Federal Response:
For the 2000 Biological Opinion, NOAA proposed estimating free-flowing Snake River survival rates by estimating survival rates of PIT-tagged smolts from both the Salmon River trap to the Lower Granite bypass and from the Snake River trap (at the head of Lower Granite Reservoir) to the Lower Granite bypass. The per-kilometer survival rate of the free-flowing portion of the Snake River could be inferred from these differences between these two trap-to-dam estimates (Ferguson et al 2004).

For the CRSO Draft EIS, NMFS used a similar method of estimating free-flowing survivals and travel times with their COMPASS model. PIT-based monitoring efforts have been added at a variety of additional hatchery and wild trap locations in the Snake and upper Columbia since the 2000 BiOp. The Salmon trap to Lower Granite reservoir free-flowing survival rate is used as representative of yearling Chinook populations for the main text of the MO3 analysis.

In the appendix, NMFS carries out a sensitivity analysis for the choice of upstream trap location by comparing free-flowing survival rate estimates from the Grande Ronde, Salmon, and Imnaha traps to Lower Granite Dam to represent dam breach conditions under MO3. There is a wide variance in per-kilometer travel times and survival rates to Lower Granite Dam among all the hatchery and wild trap locations. The three locations were selected by NMFS to represent spatial variation in stream conditions such as natural predation rates. Most juveniles at these sites are tagged as outgoing smolts and few display signs of continued tributary rearing.

Ferguson J. (2004) Memorandum to FCRPS Biological Opinion Remand Administrative Record RE: Updated estimates of free-flowing river survival. NW Fisheries Science Center.

Federal Response:
For the 2000 Biological Opinion, NMFS proposed estimating free-flowing Snake River survival rates by estimating survival rates of PIT-tagged smolts from both the Salmon River trap, and from the Snake River trap (at the head of Lower Granite Reservoir) to the Lower Granite bypass. The per-kilometer survival rate of the free-flowing portion of the Snake River could be inferred from the difference between these two trap-to-dam estimates (Ferguson et al. 2004).

For the CRSO EIS, NMFS used a similar method of estimating free-flowing survivals and travel times with their COMPASS model. PIT-based monitoring efforts have occurred at 20-plus additional hatchery and wild trap locations in the Snake and upper Columbia since the 2000 BiOp.

In Appendix E, NMFS carried out a sensitivity analysis for the choice of upstream trap location by comparing free-flowing survival rates estimates from the Grande Ronde, Salmon, and Imnaha traps to Lower Granite Dam to represent dam breach conditions under alternative MO3.

There is a wide variance in per-kilometer travel times and survival rates to Lower Granite Dam among all of the possible hatchery release sites and screw trap locations upstream of Lower Granite Dam. The river conditions and migration behavior of fish in tributaries to the Snake River is much less representative of river conditions we expect in the lower Snake River following dam breaching than are the river conditions in the free-flowing Snake River between the confluence of the Clearwater River and the confluence of the Salmon River.

NMFS selected the three locations because each trap location was low in the tributary and are very close to the mainstem Snake River; we expect that reach of the free-flowing Snake to be very similar to what the breached lower Snake would look like in MO3. Traps further up in the tributaries are likely to tag more parr while these three traps tend to intercept mostly smolt-aged fish that arrive at Lower Granite without further rearing behavior. Yet it does appear that some fish in the Lower Granite and Imnaha (GRN-IMN) data exhibit parr-like behavior, especially in early April. This is a major contributor to why the GRN-IMN model predicts slower migration and lower survival in MO3 than the other calibrations, and the reason for why it was placed into the appendix. The Salmon trap-to-Lower Granite reservoir free-flowing survival rate is used as a representative yearling Chinook population for the main text of the MO3 analysis.

In response to the comment "outside the range of the data so the model is useless," this criticism can only apply to the SNK calibration. Yes, MO3 is outside the range of the calibration data for the SNK calibration, as is noted in the CRSO EIS text.

The calibration between the Snake River Trap and Lower Granite Dam was just a calibration used to get at the GRN-IMN and SAL calibrations, and was not used in any prospective model runs for the Draft EIS. However, the SAL and GRN-IMN calibrations are NOT outside the range of the calibration data when used for MO3. Flow, water velocity and temperature are all comparable between the free-flowing reaches of the Snake River used for calibration and the breached Lower Snake in MO3.

Ferguson J. (2004) Memorandum to FCRPS Biological Opinion Remand Administrative Record RE: Updated estimates of free-flowing river survival. NW Fisheries Science Center.

Federal Response:
The model results presented in Section 3.5 and Chapter 7 address latent mortality and reservoir mortality. Latent mortality is captured directly in the CSS model for SARs and abundance levels, and is overlaid with several assumed values (10%, 25% and 50% reductions in latent mortality) in the NMFS Life Cycle model results because the level of latent mortality is uncertain. In fact, the ISAB in their 2007 report stated, "The ISAB concludes that the hydrosystem causes some fish to experience latent mortality, but strongly advises against continuing to try to measure absolute latent mortality. Latent mortality relative to a damless reference is not measurable. Instead, the focus should be on the total mortality of in-river migrants and transported fish, which is the critical issue for recovery of listed salmonids. Efforts would be better expended on estimation of processes, such as in-river versus transport mortality that can be measured directly."

bluefish counter response:
In "Evaluating river management during seaward migration...", well regarded salmon biologists Schaller, Petrosky and Tinus address the Independent Science Advisory Board (ISAB) concerns quoted above.

Conclusion of "Evaluating river management during seaward migration..." Schaller et al.
In this paper, we extended previous studies to elaborate and further test the hypothesis (consistent with recommendations of the ISAB 2007) that increased delayed mortality in the Snake River Chinook salmon populations occurs as a consequence of outmigration through the hydropower system.

Abstract of "Evaluating river management during seaward migration..." Schaller et al.
Evidence suggests Snake River stream-type Chinook salmon (Oncorhynchus tshawytscha) experience substantial delayed mortality in the marine environment as a result of their outmigration experience through the Federal Columbia River Power System (FCRPS). We analyzed mortality patterns using methods that incorporated downriver reference populations passing fewer dams, and temporal approaches that were independent of reference populations. Our results from the alternative spatial and temporal methods consistently corroborated with spawner–recruit residuals and smolt-to-adult survival rate data sets, indicating that Snake River salmon survived about one quarter as well as the reference populations. Temporal analysis indicated that a high percentage (76%) of Snake River juvenile salmon that survived the FCRPS subsequently died in the marine environment as a result of their outmigration experience.

There are additional scientific uncertainties regarding mechanisms and magnitude of delayed mortality or carryover effects resulting from migration through the CRS. Several studies using acoustic or active tags have monitored the survival of smolts through the estuary and coastal ocean below Bonneville Dam after barging vs. migrating in river (Eder et al. 2009, Dietrich et al. 2016, Rechisky et al. 2012), and following passage through eight dams vs. four dams (Rechisky et al. 2013). While there were short-term indications showing effects of barging, there was little evidence for delayed survival effects of multiple dam passage in the estuary below Bonneville. This remains an active area of research.

• Survival and travel times of in-river and transported yearling Chinook salmon in the lower Columbia River and estuary with investigation into causes of differential mortality. Final Report submitted to the USACE, Walla Walla District, Walla Walla, Washington. Dietrich, J., Eder, K., Thompson, D., Buchanan, R., Skalski, J., McMichael, G., ... & Loge, F. (2016).
• Survival and transit of in-river and transported yearling Chinook salmon in the lower Columbia River and estuary. Fisheries Research, 183, 435-446. Rechisky, E. L., Welch, D. W., Porter, A. D., Jacobs-Scott, M. C., & Winchell, P. M. (2013).
• Influence of multiple dam passage on survival of juvenile Chinook salmon in the Columbia River estuary and coastal ocean. Proceedings of the National Academy of Sciences, 110(17), 6883-6888.

EGREGIOUS -- bluefish counter response:
Despite all evidence to the contrary, NOAA Fisheries continues to ignore the survey of literature reported in Table 6 of Schaller et al. regarding delayed mortality; mortality following injury from the CRSO.

Deceitfully, NOAA would have us believe that their "Life Cycle Model" (LCM) captures a reasonable range of delayed mortality. But it does not. Their range begins at 0% and ends at 50% whereas the survey of literature finds delayed mortality to be 56% - 76%. The 0% is a complete outlier!

"Evaluating river management during seaward migration..." Schaller et al.
Our enhanced approach enabled us to estimate the impacts of the hydrosystem and address past criticisms for these types of evaluations (Zabel and Williams 2000; Schaller et al. 2000). The expansion of the SR data from seven index populations in three MPGs to 18 Snake River populations in all of the MPGs upstream of Lower Granite Dam, with varying degrees of recent hatchery influence, substantially increased the geographic representation of the Snake River ESU.
. . .
The notable exception to analyses supporting substantial delayed mortality resulted from an analytical approach that assumed common productivity (Ricker a) among all Columbia basin populations and negligible hydrosystem mortality to fish passing three dams (Hinrichsen and Fisher 2009). The assumptions for the outlier have little to no analytical support.

Moreover, NOAA's LCM results do not correspond to results from the Fish Passage Center's "Comparative Survival Study" (CSS). And rather than improving their LCM assumptions -- extending the range to cover 75% -- they instead suggest that "uncertainty" is hindering good judgement. Ludicrous.

"Evaluating river management during seaward migration..." Schaller et al.
"the uncertainty in model output... leads to increased uncertainty for decision makers." -- Executive Summary page 17 "Because MO3 would be a relatively large change to how the CRS is managed today, there is uncertainty around how the river and associated resources would respond. However, in the case of fish, both salmon and steelhead models, CSS and the LCMs, align in their prediction that MO3 would have the highest potential benefits for Snake River salmon and steelhead. While the models align on the positive direction of the impact, the differences in their specific numeric estimates also highlight uncertainty around the magnitude of that benefit." Executive Summary, page 30.

At the famous "What if we breach?" meeting at Boise's McClure Center where Idaho's US Representative Simpson's candor surprised many, I spoke with Oregon's Ed Bowles previously of Idaho Fish & Game, on the delayed mortality topic. He chided NOAA's obstinance. Bowles pointed out that when it comes to barge and truck transport of juvenile salmon, bypassing the grave CRSO hazard, NOAA finds substantial delayed mortality. How could NOAA then suggest the plausibility of zero delayed mortality for juveniles migrating down through the hydrosystem? It is preposterous.

NOAA's 0%-50% range of assumption completely misses the mark, and that is why their model does not match up with the CSS model. Many salmon biologists have been critical of NOAA's unsupportable assumption. Yet here we sit, dumbfounded, with a Final EIS in which expert opinion carries no meaning: Set aside, it is ignored.

"A small mind is obstinante. A great mind can lead and be led." -- Alexander Cannon

The survey of literature flies in their face, they duck, and act like 75% delayed mortality is not supported, while 0% somehow is. Why stretch rationatiy? Because it hides a dismal reality. Only one of eight juveniles from Idaho survive the CRSO unscathed. When 75% mortality follows a measured 50% direct CRSO mortality, only one out of eight survive the hazard.

I have brought Schaller's Table 6 to the attention of NOAA's Graves, ACOE's Ponganis, BPA's Manizer and many others, but they never metion it anywhere, and continue to cling to model assumptions that are unsupported.

This bluefish comment includes the table once again, and the CRSO process refuses to even recognize the mere existence of Schaller's Table 6 and their survey of the science literature. Notice that the names of scientist of Table 6 do not appear in their footnotes, or in their response to this comment.

Their goal is to conceal what they wish us not to see, and that is illegitimate and reprehensible.

The Preferred Alternative includes an adaptive management process that would consider additional opportunities to further the effectiveness of the operation while maintaining the goals of the flexible spill operation: additional improvements for salmon and steelhead, maintain opportunities to operate the CRS for hydropower generation in a flexible manner that provides value to the Northwest, is implementable by the dam operators, and provides opportunity to reduce uncertainty and improve the learning opportunities around how operations of the CRS can influence the magnitude of latent mortality effects. The Preferred Alternative will be implemented using a robust monitoring plan to help narrow the uncertainty between the two models and to determine how effective increased spill can be towards increasing salmon and steelhead returns to the Columbia Basin.

Federal Response: Thank you for your comment, the co-lead agencies concur with this comment.

bluefish counter response: Well that's a good thing, because it is a direct excerpt from the CRSO Draft.

Federal Response:
The EIS set forth eight objectives which, in tandem with the Purpose and Need Statement, establish the framework for evaluating the ability of an alternative to satisfy the co-lead agencies numerous legal obligations. The Preferred Alternative meets the objectives of the EIS for ESA-listed juvenile and adult anadromous salmonids, resident fish, lamprey, hydropower generation, water management, and water supply, while minimizing adverse effects to communities and the economy. The co-lead agencies are legally obligated to operate and maintain the CRS to meet multiple statutory purposes. They are also required to ensure operation of the CRS complies with other laws. Under the ESA, in particular, the operation of the CRS may not appreciably reduce the likelihood of ESA-listed species survival and recovery, or adversely modify or destroy species habitat. The ESA does not, however, require the co-lead agencies to take affirmative actions to recover ESA-listed species.

The EIS concluded MO3, which includes breaching the four lower Snake River dams would have greater improvement to certain salmon species in the lower Snake River. It did not, however, conclude there was greater certainty of that result in MO3 over any other alternative. Because of delayed response time in MO3, and the potential severity of the short term effects, MO3 would likely have the most substantial uncertainty in terms of beneficial effects.

bluefish counter response: As discussed in the counter response above, NOAA assumption that delayed mortality ranges between 0% and 50% completely misses the mark, and that is why NOAA's LCM model does not corresond to the results of Fish Passage Center's CSS model. Many salmon biologists have been critical of NOAA's unsupportable assumption, but their words have landed upon deaf ears.

Executive Summary:
Given the ongoing regional and scientific debate over these two models, the co-lead agencies decided to use both models to evaluate the range of potential impacts in the CRSO EIS. This approach allows for a transparent examination of the results and assumptions embedded in the two primary analytical models and allows the co-lead agencies to share the assumptions and results of both models to inform decision making. The differences in the two models illustrate the complexity of predicting how anadromous fish would respond to different management actions and highlight the uncertainty that future research and management decisions will need to address.

Following the lead of the 2002 EIS on the same topic, this CRSO EIS purposefully builds uncertainty into their models, so that they can claim "substantial uncertainty" as an excuse for not doing what the science clearly reveals is necessary. Importantly, both the LCM and the CSS find that Remove Lower Snake River Embankments is by far the best option for Idaho's ESA-listed fish.

The 2002 EIS also found that LSR dam breaching was by far the "environmentally preferred alternative" but paused implementation, because it had not been proven that such action was "necessary at this time". And similar to the CRSO EIS, "uncertainty" was reason for not breaching then too.

Regarding the Preferred Alternative, this alternative is not simply a minor change to operations and maintenance of the CRS. The spill operation for juvenile fish passage in the Preferred Alternative is a significant departure from previous operations, so much so that the Washington and Oregon state water quality standards had to be changed to implement the new spill regime.

The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as the MO3 which includes the dam breaching measure. The Preferred Alternative also meets the EIS objectives for resident fish, lamprey, hydropower generation, water management, and water supply, while minimizing adverse effects to communities and the economy.

With respect to the Preferred Alternative, the CSS model predicts that average Smolt-to-Adult return rates will increase for both Snake River spring Chinook and steelhead and will average well above 2% (the lower end of Northwest Power and Conservation Council's recovery targets for the region) as a result of the Preferred Alternative, as a result of the Preferred Alternative increasing SAR from 2.0% to 2.7% for Chinook, a 35% relative increase. The NMFS COMPASS and Life Cycle models predict higher levels of risk associated with increased spill levels in the absence of offsets from decreased latent mortality. To address uncertainty highlighted by the two models, the Preferred Alternative includes working with regional sovereigns to develop a study that assess the effectiveness of the increased spill regime on adult returns as well as assessment and management of adverse unintended consequences, such as long delays of adult migrants, or TDG-related mortality of juvenile migrants. See Appendix R, Part 2 Process for Adaptive Implementation of the Flexible Spill Operational Component of the Columbia River System Operations EIS for additional information. The Preferred Alternative will make a meaningful contribution towards recovery.

The overall health and condition of the Southern Resident Killer Whale (SRKW) depends on the availability of a variety of fish populations throughout their range. SRKW are Chinook specialists, but also consume other available prey populations while they move through various areas of their range in search of prey. National Marine Fisheries Service (NMFS) and the Washington Department of Fish and Wildlife (WDFW) have developed a prioritized list of Chinook salmon within their range that are important to SRKW, to help prioritize actions to increase prey availability for the whales (NMFS and WDFW 2018). This list includes many Columbia River Basin Chinook salmon stocks including lower Columbia fall run (Tules and Brights), Upper Columbia and Snake fall run (Upriver Brights), Lower Columbia River spring run, Middle Columbia River fall run, and Snake River spring/summer run. SRKW also are known to eat some steelhead, coho, and chum salmon, and halibut, lingcod, and big skate while in coastal waters. The diet is dominated by Chinook salmon both in coastal waters and within the Salish Sea; SRKW are opportunistic feeders that follow the most abundant Chinook salmon runs throughout their range from the west side of Vancouver Island to the central California coast. Snake River spring/summer Chinook salmon is a small portion of SRKW overall diet, but can be an important forage species during late winter and early spring months near the mouth of the Columbia River (Ford 2016).

NMFS CSS and Lifecycle models predict that lower Snake River Chinook salmon Smolt-to-Adult return rates (SARs) would have a moderate to major increase under MO3. Operation of Lower Snake River Compensation Plan fish hatcheries under MO3 is uncertain and therefore, production of Snake River hatchery fish is assumed to decline over the long-term, while returning adult wild salmon are anticipated to increase. However, the co-leads do not anticipate a lack of hatchery fish in the short-term based on the proposed fish hatchery mitigation described in Chapter 5. These additional hatchery fish should mitigate short-term construction effects to Snake River populations. Additionally, to address short-term effects to ESA-listed species, the co-lead agencies propose constructing a new trap and haul facility at McNary and conducting at least two years of trap and haul operations for Snake River fish (Chinook, sockeye, and steelhead). Therefore, there may be short-term adverse effects to the SRKW population as the lower Snake River wild salmon populations adjust to changes associated with dam breaching.

bluefish counter response:

Shoshone-Bannock Tribes' CRSO Tribal Perspectives Document:
The Lower Snake River Compensation Plan (LSRCP) was authorized in 1976 explicitly to mitigate for lost commercial and recreational harvest opportunities associated with the construction and completion of the four dams on the Lower Snake River (Corps of Engineers 19759). LSRCP included a significant hatchery program aimed at compensating for the estimated loss of 48% of juveniles migrating through the system and set production goals at 11 hatcheries to offset that loss (ISRP 200210). Throughout the program's history up to present, LSRCP programs have not met their compensation goals in most years despite decades of hatchery reform and expensive changes to System infrastructure to increase the viability of hatchery reared juveniles and decrease System related losses, respectively (Marshall 201011, Marshall 201212). ... The failure of the LSRCP to meet its congressionally authorized goals parallels continued declines in wild anadromous fishes above the four Lower Snake River dams and demonstrates that the losses associated with the current configuration of the System may be too great, and its effects too strong, to adequately mitigate.

The co-lead agencies agree that the quantity and quality of prey is one of the limiting factors identified by NMFS in recovery of SRKW, along with vessel traffic and noise, and toxic contaminants. The operation of the CRS directly affects Chinook salmon, both wild and hatchery origin fish, which migrate past these Federal dam and reservoir projects, and the associated effects would indirectly affect SRKW. However, according to NMFS, in terms of the overall abundance of Chinook salmon available to SRKW for prey, numbers of adults from the Snake River Basin (including both hatchery and wild produced fish) are now greater than they were in the 1960s, before three of the four lower Snake River dams were built. NMFS maintains that hatcheries produce more than enough Chinook salmon in the Columbia River basin to offset losses caused by the dams. So far as researchers can determine, SRKW do not distinguish between or benefit differently from hatchery and wild fish. Hatchery fish today likely make up the majority of fish consumed by SRKW (NMFS BiOp 2020). The co-lead agencies conclude there could be a negligible to minor beneficial effects to SRKW from implementing MO3. Additionally, MO3 is not likely to adversely affect the SRKW distinct population segment in the short-term analysis because increased hatchery production and the new trap and haul facility at McNary proposed for MO3 in Chapter 5 would address any potential short-term impacts. Additional details on the most crucial prey stocks for SRKW, as well as their population and range, is available from several fact sheets and videos available here: www.fisheries.noaa.gov/species/killer-whale#spotlight. For more information, visit this NMFS StoryMap on SRKW.

bluefish counter response: Executive Summary:
To suggest that implementing MO3 would have "negligible to minor beneficial effects" completely contradicts the CRSO findings. Let's recap those findings discussed above and in the referenced documents.

Snake River Fall Chinook are listed near the top of WDFW's Priority Chinook Stock List (with a score of 4.25 out of 5). The CRSO clearly states that MO3's Remove Lower Snake River Embanments would increase the spawning area of these Fall Chinook by 15 times.

How could that translate into a "negligible to minor beneficial effect" for cricitally endangered SRKW? This is a bald-faced lie, and the greatest of Fatal Flaws in this NEPA document.

Excerpt from first paragraph of Federal Response to bluefish (above)
The Preferred Alternative meets the objectives of the EIS for ESA-listed juvenile and adult anadromous salmonids, resident fish, lamprey, (no mention of SRKW), ... Under the ESA, in particular, the operation of the CRS may not appreciably reduce the likelihood of ESA-listed species survival and recovery

Federal Response:
The commenter is correct regarding projected effects on adult upstream migrants under MO3. Fallback may increase under conditions of higher flow and spill. Powerhouse surface passage structures were not anticipated to have a large effect on juvenile passage or adult fallback in the CSS and NMFS COMPASS models but were primarily discussed qualitatively. As real world operations are implemented, increased evidence of fallback would be managed through in-season adaptive management as part of the Regional Forum teams like TMT.

Federal Response:
The NMFS COMPASS model forecasted a 23% improvement in in-river survival, and 45% decrease in travel time, and the CSS model predicted a 46% increase in survival and 32% decrease in travel time for Snake River steelhead. The substantial (178%) increase in SAR under MO3 relative to the No Action Alternative in the CSS model results both from the improvement in in-river survival and a decline in delayed mortality.

Federal Response:
The co-lead agencies are legally obligated to operate and maintain the CRS to meet multiple statutory purposes. They are also required to ensure operation of the CRS complies with other laws. Under the ESA, in particular, the operation of the CRS may not appreciably reduce the likelihood of listed species survival and recovery, or adversely modify or destroy designated critical habitat. The ESA does not, however, require the co-lead agencies to take affirmative actions to recover ESA-listed species.

Based on the fish analysis in Section Chapter 7.7.4, the co-lead agencies anticipate that the Preferred Alternative would provide substantial benefits to ESA-listed species and is not expected to diminish the likelihood of recovery. Recovery is a broader regional goal and is above and beyond the co-lead agencies obligations under Section 7(a)(2) of the ESA for the effects of operation and maintenance of the CRS. That call, however, is ultimately the role of NMFS and the USFWS. Recovery efforts will need to continue to involve parties across the region that have an influence and impact on ESA-listed species.

bluefish counter response:
Catch-22, a circle of responsibility has been established where the co-lead agencies point to NOAA Fisheries, who then points back to the co-lead agencies that are directing this CRSO process. This has become a common strategy over the past decades and Snake River salmon populations continue to decline.

ESA Recovery Plan: Snake River Spring/Summer Chinook Salmon NOAA Fisheries, November 2017

. . .

The Preferred Alternative is nevertheless predicted to benefit salmon and steelhead. It also meets the other objectives of the study for resident fish, hydropower, water management, and water supply, while minimizing adverse impacts to communities and the economy. MO3, by contrast, has significant regional economic and community effects, and meets fewer of the EIS objectives. Thus, in the Draft EIS, the co-lead agencies did not recommend MO3 which includes breaching the four lower Snake River dams, because the Preferred Alternative is more likely to satisfy multiple complex and at times conflicting legal requirements for a complex system.

Federal Response:
Thank you for the summary of the environmental consequences analysis of the Draft EIS for Snake River fall-run Chinook, under MO3.

bluefish counter response:
The following is an essential CRSO excerpt that is vastly important for the "continued existence" of Southern Resident Killer Whales (SRKW).

Yet elsewhere in the CRSO EIS we are asked to believe that "implementing MO3" would have only "negligible to minor beneficial effects to SRKW". Really?!

A huge increase of spawning areas for Snake River Fall Chinook, ranked near the top of NOAA's Priority Chinook Stock list for SRKW, would only yield "negligible to minor beneficial effects to SRKW". This stretches far beyond any rational argument imaginable.

This fatal flaw of the CRSO NEPA document was purposefully overlooked so that the Preferred Alternative could be selected. Otherwise -- if this had been a legitmate NEPA process -- Remove Lower Snake River Embankments would have been the core of the Preferred Alternative.

Prioritized list of Chinook salmon that are Important to SRKW NOAA Fisheries & WDFW

Federal Response: Thank you for your comment, the co-lead agencies concur with this comment.

bluefish counter response: Well that's a good thing, because these are direct excerpts from the CRSO Draft.

Federal Response:
Current and anticipated future fish and wildlife mitigation measures and operations are described under the No Action Alternative, Section 2.4.2.Many of the structural and operation measures are carried forward and proposed to be implemented or expanded under the Preferred Alternative (See Section 7.6). Funding of fish and wildlife mitigation actions and programs is described in Appendix Q, Section 6.1 and Table 6-1.

Additionally, Section 5.2.1 describes the existing mitigation programs under the No Action Alternative and provides a high-level summary of some of the accomplishments stemming from the significant Federal investment to date. Since the 1990s, the Federal agencies have overhauled system operations and infrastructure, achieving juvenile dam passage survival that meets or exceeds performance standards of 96% and 93% for spring and summer migrants respectively, a marked improvement as compared to when Congress passed the Act and the estimated average juvenile mortality at each mainstem dam and reservoir project was 15%-20% with losses recorded as high as 30%. Travel time improved for yearling Chinook and juvenile steelhead through the system, even in low flow years such as 2015, and total In-River survival has improved for migrating juvenile salmon and steelhead. Comparing two time periods reported in NOAAs reach study (1997-2007 and 2008-2016), there has been a 10% survival increase for hatchery and wild sockeye salmon, a 2% increase in hatchery and wild Chinook (4% for wild), and a 25% survival increase for hatchery and wild steelhead (13% for wild).

Regarding the statement in the Cost Appendix Q, the phrase "tens of millions of dollars" has been removed and replaced with updated language in the final EIS.

Federal Response:
For MO3, Chapter 3 incorrectly presented CSS SAR results as "LGR-LGR". These should be LGR-BON, and will be corrected in the final. As such, they are comparable across all the multiple objective alternatives and the No Action Alternative.

The model results presented in Sections 3.5 and 7.7.4 address latent mortality and reservoir mortality. Latent mortality is captured directly in the CSS model for SARs and abundances, and is overlaid with several assumed values (10%, 25% and 50% reductions in latent mortality) in the NMFS Life Cycle model results. Moreover, the value of latent mortality is uncertain. In fact, the Independent Scientific Advisory Board (ISAB) in their 2007 report stated, "The ISAB concludes that the hydrosystem causes some fish to experience latent mortality, but strongly advices against continuing to try to measure absolute latent mortality. Latent mortality relative to a damless reference is not measurable. Instead, the focus should be on the total mortality of in-river migrants and transported fish, which is the critical issue for recovery of listed salmonids. Efforts would be better expended on estimation of processes, such as in-river versus transport mortality that can be measured directly."

bluefish counter response:
In "Evaluating river management during seaward migration...", well regarded salmon biologists Schaller, Petrosky and Tinus address the Independent Science Advisory Board (ISAB) concerns quoted above.

Conclusion of "Evaluating river management during seaward migration..." Schaller et al.

In this paper, we extended previous studies to elaborate and further test the hypothesis (consistent with recommendations of the ISAB 2007) that increased delayed mortality in the Snake River Chinook salmon populations occurs as a consequence of outmigration through the hydropower system.

Abstract of "Evaluating river management during seaward migration..." Schaller et al.

Temporal analysis indicated that a high percentage (76%) of Snake River juvenile salmon that survived the FCRPS subsequently died in the marine environment as a result of their outmigration experience.

Under the Preferred Alternative, the inclusion of the adaptive management process would provide additional opportunities to further the effectiveness of the operation while maintaining the goals of the flexible spill operation:

• additional improvements for salmon and steelhead,
• maintain opportunities to operate the CRS for hydropower generation in a flexible manner that provides value to the Northwest,
• is implementable by the dam operators,
• and provides opportunity to reduce uncertainty and improve the learning opportunities around how operations of the CRS can influence the magnitude of latent mortality effects.

The Preferred Alternative will be implemented using a robust monitoring plan to help narrow the uncertainty between the two models and to determine how effective increased spill can be towards increasing salmon and steelhead returns to the Columbia Basin.

bluefish counter response:
Did the fed's "robust monitoring" notice the disastrous survival results of their first year's "Flex Spill experiment"?

Data source: NOAA Fisheries memo from Zabel to Graves (9/19/19), graphic by bluefish

BPA Administrator Elliot Mainzer was handed the above graph at our face-to-face meeting (Dec 2019), and the concern was raised again at our two subsequent web-based meetings (March and May 2020). Irregardless of this data, a second year of "Flex Spill experiment" with "robust monitoring" was implemented in 2020.