10 percent, and wild steelhead by 22 percent.
But Redden sided with the plaintiffs' experts, who said the study was "flawed" because it didn't compare survival differences between barged fish and "undetected" fish that passed lower Snake dams via spillway or turbines.
The feds examined the differences in survival between two groups of fish that had been bypassed at Lower Granite Dam because it was the only way for them to know how many were actually in the inriver portion. If they had used "undetected" fish in their analysis, the number would have been an estimate based on assumptions about spill volumes and fish passage guidance at the dam.
Plaintiffs also argued that the smolt-to-adult returns were higher for inriver wild migrants in three of the four years analyzed by NMFS, citing results of a workshop sponsored by the Fish Passage Center in 2004.
But the feds have argued that the annual average SARs developed by the Fish Passage Center can't capture the within year differences in survival.
The issue was brought up at the 2004 workshop, but some participants argued that SARS would be less reliable during intervals when few fish were tagged. According to workshop results posted on the FPC Web site, state and tribal SARs were figured differently, and came out about 30 percent lower than the feds' analyses.
The ISAB has recently come down on the side of the feds. In a March 18 review of the latest FPC survival study, they took issue with the FPC's use of annual SARs, when the smolt-to-adult returns vary as much within years as between them.
The argument over inriver passage versus barging is likely to resurface in Redden's court, because the status update says the Corps' barging proposal will be one of several potential actions that will soon be analyzed, along with operations in the ancient 2000 BiOp and 2004 BiOps, both thrown out by Judge Redden.
Several other scenarios will be considered, including one that models the Montana proposal (lower its reservoirs at a steady rate) coupled with the 2006 court-ordered spill operations. The technical group will also look at how effective it would be to operate federal storage reservoirs at upper rule curves, starting in January.
A third analysis will look at effects of prioritizing storage water for spring migrants over flows for incubating chum below Bonneville and Hanford Reach chinook in the driest 20 percent of all water-years.
Other actions may be reviewed along with the Corps' barging alternative proposed last year. These include a review of the 2006 court-ordered spill levels, and effects on fish if spill is curtailed when 95 percent of the fall chinook run has passed the hydro system, as well as effects from passage improvements and predation by birds and other fish.
The operational analyses should be completed over the next few months. The remodeled salmon passage model is almost ready to roll, according to NMFS scientist Rich Zabel, and it has received a preliminary thumbs-up from the ISAB, in spite of significant griping from states and tribes, who say the COMPASS model is too complex.
COMPASS is a combination of the SIMPAS salmon passage model used by NMFS in earlier BiOps, with the much more complex UW/BPA CRiSP model developed over the years by Seattle-based Columbia Basin Research.
The ISAB said SIMPAS was too simple, and CRISP was too complex, but the COMPASS provides "a reasonable level of complexity, with sufficient detail to capture what is happening, without being overly demanding of knowledge that does not exist."
COMPASS has developed into a full-blown life-cycle model. It will include a factor for delayed mortality and survival beyond the hydro system to estimate adult returns from different operational scenarios.
The results will be used to inform the "gap analysis," which will develop potential actions in other H's (harvest, habitat, and hatcheries) to fill in gaps between the current status of listed populations and their desired status. These actions, or recovery goals, include those by other federal agencies not involved with the hydro system that NMFS has concluded consultation with. According to the update, these actions will be included in the environmental baseline, while non-federal actions reasonably certain to occur will be included in the "cumulative effects" category.
It was reported that any potential changes in the harvest and hatchery areas are not expected to have much effect on closing any gaps.
But the heavy lifting has just begun. According to the update, serious disagreements remain over the relative magnitude of human-induced mortality to the listed stocks, and the amount of delayed mortality to assign to inriver migrants, direct harvest, tributary habitat effects, and hatcheries.
The update also brought the judge up to speed on the latest news regarding the fate of the Fish Passage Center. In a declaration by BPA vice president Greg Delwiche, the power agency spokesman said the FPC contract had been extended a month, as litigation begins both in the 9th U.S. Circuit of Appeals and U.S. District Court by groups opposed to the FPC defunding, and by some FPC staffers themselves.
Delwiche said a recent memo written by FPC director Michele DeHart made claims that "were largely mistaken." DeHart had claimed that some work elements in the old FPC contract had been eliminated in the new contracts awarded by BPA to other entities that are continuing the data warehousing and analysis functions through 2006.
Plaintiffs' attorney Todd True responded April 11, saying the feds' second update "appears to imply greater accomplishment than actually has been achieved." True said few issues have been resolved, and that it was too soon to tell whether the collaboration process will produce a legal and scientifically sound BiOp.
True also tacked on a request to change spill operations at John Day Dam endorsed by the salmon managers April 4 that had been discussed at the technical management level with other entities without reaching any decision. Dam operators had to shut down several turbines at John Day after a transformer failure and the fish managers want the spill changed from the current zero daytime/ 60-percent nighttime scenario endorsed by Judge Redden to 30-percent spill for 24 hours a day, arguing that it will improve fish survival because they anticipated a large eddy to form that would hinder juvenile passage from the dam's tailrace. It was reported that BPA flew salmon managers over the site, and no eddy was observed. -Bill Rudolph
[2] Feds Come Out Swinging Against BiOp Judge In Appeal Brief
The federal government seems to have come down with a severe passive-aggressive disorder during the latest remand. In an April 3 status update on the new BiOp, they told U.S. District Court judge James Redden that the process is proceeding apace in collaborative fashion, though some fundamental disagreements remain. They pointed out that 12 different technical groups are grappling with the "best, available science" in the new remand, and that the groups are composed of federal, state and some tribal scientists, along with "observers" from environmental and BPA customer groups.
But a few days later, in a brief filed in the 9th U.S. Circuit Court of Appeals that deals with their appeal of the 2004 BiOp, the Justice Department said Judge Redden didn't have the right to dictate the terms of the remand, including the call for collaborating with other sovereign entities.
Predictably, the feds' took issue with Redden's ruling that the government's 2004 jeopardy analysis was flawed because the analysis separated the existence of dams from the operation of dams, and compared fish survival estimated from proposed operations to that of a hypothetical "reference" operation that was maxed-out for fish survival.
The federal analysis had found dam operations did not jeopardize survival of the ESA-listed salmon. Furthermore, Judge Redden had said the government must count all the other bad things that happen to the fish cumulatively when weighing fish losses from dam operations.
The feds say the 2004 BiOp that Redden threw out was a product of their "best, available science," and that the new methodology they had developed was created to satisfy the court's concerns over the 2000 BiOp, which Redden threw out in 2003.
They said it was "inherently impossible for the agency to make informed projections 100 years into the future and across the species' range, as it had attempted to do in the 2000 BiOp, while at the same time limiting consideration only to the proposed action and to the environmental baseline and cumulative effects within the action area."
The feds said the judge's ruling on the 2000 BiOp had rejected the long-term, range-wide approach and related "scientific tools" used in that document.
But in the new remand, the government has gone back to the standard convention in conservation biology to assess extinction risks of the listed stocks over the next 100 year, hoping to get that risk below 5 percent.
Plaintiffs in the BiOp litigation will respond to the government's arguments by the end of the month, but won the first round when the Niners OK'd a motion by Earthjustice attorneys to use the same three-judge panel that granted more spill for last summer's operations after a hearing in Seattle.
That panel was mentioned in an amicus brief filed by a Columbia-Snake irrigators' group that supported the government's appeal. The brief noted that the panel amended its earlier opinion after a government attorney said the dams killed up to 86 percent of the fall chinook in the Columbia and Snake rivers.
The panel admitted that a "non-trivial" level of mortality would occur in a free-flowing river, but irrigators' attorney James Buchal said the court had "still not gotten it right." He argued that most of the fish mortality in the rivers is natural, and that any mortality from dams is not the product of operational choices, but from other factors, like the decisions to build them, long before the ESA was written.
The state of Idaho also supported the NOAA Fisheries appeal, arguing that the feds' jeopardy analysis was proper and the agency was due deference in its judgments. Idaho also said the district court was wrong when it supported the plaintiffs' argument that all the adverse actions to salmon had to be added to the proposed effects from dam operations before the analysis could be completed --B. R.
[3] Spring Chinook Run Even Later Than Last Year
Harvest managers shut down the lower Columbia River to sportfishing last week after the upriver spring run stayed at a slow trickle over Bonneville Dam.
The managers said sport catches weren't that bad, showing some evidence of a fair number of chinook in the river. But they are concerned that the run may be smaller than anticipated, like last year's spring returns.
In 2005, the chinook numbers were almost this bad. By April 16 last year, only 851 chinook had been counted at the dam. This year it's a measly 205 fish. The 10-year-average count by this date, which includes some of the largest years on record (2001, 2002) is over 40,000 fish.
The paltry numbers last year added up to an upriver spring/summer run of about 106,000 fish, about half of the preseason estimate. Managers say they expect only 88,000 upriver chinook this spring.
Over on the Willamette, it's the same story. Only 79 fish had been counted at the falls by April 12, with a run size projected around 46,500 fish. Last year, 476 had been counted at Willamette Falls by this date, but in 2004, more than 4,500 chinook had been tallied by this time. Eventually, 61,000 chinook were counted last year, significantly lower than the preseason estimate of 117,000 fish.
Scientists say near-ocean conditions in the Pacific off the West Coast are still very wintry, with much cooler water than observed over the past several years. This could mean good news for juvenile salmon that are beginning their migration to the sea.
Warm water and lack of upwelling in recent years has reduced productivity of salmon runs. In fact, the warm currents brought with them huge schools of hake from southern California waters, which scientists think have preyed heavily upon young salmon, as well as the large schools of anchovies and sardines that have appeared off the Columbia River.
Data published last year in the journal Progress in Oceanography (Emmett et al., 2005) support earlier hypotheses by other scientists that the low marine survival of Oregon coho was due not to a lack of food, but rather to increased predator activity on salmon when the favorite foods of hake and mackerel, like sardines and anchovies, were scarce.
The paper's authors said their ocean surveys found large numbers of predators like hake in 2003, but speculated that marine survival of salmonids shouldn't be as poor as during most of the 1990s because alternative prey has remained abundant.
The West Coast hake population has grown fast from its "overfished" status a few years back, and is now being targeted by both factory trawlers and smaller vessels. In 2003, hake abundance was estimated at 3.4 billion fish, or 1.8 million metric tons.
With the return to cooler water, the hake may stay farther offshore and give the juvenile salmon a better chance of making it to the Gulf of Alaska. The latest ENSO forecast issued April 6 calls for continued cool La Nina conditions for the next one-to-three months.
Several hundred thousand juvenile spring chinook have already passed Lower Granite Dam on the lower Snake River, on their way to a more hospitable sea. It's the highest smolt estimate for this date in the past six years. Spill began there April 3 and started at mainstem Columbia dams last week. -B. R.
[4] South Coast Gets Some Chinook Fishing This Year, Cuts In North And Puget Sound
The Pacific Fishery Management Council OK'd some ocean fishing south of Oregon's Cape Blanco this year after federal fishery managers had recommended a total closure to protect weak stocks of Klamath River chinook. The Klamath stock has been hammered in recent years by a combination of poor inriver flows for adult passage and a decline in ocean productivity.
After thousands of comments poured in, including a petition with over 7,000 signatures calling for a fishery that targeted the healthy Sacramento chinook stocks, the Council agreed to allow enough fishing that will still allow an estimated 21,000 spawners in the Klamath, while letting ocean commercial and recreational fishermen more than 200,000 chinook.
From Florence north to Cape Falcon (near Cannon Beach), commercial boats will be allowed to fish three to four days a week June through July, with a limit of 75 chinook per week. They will get only a few days to fish in August, September and October. From Arcata to Fort Bragg, a small commercial fishery will be allowed in September, with more fishing south to San Francisco
The Council had expected 25,000 chinook to spawn in the Klamath this year, the third year in a row that that the minimum target of 35,000 spawners would be missed, but they said low numbers of returning fish in past years had produced strong runs in the future. They noted that the 19,000 spawners that returned in 1999 produced a run of nearly 200,000 salmon. Drought conditions in the Klamath Basin have eased, and ocean conditions have likely improved as well compared to the past few years.
Recreational fishermen will not be as restricted, and will even get to fish near the Klamath until July 4 and after September 1.
With the fisheries worth an estimated $133 million to coastal communities, the pressure to keep them open was intense, and the Council will have to pass an emergency rule to keep to allow it. The Secretary of Commerce must still sign off on the proposal.
North of Falcon, the Council approved a non-Indian catch of 65,000 chinook, with 31,000 going to the sport sector. Most of the 80,000 hatchery coho catch was allotted to sporties as well, 73,200 to be exact. Last year, the sports side was allowed 43,250 chinook and about 122,000 coho, but managers expect fewer fish to return this year than in 2005.
The treaty-Indian catch was set at 42,200 chinook and 37,500 coho. Last year, the treaty share was 48,000 chinook and 50,000 coho.
Coho restrictions have increased with the ESA listing of lower Columbia coho, but WDFW head Jeff Koenings said hatcheries are being "re-tooled" to provide sustainable harvests that target hatchery-origin coho, while limiting impacts to weak stocks.
Some additional restrictions will take place in Puget Sound as well, with a two-week closure on the Skokomish River in September, an all-August closure on the Puyallup, with fishing only open on Elliott Bay from July 14 through Aug. 20 (Fridays through Sundays). -B. R.
[5] Feds Recommend Fish Ladders At Pacificorp's Klamath Project
The U.S. Department of Interior and NOAA Fisheries Service have recommended to the Federal Energy Regulatory Commission that PacifiCorp add fish ladders to its 151-MW Klamath River Hydroelectric Project as a condition of renewing the project's license.
The recommendation thrust PacifiCorp onto center stage in a new round of contentious and heated debate over salmon and water policy in the basin.
To protect the Klamath's fall chinook run, the Pacific Fishery Management Council voted to close the ocean to commercial trollers from Florence, Oregon to Arcata, California.
California Gov. Arnold Schwarzenegger joined Oregon Gov. Ted Kulongoski in asking the U.S. Department of Commerce to declare an economic disaster because of the new fishing restrictions.
In PacifiCorp's 7,000 page relicensing application that was filed in 2004, the utility did not include the addition of fish ladders as an option because the estimated costs of installing fish passage would be about $200 million. PacifiCorp's study of habitat in the upper Klamath indicated that water quality and temperature could not support salmon.
Removing the hydro facilities would cost an estimated $100 million.
"Water quality entering our project is already very poor," Dave Kvamme, spokesman for PacifiCorp, told NW Fishletter. "The source of the Klamath is not a pristine snowpacked mountain. The water quality is hypereutrophic--meaning its filled with algae."
PacifiCorp operates the Iron Gate hatchery, just below the Iron Gate dam, which sees about 20,000 adult fish return yearly, Kvamme said. The Iron Gate Hatchery is one of three hatcheries in the basin.
Kvamme added that huge amounts of Klamath River water are diverted for irrigation use, some of which flows back into the river. The basin is also plagued by abandoned side channels once used for logging and the remnants of "really poor" mining practices, he said.
"The reason we didn't call for fish passage is, we just don't think any significant numbers of fish could be produced," he said.
In 2000, the Pacific Fishery Management Council estimated the inriver chinook run totaled 218,077, the second largest run since 1978. In 2003 an estimated 191,948 fish were counted inriver, but that number declined to 79,192 in 2004, and 65,280 in 2005.
Federal fish managers expect about 110,000 fish to return this year.
The debate over Klamath fish has prompted several groups to point fingers at the Klamath project. In May 2004, the California Energy Commission asked FERC to consider decommissioning some or the entire project. The California Water Resources Council, the Resources Agency and the Department of Fish and Game, have joined the CEC in calling for removal of the dams.
"Fully 300 miles of mainstem and tributary salmonid habitat could be made accessible to the Klamath River salmonids if the barriers to passage created by PacifiCorp's lower dams...were removed," the staff of the CEC wrote to FERC.
But none of the agencies pushing for fish ladders could quantify in fish numbers any expected benefits.
PacifiCorp has offered a number of system enhancements in its application to address impacts on fish populations. These include decommissioning two powerhouses which generate 3.8 MW total, increasing minimum flows, augmenting "spawnable gravel," and adding fish screens and some fish ladders at various locations.
Most recently angry commercial fisherman have blamed the dams for the loss of their season.
The utility will file its response to the Fed's recommendations to add fish ladders to three of the six hydroelectric facilities in the project by May 15.
No talks are currently scheduled, but PacifiCorp remains hopeful that a settlement can be reached that will avoid either being forced to build fish ladders or remove the dams completely, Kvamme said.
The project's 151 MW is enough to serve PacifiCorp's customers in Northern California.
"The settlement process, however difficult, has the advantage of being done under confidentially agreements and with a mediator," Kvamme said. "It's in that kind of environment that lots of ideas can be brought forth and we can focus on things that are doable and practicable." -Steve Ernst
[6] Lawsuit Challenges NMFS' New Hatchery/Wild ESA Fish Policy
Several environmental groups have filed a lawsuit in U.S. District Court in Seattle to challenge the new NMFS policy that counts hatchery fish with wild fish in some populations listed under the Endangered Species Act.
The policy was developed after an earlier lawsuit by property-rights groups (Alsea Valley Alliance v. Evans) won a ruling in Oregon that said the agency's coastal coho listing was illegal because listed hatchery fish weren't offered the same protections as the wild component of that ESU.
The groups are also going after a recent action by the federal fish agency to downlist upper Columbia steelhead from "endangered" to "threatened" status.
The lawsuit contends that the new NMFS policy was approved even though a panel of independent scientists had unanimously concluded that wild and hatchery salmonids should be treated separately under the ESA. (See NW Fishletter 177)
The plaintiffs say that including hatchery fish in an ESA listing runs counter to the ESA goal of protecting species in their natural environments.
The groups going after the hatchery policy are represented by Earthjustice, and include Trout Unlimited, American Rivers, Pacific Rivers Council, Wild Steelhead Coalition, Native Fish Society, and the Sierra Club. -B. R.
[7] Fish Passage Center Gets Contract Extension Through November
The Bonneville Power Administration announced last week that it will extend the temporary contract of the Fish Passage Center through November to satisfy concerns that the power-marketing agency is complying with terms of a court order.
The 9th U.S. Circuit Court of Appeals granted a March 17 emergency stay of the FPC's defunding after an environmental group and the Yakama Nation separately filed motions to keep the center alive while the issue awaits a hearing.
The Niners have told all parties to get their briefs done by early August because arguments will likely be heard in September. The argument centers around the use of report language in an appropriations bill inserted by Sen. Larry Craig (R-Idaho) that called on BPA to quit funding the agency. Craig said the FPC played too much of an advocacy role in the region. The FPC analyses of river flows, spill and fish survival have been used by plaintiffs in the ongoing litigation over federal dam operations in the Columbia and Snake rivers.
But critics of Craig's move say it's illegal, and the issue could have ramifications far beyond the Columbia Basin.
BPA had earlier granted a one-month extension of the FPC contract. Greg Delwiche, BPA vice president for Environment, Fish and Wildlife said that the new, one-year contract BPA had signed with the Pacific States Marine Fish Commission for data warehousing is on hold. However, the contract with Battelle Northwest to take over the monitoring and analysis functions of the old FPC contract is in effect, so Battelle can develop the pool of scientific talent that will be used for future analyses.
Delwiche said that BPA would like to demonstrate that the new analysis function will work as planned, and be in place by next fall when the Niners will likely decide the case. Agencies or individuals requesting some type of analysis regarding dam operations, flows and fish survival may soon be able to choose either Battelle's Pacific Northwest Lab or the FPC staff to do the work. -B. R.
[8] Nez Perce Side With Feds In Lawsuit Over Upper Snake Water
The latest briefs in a lawsuit that tries to join different biological opinions which govern upper and lower Snake reservoir and dam operations were filed last week in Oregon District Court, where oral arguments are scheduled to be heard April 26 by Judge James Redden.
A filing by the Nez Perce Tribe shows that it is clearly on the side of federal defendants. The tribe is concerned that any ruling which would link upper and lower Snake BiOps could adversely affect its recent settlement in the Snake River Basin Adjudication Agreement. The agreement limits how much upper Snake water can be used to augment flows in the lower Snake.
In an earlier filing, the tribe said the agreement added a measure of certainty to the annual delivery of Idaho's 427,000 acre-feet of water for flow augmentation, along with permanent acquisition of another 60,000 acre-feet for annual fish flows.
The three other tribes in the lower Columbia region are on the other side of the fence, joining plaintiff American Rivers and other environmental groups, who say the upper Snake operations, which use about 6 million acre-feet of water, should clearly be analyzed in the context of the ESA-listed salmonids in the lower Snake.
But NOAA Fisheries says the operations do not complement one another and are not linked in any way. That's why its consultation over operation of the Bureau of Reclamation projects was separated from operation of the federal dams on the lower Snake and Columbia.
The state of Idaho weighed in as well, arguing that combining the two consultations "would take the focus off remedies directly addressing passage issue at the FCRPS projects in favor of simply masking such effects by pouring additional water down the river."
The state also said that Congress explicitly indicated that flow augmentation from the upper Snake was to be carried out as an independent agency action defined by the Snake River Water Rights Agreement, and that its intent does not conflict with ESA consultation requirements.
Idaho's filing pointed to NOAA Fisheries' analysis of the upper Snake operations, which found that by storing water in the spring at the BuRec projects, the freshet was reduced by about 8 percent, but the action reduced water temperatures and total dissolved gas levels at federal projects downstream.
The feds estimated that during the summer, upper Snake operations actually increased flows by nearly 8 percent and usually increased water temperatures at Lower Granite Dam, reduced them at Ice Harbor and had little effect at McNary Dam.
Idaho said the NOAA SIMPAS passage model estimated a .1 percent to .3 percent reduction in survival of spring chinook migrants from upper Snake operations, while summer fall chinook migrants got up to a 4-percent survival boost from increased flows.
In their own reply brief, the feds said the current remand process to produce a new hydro BiOp would suffer if upper Snake operations were "subsumed" into the FCRPS consultation, and raised the possibility that some of the work completed by the 14 remand workgroups would have to be started over.
The feds also argued that the court should reserve judgment on the merits of the 2005 upper Snake BiOp until the Ninth Circuit Court rules on the federal appeal of the 2004 hydro BiOp because the legal issues in question are "substantially similar." The Niners recently granted an expedited appeal process with oral arguments set for May 25.
The feds took issue with the language in the plaintiffs' opening brief that described their "virtually unbroken" string of victories as a reason for ruling in their favor in this case as well. But government attorneys said that was no reason for the court to adopt an unprecedented standard for defining a proposed action under the ESA, as the plaintiffs suggest.
The feds said adoption of such a standard would make a federal agency determine the biological effects of an action "apparently in a vacuum" and then trace those effects to include all the federal actions within the scope of the biological web. The feds said this may make sense to the environmentalists, but isn't what Congress had in mind when it passed the ESA. -B. R.
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