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to Bill Clinton A Letter from 200 Scientists March 22, 1999

December 18, 2000

President Bill Clinton
The White House
1600 Pennsylvania Ave.
Washington, D.C. 20500

Dear President Clinton,

We, the undersigned scientists, are writing to express our strong disagreement with your administration’s draft biological opinion for Columbia basin salmon and steelhead that was released by the National Marine Fisheries Service (NMFS) on July 27, 2000. As scientists who are familiar with this issue, we feel obliged to inform you that the recovery measures set forth in the biological opinion are unlikely to recover many of the Columbia basin salmon stocks that are listed under the federal Endangered Species Act. For several severely depressed stocks, including those in the Snake River, extinction is not likely to be averted unless the biological opinion is substantially improved.

You may recall the letter we sent you in March 1999 in which we expressed our concern that “the current management approach appears to be fixed on a path of technological solutions instead of a return to more normative river conditions.” We regret to report that that warning apparently has not been heeded. One statement in our previous letter merits repeating: “The weight of scientific evidence clearly shows that wild Snake River salmon and steelhead runs cannot be recovered under existing river conditions.”

Although the draft biological opinion calls for habitat restoration in the Columbia estuary, it does not call for any major improvements to the mainstem migration corridor, where unacceptably high levels of hydrosystem-related mortality would be allowed to continue largely unabated. Similar criticisms have been voiced by fish and game agencies from Oregon, Idaho, and Alaska; tribal fisheries agencies; and the Oregon and Idaho Chapters and Western Division of the American Fisheries Society.

We recognize there are now twelve listed stocks of Columbia basin salmon and steelhead, and any comprehensive recovery plan must address the needs of each individual stock during all stages of their life cycle. However, we continue to emphasize the importance of Snake River salmon because they account for a disproportionately large share of the restoration potential for wild salmon in the Columbia basin. Approximately 70 percent of the Columbia basin’s restoration potential for spring/summer chinook and summer steelhead lies within the Snake basin.

Before addressing the specific flaws in the biological opinion, we caution you not to give too much weight to the reports of abundant salmon returns in the Columbia basin this year. Approximately 80 percent of the “record runs” of spring chinook to the lower Columbia River were of hatchery origin. Likewise, all but ten of the sockeye salmon that returned to the Snake basin this year were products of a captive broodstock program. These returns do not accurately reflect the freshwater habitat conditions wild fish face. Without substantial improvements in freshwater habitat, wild stocks are likely to resume their downward spiral as less favorable environmental conditions return.

Moreover, wild salmon returns to the Snake River continue to be extremely weak. In fact, this year’s return of wild Snake River spring/summer chinook ranked as the fourteenth worst return in history. It will represent a greater than 80 percent decline from the pre lower Snake River dam returns of the 1960s. Even under the extremely favorable outmigration and ocean conditions of the past few years, smolt-to-adult survival for these runs remains insufficient to maintain existing fish populations.

The administration’s draft biological opinion suffers from three fundamental flaws. First, it fails to define scientifically sound standards against which potential recovery measures can be measured. NMFS uses an extremely risky survival metric - the likelihood of reaching absolute extinction - to judge the adequacy of its proposed measures. This is inconsistent with widely accepted conservation biology principles, which call for using a higher abundance level to account for the fact that populations enter an extinction vortex long before declining to one individual. More important, however, is that NMFS has failed to define what is necessary to achieve recovery, which is defined as abundant, self-sustaining populations that are sufficient to support the treaty-based fishery rights of Columbia basin tribes. Until this critical metric is defined, the adequacy of the proposed actions cannot be determined.

Second, it ignores the weight of scientific evidence pointing to the dams as the primary cause for the sharp decline of Snake River stocks over the past few decades. NMFS suggests that recovery of spring/summer chinook could be achieved by improving survival in upriver tributary habitat, where these fish spend their first year of life. This conclusion is inconsistent with the fact that abundant high quality spawning and rearing habitat is already available to these fish. Almost 4000 stream miles remain accessible to Snake River salmon above the lower Snake River dams. One-third of that habitat lies within federally-designated wilderness areas and is in near pristine condition. Empirical evidence clearly shows that juvenile survival in these tributaries has not declined significantly over the past thirty years when Snake River stocks crashed. In contrast, the weight of the evidence supports a different conclusion - that the cumulative effect of passing the four lower Snake River dams is the primary reason for the decline of Snake River spring/summer chinook.

For Snake River fall chinook, the case for dam breaching is even stronger. A recent report funded by the Bonneville Power Administration speaks to the need for mainstem habitat restoration to benefit fall chinook:

“It is not possible to increase natural production of fall chinook in the Columbia River basin without restoring those controlling factors and processes that supported their life history requirements. In this context, selective reservoir drawdown and/or dam breaching, in combination with establishment of more normative flow regimes, is the only viable strategy for restoring mainstem habitat.”

More than half of the 140 river miles currently inundated by the lower Snake River dams has the potential to become quality spawning habitat, according to this study. Similarly, NMFS scientists have acknowledged that breaching the lower Snake River dams is “highly likely” to recover fall chinook. Though it may be possible to prevent extinction of fall chinook by drastically reducing harvest, harvest reductions alone will not recover self-sustaining, harvestable runs because the lack of adequate mainstem spawning and rearing habitat is the primary factor preventing recovery. The draft biological opinion calls for no measures that would significantly improve mainstem habitat in the Snake River.

Finally, and perhaps most important, is the fact that NMFS has not identified any specific, feasible recovery measures that are likely to recover Snake River stocks short of dam breaching. They have only surmised that such measures may exist. More studies, planning, and pilot projects are not going to provide the survival improvements necessary to achieve recovery, yet they are precisely what the draft biological opinion calls for. Dam removal aside, there is absolutely no potential for achieving recovery unless major remedial actions are commenced soon, as there is unanimity among scientists that the risk of extinction in the short term is high. Extinction models show some Snake River stocks have less than two decades before they go extinct.

In conclusion, Mr. President, we repeat our warning that if your administration is truly committed to restoring Columbia and Snake River salmon, NMFS’ draft recovery plan must be amended to address our concerns. We repeat here the words of the Independent Scientific Group, an eminent group of scientists convened by the Northwest Power Planning Council to guide salmon recovery research and planning:

“Without a fundamental change in our approach to salmon restoration, more extinctions of salmon populations are likely and progress toward the rebuilding goal unlikely. Temporary increases in some populations may occur in response to fluctuations in ocean conditions, and small increases may result from large-scale use of technology such as hatcheries, but the overall downward trend in returns that has occurred throughout this century will likely continue without a fundamental change in approach.”

For Snake River stocks, the weight of scientific evidence clearly dictates that the final biological opinion must commit the federal government to plan for breaching the lower Snake River dams in the near term, while simultaneously calling for immediate implementation of real, on-the-ground recovery measures and further research to help resolve remaining uncertainties. If it can be clearly demonstrated in the next few years that other avenues exist to achieve recovery without breaching the dams, then those measures should be pursued. But without such evidence, the lower Snake River dams must be breached soon if Snake River stocks are to be recovered.

Sincerely,

The following Concerned Scientists:

Jeffrey Abrams, fishery biologist, ID
Kimberly A. Apperson, fisheries biologist, ID
Robyn Armstrong, fisheries biologist, ID
Bill Arnsberg, fisheries biologist, ID
Becky Ashe, fisheries biologist, ID
Dan Averill, aquatic biologist, OR
Ed L. Avery, salmonid research scientist, WI
John S. Barclay, PhD, Professor of Wildlife Biology, University of Connecticut, CT
Colden Baxter, fisheries research biologist, OR
Peter B. Bayley, PhD, Professor of Fisheries, OR
egon State University, OR
Hal A. Beecher, PhD, fish ecologist, WA
Jerry Berg, fishery biologist, AK
Hans B. Berge, fisheries biologist, WA
Robert F. Bessey, fish biologist, OR
Patricia Bigelow, fishery biologist, ID
Randy Binder, fisheries biologist, MN
Charles L. Blair, ecologist, ID
Edward S. Bosse, conservation scientist, ID
Nick Bouwes, PhD, fisheries scientist, OR
Douglas Bradley, fisheries biologist, ID
Bill Bradshaw, fisheries management biologist, AFS-Western Division President, WY
Jody Brostrom, fishery biologist, ID
Evan M. Brown, fisheries biologist, ID
Kevin M. Brownlee, fishery scientist, AK
Edwin Buettner, fisheries scientist, ID
Deb Bumpus, endangered species biologist, ID
David C. Burns, PhD, fisheries scientist, ID
Paul Burns, fishery biologist, OR
James M. Cahow, stream biologist, WI
Henry J. Calanchini, PhD, fisheries research biologist, CA
David Cannamela, fisheries biologist, ID
Gary Carnefix, fisheries research biologist, MT
R. Scott Carney, anadromous fisheries biologist, PA
Beverly Chaney, fishery biologist, CA
Caty Clifton, forest hydrologist, OR
Edouard J. Crateau, retired Lower Snake River Compensation Plan Coordinator, ID
Tom Curet, fisheries biologist, ID
Michele DeHart, Fish Passage Center Manager, OR
Shana Dodd, wildlife biologist, CA
Lawrence G. Dominguez, salmon biologist, WA
Buddy Drake, aquatic biologist, MT
Walter Duffy, PhD, fishery biologist, CA
Nicholas Duncan, fisheries biologist, OR
Jason Dunham, PhD, research fishery biologist, ID
Israel N. Duran, fishery biologist, WA
William P. Dwyer, fishery biologist, MT
Timothy J. Ehlinger, PhD, Professor of Biological Sciences, U of Wisconsin-Milwaukee
Steve Elle, fishery biologist, ID
Michael D. Enk, fisheries biologist, MT
Al Espinosa, fisheries scientist, ID
Michele Ferry, research program analyst, WA
Margaret J. Filardo, PhD, fishery biologist, OR
Scott A. Fleury, PhD, conservation biologist, CA
Frazey, Sharon, biological technician, OR
Jeffrey K. Fryer, PhD, fisheries scientist, OR
Craig Fusaro, PhD, marine/environmental scientist, CA
Daniel B. Gale, fisheries biologist, CA
Mark Gamblin, fisheries biologist, ID
Kurt Gamperl, PhD, Associate Professor of Biology, Portland State University, OR
Gayle Garman, PhD, aquatic ecologist, CA
Bob Garner, fisheries biologist, OR
Thomas A. Gavin, PhD, Professor of Fisheries, Cornell University, NY Stephen R.Gephard, fisheries biologist, CT
Michael J. Gratson, PhD, research biologist, ID
Warren J. Groberg, PhD, retired fish pathologist, OR
Richard T. Grost, fisheries scientist, OR
William E. Haas, wildlife ecologist, CA
David G. Hankin, PhD, Professor of Fisheries, Humboldt State University, CA
Michael Hanks, research scientist, OR
Dale Hanson, fisheries biologist, OR
Archie Harper, fisheries biologist, MT
Charles E. Harris, PhD, wildlife research biologist, ID
Pete Hassemer, fishery biologist, ID
Shelly Hatleberg, biologist, CA
James M. Haynes, PhD, Professor of Biological Sciences, SUNY-Brockport, NY
Roy Heberger, Jr., retired USFWS biologist, ID
Robert Heinith, fisheries scientist, OR
Michael L. Hendricks, fisheries scientist, PA
Nathaniel P. Hitt, President, Montana Chapter of Society for Conservation Biology, MT
Nancy J. Hoefs, fish ecologist, ID
Robert House, fishery biologist, ID
Steven R. Howard, fisheries biologist, CA
Robert M. Hughes, PhD, aquatic ecologist, OR
John W. Icanberry, fishery biologist, CA
Andrew Jensen, fisheries biologist, CA
Ian Jesorek, fishery biologist, WA
David B. Johnson, hatchery production coordinator, ID
Ryan Johnson, fisheries biologist, ID
Paul D. Kanehl, fisheries research biologist, WI
Jacob Kann, PhD, aquatic ecologist, OR
James R. Karr, PhD, ecologist, University of Washington, WA
Malcolm Karr, retired hydrologist, WA
Paul F. Kazyak, fishery biologist, MD
Russell B. Kiefer, salmon research biologist, ID
Mary Claire Kier, fishery biologist, CA
Sue Knapp, fisheries biologist, WA
Willaim L. Knotek, fish management biologist, MT
E. Eric Knudsen, PhD, fisheries scientist, AK
Kathy L. Knudsen, research geneticist, MT
Patrick M. Kocovsky, fishery research biologist, PA
Greg Koonce, fishery biologist, OR
Sharon H. Kramer, PhD, fisheries biologist, CA
Steve H. Kramer, fisheries biologist, CA
Keith Kutchins, anadromous fisheries biologist, ID
Karen Kuzis, WA
tershed specialist, ID
Michael B. Lambert, fisheries biologist, OR
Mike Larkin, fishery biologist, ID
R. Ed Larson, hatchery production manager, ID
Ron Larson, PhD, fishery biologist, OR
Jayne LeFors, fisheries biologist, OR
Eric Leitzinger, fisheries biologist, ID
Hiram W. Li, PhD, Professor of Fisheries Science, Oregon State University
Judith Li, PhD, Professor of Fisheries Science, Oregon State University
Stephanie D. Lindloff, river restoration specialist, WI
Peter T. Lofy, fish biologist, OR
Gregg Lomnicky, PhD, aquatic ecologist, OR
Steve Lundt, WA
ter resource specialist, OR
Beth MacConnell, fishery biologist, MT
Dorene E. MacCoy, biologist, ID
Terry Maret, aquatic biologist, ID
Derek E. Marks, fisheries biologist, WA
J. Ellen Marsden, PhD, fishery biologist, VT Jim Martin, retired fisheries chief, OR
egon Department of Fish and Wildlife, OR
Jennifer L. Matthews, PhD, research scientist, OR
Gregg Mauser, fishery biologist, ID
Dale A. McCullough, PhD, fishery scientist, OR
Christine McGuire, fishery biologist, CA
Ron G. McMullin, fisheries biologist, OR
Martin J. Melchior, fisheries/stream restoration specialist, WI
Dennis Mengel, PhD, ecologist, ID
Eric Merten, fisheries biologist, MN
William H. Miller, PhD, fishery biologist, ID
G. Wayne Minshall, PhD, stream ecologist, Idaho State University, ID
W. Linn Montgomery, PhD, Professor of Fisheries, Northern Arizona University, AZ
Peter B. Moyle, PhD, Professor of Fisheries, University of California-Davis, CA
Dietland Muller-Schwarze, PhD, Prof. of Environmental Biology, SUNY-Syracuse, NY
William H. Mullins, biologist, ID
Michael Mulvey, aquatic biologist, OR
Katherine W. Myers, PhD, Professor of Fisheries, University of Washington, WA
Richard K. Nawa, ecologist, OR
John E. Nelson, fisheries biologist, WI
Douglas J. Nemeth, fisheries biologist, FL
Richard J. Neves, PhD, fishery biologist, Virginia Tech University, VA
Robert Nichols, fishery biologist, OR
Gretchen R. Oosterhout, PhD, system/decision analyst, OR
Wess Orr, fisheries biologist, MT
Kerry C. Overton, fisheries scientist, ID
Steven S. Parker, fishery biologist, WA
Kathleen Patnode, PhD, fish and wildlife biologist, PA
Edward Perry, aquatic biologist, PA
Gary D. Peterson, fisheries biologist, CA
Charles Petrosky, PhD, fisheries scientist, ID
Ginger Phalen, biologist, WA
Scott A. Putnam, fishery biologist, ID
Richard Pyzik, fish habitat biologist, OR
Jonathan J. Rhodes, fishery scientist, OR
Carl Richards, PhD, Professor of Biology, University of Minnesota-Duluth, MN
Pat Rivers, fisheries biologist, MN
James B. Reynolds, PhD, Professor of Fisheries, University of Alaska-Fairbanks, AK
Lou Reynolds, fishery biologist, PA
James A. Rice, PhD, Professor of Zoology, North Carolina State University, NC
Cathleen E. Rose, fisheries biologist, OR
Jonathan Rosenfield, conservation ecologist, NM
Robert M. Ross, PhD, ecologist, PA
Carl Safina, PhD, marine scientist, Audubon Society, NY
Saul B. Saila, PhD, Professor Emeritus of Oceanography, University of Rhode Island, RI
Alan R. Sands, wildlife biologist, ID
Jessie Schillaci, senior scientist, FL
Daniel Schneider, PhD, aquatic ecologist, IL
Bill Schrader, fisheries biologist, ID
David A. Seibel, fisheries biologist, WI
Paul Seronko, environmental protection specialist, ID
Gregg Servheen, fish and wildlife management biologist, ID
Fraser Shilling, PhD, ecologist, University of California-Davis, CA
Thomas C. Shirley, PhD, Professor of Fisheries, University of Alaska-Fairbanks, AK
Wayne Simmons, biologist, ME
Gary E. Smith, fishery biologist, CA
Jason A. Smith, fisheries biologist, OR
Karen A. Smith, fisheries biologist, ID
Richard W. Soderberg, PhD, Professor of Fisheries, Mansfield University, PA
Nick Southall, hydrologist, OR
Wayne D. Spencer, PhD, conservation biologist, CA
Sherman Sprague, fisheries biologist, ID
Eric Stark, fisheries research biologist, ID
David P. Statler, fisheries scientist, ID
Jim Steele, environmental scientist, CA
Geoffrey B. Steinhart, aquatic ecologist, OH
Sharon Stohrer, environmental specialist, CA
Ruth Sundermeyer, senior biologist, CA
Doug Taki, fisheries biologist, ID
Pater Tango, PhD, natural resource planner, MD
Kristen Taylor, fisheries biologist, NJ
Ross N. Taylor, fisheries biologist, CA
William Thorn, fisheries research biologist, MN
Russ Thurow, fisheries research scientist, ID
Kimberly True, fish health biologist, CA
Tim Unterwegner, fish biologist, OR
Robert L. Vadas, Jr, PhD, fisheries biologist, FL
Angelo Vitale, fisheries biologist, ID
Jason Vogel, fisheries project leader, ID
Vicki Watson, PhD, Professor of Environmental Studies, University of Montana, MT
Earl Weber, fisheries scientist, OR
David L. Wegner, PhD, aquatic ecologist, CO
Miller G. White, fisheries biologist, SC
Robert Wilberding, fish hatchery manager, PA
Matthew Wilcox, fisheries biologist, WA
Roger S.C. Wolcott, fishery biologist, OR
Aimee Wyrick, aquatic ecologist, MT
Frank Young, fisheries biologist, OR
David J. Zaber, PhD, wildlife biologist, WI
Don W. Zaroban, fisheries scientist, ID
Joy B. Zedler, PhD, Aldo Leopold Prof. of Restoration Ecology, U of Wisconsin, WI
Bruce Zoellick, fisheries Biologist, ID
Troy Zorn, fisheries research biologist, MI
Caleb Zurstadt, fishery biologist, ID
Roberta J. Zwier, wildlife biologist, PA

cc: Donna Darm, NMFS