Columbia River System Operations
Comment & Response
of bluefish.org

Cover Letter
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Conservation
Coal
Carbon Sequestration
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Irrigation
Barging Wheat
Barging Salmon and Steelhead
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Survival of Salmon and Steelhead
Juvenile Survival through Hydrosystem
     Water Temperature
     Predation by Birds
Ocean Conditions
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Greenhouse Gases
An Adequate Power Supply
An Economic Power Supply
A Reliable Power Supply
An Efficient Power Supply
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Potatoes, Apples & Grapes
Petroleum to Pasco
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Orca and Idaho's Chinook
Flex Spill to 125% TDG
Breach Lower Snake River Embankments
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Social Effects
Cultural Resources
Environmental Justice
----------------------------
Conclusion

bluefish had 45 days to prepare the following comment                      

Orcas and Idaho's Chinook, comment by bluefish.org, response by CRSO.info
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 ESA-listed species survival and recovery, or adversely modify or destroy designated critical habitat. The ESA does not require the co-lead agencies to take affirmative actions to recover ESA-listed species as that is a broader goal with shared responsibility.

Based on the fish analysis in Section 7.7.4, the co-lead agencies anticipate that the Preferred Alternative would provide substantial benefits to ESA-listed anadromous fish 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 Columbia River System. Recovery efforts will need to continue to involve parties across the region that have an influence and impact on 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:
The co-lead agencies start by setting a low bar for themselves to clear: "Not required to take affirmative actions to recover ESA-listed species" the CRSO is satisfied by "not expecting to diminish the likelihood of recovery." As the reader will soon see, the CRSO fails even this low bar they have set for themselves.

Selecting the Flex Spill Experiment as the Preferred Alternative rests upon the following:

  • Hatchery production is "more that enough" compensation for impacts of the federal Columbia River System (CRS) hydrosystem, only it is not.

  • Combined, hatchery and wild Chinook returns to the Snake River, is better than in the 1960s, only that they are not.

  • The PA will increase SARs into the low range of recovery targets, only it does not.
While noticing these failings, consider an Alternative that has the highest likelihood of recovering Idaho's salmon and steelhead.

Remove Snake River Embankments has these qualities: Graphic: Recovery of Snake River Chinook would occur in ten years, according to projections from Fish Passage Center models assuming Average Ocean Conditions.

  • Greatly increases Smolt-to-Adult Ratio (SAR) of salmon and steelhead;

  • Increases the available spawning area for fall-run Chinook by 15 times;

  • Comparative Survival Study (CSS) model, with 1.0 SAR starting assumption, brings recovery in ten years (graphic at right);

  • With appropriate mitigations, electric power rates could come down;

  • With appropriate mitigations, irrigators continue to irrigate, possibly with no change in their costs if State of Washington were to assist;

  • With appropriate mitigations, wheat shipping moves to rail that parallels the Lower Snake River (LSR).

  • Recovery of Idaho's Chinook will provide substantial benefit to Southern Resident Killer Whale (SRKW).

With respect to the Preferred Alternative, the CSS model predicts that average Smolt to Adult return rates would increase for both Snake River spring Chinook and steelhead and will average above 2% (the lower end of the Northwest Power and Conservation Council's recovery targets for the region) as a result of the Preferred Alternative, increasing 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.

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. 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.

bluefish counter response:
Unfortunate for the CRSO respondents -- or for the Southern Resident Killer Whale (SRKW) depending on the outcome of all of this -- the Columbia River System Biological Opinion (CRS BiOp) inadvertantly reveals the fatal flaw of the self-contradictory NEPA document.

The argument rests squarely upon two primary pillars:

  • First, is that Snake River Chinook are doing fairly well; "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."

  • Second, is that population trends are nearly steady: Two adults returning to spawn from every two spawners a generation before, a 1:1 Adult-to-Adult Ratio is commensurate with a 2% Smolt-to-Adult Ratio (SAR).
The co-lead agencies have not diverted from this argument, justifying their "plan of action" over the years, for more than quarter of a century. This, in spite of a legal lashing and rebuke by Federal Judge Malcolm Marsh:
"NMFS also failed to articulate a rational connection between the facts, circumstances and myriad of factors contributing to the decline of the listed species and the choice of a standard by which to measure future success against. Instead, NMFS focussed on the system capabilities tending to the status quo rather than stabilization of the species.
. . .
"But the process is seriously, "significantly," flawed because it is too heavily geared towards a status quo that has allowed all forms of river activity to proceed in a deficit situation -- that is, relatively small steps, minor improvements and adjustments -- when the situation literally cries out for a major overhaul. Instead of looking for what can be done to protect the species from jeopardy, NMFS and the action agencies have narrowly focussed their attention on what the establishment is capable of handling with minimal disruption."

Graphic: Returns of natural-origin adult salmon and steelhead to uppermost Snake River dam (1962-2018).

Today, as we consider the CRS, we see that neither of these two pillars stand up to the facts of the matter:

  • Snake River salmon populations are worse than they were in the 1960s. Quite likely, they are at the lowest point of their twelve thousand plus years of existence in Idaho (see bluefish graph of Idaho Fish & Game data above, and Columbia Basin Research data combining hatchery and wild counts, below).

  • For Snake River, NMFS estimates for the Fall Chinook a 0.3% SAR, and for the Spring Chinook a 0.4% SAR. These are far, far below the low end of the range deemed necessary for recovery (2.0% SAR), which is a population that neither grows nor declines, just hangs on steadily where it is. (See table below, Jording estimates for U.S vs Oregon Feb. 23, 2018)

Estimate of Adult Chinook available to Southern Resident Killer Whales in coas waters based on hatchery production for CRS mitigation under the 2018 to 2027 U.S. v. Oregon Management Agreement. Source: Jording (2020).

The populations are dwindling, and a thirty-five percent improvement from 0.3% (to a 0.4% SAR), is not much of an improvement.

By holding to a strongly rebuked argument and ignoring solid facts, the co-lead agencies are thumbing their nose at the Federal Judges and Courts. With clearly no intention of creating a legitimate NEPA document, they unabashedly show us that they do not really give damn. The status quo remaining unshaken.

The population dynamics of the SRKW are complicated and there are multiple factors that contribute to the overall success of this species. The quantity and quality of prey is one of the limiting factors identified by NMFS in recovery of SRKWs, along with vessel traffic and noise, and toxic contaminants.

The operation of the Columbia River System 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 SRKWs. 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.

Graphic: Returns of adult Chinook  to uppermost Snake River dam (1962-2020).

NMFS maintains (to affirm in or as if in argument -- Merriam Webster) 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 (NOAA BiOp 2020).

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.

NMFS and 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 (NOAA 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. Southern Residents 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; SRKWs 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. There is no evidence that SRKWs feed or benefit differentially between wild and hatchery Chinook salmon. 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).

Egregious -- bluefish counter response:
Let's take a few CRSO excerpts one at a time:
  • "The quantity and quality of prey is one of the limiting factors"
    The suggestion is that vessel noise and envrionmental toxins are equal in importance.

  • "Numbers of adults from the Snake River Basin (including both hatchery and wild produced fish) are now greater than they were in the 1960s."
    Abundance of natural-origin Snake-River Chinook have never recovered to the levels of 1960s. In an effort to mitigate for this loss, hatchery production increased greatly in 2000, but overall Chinook populations are once again below the 1960s (see bluefish graphics above and below).

  • "SRKWs do not distinguish between or benefit differently from hatchery and wild fish"
    Hatchery fish are typically smaller than wild (or natural-origin) Chinook, and thereby provide less nutrition for the same energetic effort of catching a fish.

  • "Snake River spring/summer Chinook salmon is a small portion of SRKW overall diet"
    Not mentioning the Snake River Fall Chinook that rank five on the Chinook Priority Stock List, Snake River Spring Chinook rank nine. When these runs were higher, before construction of the federal hydrosystem, the consequent percentage of the SRKW diet would also be higher.

Details on the most crucial prey stocks for Southern Resident killer whales, as well as their population and range, is available from several fact sheets and videos available here. For more information, visit this NMFS Story Map on Southern Resident killer whales.


Orcas and Idaho's Chinook, comment by bluefish.org, response by CRSO.info
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-leads numerous legal obligations. The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3 which includes breaching the four lower Snake River dams. However, the Preferred Alternative also meets most other EIS objectives including those for resident fish, lamprey, hydropower generation, water management, and water supply, while minimizing adverse effects 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.

The co-lead agencies conclude there could be a minor beneficial effect to SRKW from implementing MO3. CSS and NMFS Lifecycle models predict that lower Snake River Chinook salmon smolt-to-adult returns 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).

Multiple Objective meets several objectives of the Columbia River System Operations (CRSO) as clearly stated in this excerpt from the CRSO Executive Summary bluefish counter response:
The CRSO is setting aside MO3, which has a moderate to major effect on salmon population, and instead chooses a "spill experiment" that "has negligible effects on SRKWs". Where is the rationale?

The first paragraph above, suggests that the Preferred Alternative is being selected because it meets more of the EIS objectives than MO3. How many of the eight EIS Objectives are met or could be met if appropriate mitigations were to occur? That is a good question. It is all important.

  • Multiple Objective 3 (MO3) and Preferred Alternative (PA) both Improve Juvenile Salmon (see image above);

  • MO3 and PA both Improve Adult Salmon (see image above);

  • MO3 and PA both Improve Resident Fish (see image above);

  • MO3 and PA both Improve Lamprey (see image above);

  • Provide a Reliable and Economic Power Supply;
    Executive Summary (page 30)
    Under MO3, hydropower generation would decrease by 1,100 aMW (about 1,000 aMW from breaching the four lower Snake River dams) under average water conditions, and 730 aMW under low water conditions compared to the No Action Alternative.
    . . .
    A "conventional" Resource Replacement Portfolio "includes 1,120 megawatts (MW) of combined cycle natural gas turbines at an overall cost of about $250 million a year. (See An Economic Power Supply for discussion of appropriate mitigation and (730 MW / 1,120 MW = 65% of) MO3 cost effects.)

  • Minimize GHG Emissions;
    Executive Summary (page 31)
    MO3 would also not meet the objective to Minimize GHG Emissions. ... GHG emissions would increase the most if the hydropower were replaced with natural gas. This would lead to an additional 3.3 million metric tons (MMT) of CO2, a 9% increase in power-related emissions across the Northwest (See Carbon Sequestration)
    . . .
    In the future, technical advances in storage and other low-carbon options may become increasingly viable to help integrate variable renewable generation. With the expanded portfolio that is intended as a full replacement of the capabilities of the lost generation from the lower Snake River dams, the GHG emissions impact would probably be lower.

  • MO3 would meet the objective to Maximize Adaptable Water Management (Executive Summary, page 32);

  • MO3 and PA both Provide Water Supply; Measures implemented under MO3 could have major beneficial effects in Regions A and B and minor effects in Region D due to sediment accumulation near the pumps near McNary Dam.

    MO3 could affect delivery of current water supply in Region C, which would result in major effects to the Ice Harbor private, municipal, and industrial pumps located near Ice Harbor dam (see Irrigation).

    Water supply engineer Rod Sampson estimates that continuing irrigation from Ice Harbor pool will cost approximately $20 million.

Those are the eight stated Objectives of the EIS.
Strangely, the CRSO respondents suggest, incorrectly, that "minimizing adverse effects to communities and to the economy" and "hydropower" are stated Objectives of the EIS.

Of the eight EIS Objectives, how many are met, or could be met if appropriate mitigations were to occur? That is a good question. It is all important.

Federal Response (from opening paragraph above):
The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3 which includes breaching the four lower Snake River dams.

According to NMFS and the EPA, the estimated SRKW population has fluctuated between 67 and 98 whales between 1960 and 2015. The Snake River dams were constructed between 1962 and 1975. The SRKW population increased from a record low in 1970 to its highest population numbers in 1995. Those years were not high years for Snake or Columbia River Chinook Salmon. Ocean conditions between 2011 and 2013 were good years for salmon. At the same time, 2010 and 2013 were good outmigration years. Particularly, 2011 and 2012 were above normal in water supply, which would mean more cooler water was available and there was better survival of salmon, and 2011 through 2014 were higher than normal spill years as well. The combination of outmigration and ocean conditions created improved adult salmon returns.

The EIS has analyzed spill as a measure in the Preferred Alternative and determined the overall effect to SRKW to be negligible, in large part because hatchery production is consistent between the No Action Alternative and the Preferred Alternative.

bluefish counter response:
For endangered SRKW, the overall effect of the Preferred Alternative will be negligible. Well said.

Because the impact from the Preferred Alternative was determined to be negligible, the agencies determined that existing hatchery production would be sufficient to address any potential impacts to prey availability for SRKWs. The co-lead agencies note the contribution to the prey of SRKW through the continued existence of their respective independent Congressionally authorized hatchery mitigation responsibilities, including, but not limited to, Grand Coulee mitigation, John Day mitigation and programs funded and administered by other entities, such as the Lower Snake River Compensation Plan (other than under MO3), which is administered by USFWS.

The Preferred Alternative and Proposed Action in the agencies' biological assessment carry forward certain mitigation measures described in Chapters 2 and 7 of the EIS, which include continued salmon and steelhead hatchery production. The Preferred Alternative has negligible effects to SRKWs as described in Section 7.7.8.

bluefish counter response:
Starting with the CRS BiOp estimate of 0.4% SAR for spring-run Chinook (Table 2.16-1 above); of one thousand spring-run Chinook leaving Idaho, four return as a adults to spawn. From those four, less than 500 juvenile smolts will leave Idaho. The next generation sends less than 250 to the ocean. You can see where this is heading. The SAR ratio is not the cause of this, it is merely a measure of the rate of decline.

Decline is the state that Snake River salmon and steelhead are within. If we have not already waited too long to act, Remove Snake River Embankments can reverse this downward course. The populations could once again build, and then soon thrive. It only takes our collective decision to do so.

Why are we waiting? That's a very good question to ask.

The final EIS in Vegetation, Wetlands, Wildlife,and Floodplains (Section 3..6.2.6 and Table 3-102), and Chapter 7 (Preferred Alternative), has been updated with additional analysis information on SRKW and the potential increase in forage fish, in particular, Chinook salmon (Section 7.7.8). Moreover, NMFS concluded in its 2020 CRS BiOp that operations, maintenance and configuration of the CRS is not likely to adversely affect SRKW.

bluefish counter response:
Restated, NMFS concluded that the EIS, will have negligible effect on the starving SRKW.

Cheer up, things cannot get much worse, as we are asked to be appeased; "The configuration of the CRS, is not likely to adversely effect the SRKW." But removing four reservoirs, will increase Snake River spawning areas by fifteen times!

Good-bye Shamu. Thanks for all the fish.

Orcas and Idaho's Chinook, comment by bluefish.org, response by CRSO.info

Federal Response:
The Biological Assessment (BA) describes the effect of the Proposed Action on the SRKW forage species (see BA Section 3.5.1.2, Southern Resident Killer Whale). The proposed changes in operation of the Columbia River System include increased spring spill during the downstream migration of juvenile spring and summer run Chinook salmon. The result of this action includes potential increases of juvenile fish passing through the spillways, reductions in juvenile fish direct and indirect mortality associated with downstream passage, and the Comparative Survival Study (CSS) model predicts increases in numbers of returning adults, which will benefit SRKWs foraging in and around the mouth of the Columbia River in winter and spring (See EIS Section 7.7.8).

The CSS model results predicts Snake River Chinook salmon would have relative improvements in smolt-to-adult returns of 35 percent (see EIS Section 7.7.4). The smolt-to-adult return ratio (SAR) is the rate at which of a group of fish survive from their smolt life stage to a defined ending point where they return as adults. While recovery targets will require more than just the efforts of federal agencies, the CSS models indicate the potential for SARs of Snake River Chinook salmon and steelhead to increase to levels that could approach recovery targets set by the Northwest Power and Conservation Council.

bluefish counter response:
FALSE. The numbers of returning adults only increasess when SARs are averaging above 2.0%.

The CRS BiOp estimates a 0.4% SAR for Spring Chinook, and a 0.3% SAR for Fall Chinook. The CRSO NEPA document, in discussion of the CSS model, begins with a 2% SAR, and it is with that starting assumption, that allows them to claim, falsely, that the "model predicts increases in numbers of returning adults".

Estimate of Adult Chinook available to Southern Resident Killer Whales in coas waters based on hatchery production for CRS mitigation under the 2018 to 2027 U.S. v. Oregon Management Agreement. Source: Jording (2020).

The BA, also consistent with the EIS, acknowledges past improvements to the configuration and operation of the Columbia River System, additional improvements to the environmental baseline as a result of completed estuary and tributary habitat actions, and the prospective non-operational conservation measures proposed in Chapter 2 of the Draft EIS, all contribute towards maintaining and improving Chinook abundance.

Relevant conservation measures include, among other things, a commitment to continue funding the conservation and safety net hatchery programs listed in Chapter 2 of the Draft EIS. As discussed above, the agencies will fulfill congressionally authorized hatchery mitigation objectives through the funding of hatchery programs that are operated consistent with their independent hatchery program consultations during the term covered by this consultation. Based on those hatchery program consultations, the production levels associated with congressionally authorized hatchery mitigation objectives will continue, at minimum, to be consistent with levels previously analyzed by NOAA in the system consultations in 2008, 2014, and 2019.

For the 2020 ESA consultations, therefore, the agencies expect that collectively, all of the actions described above (substantial modifications to migration conditions designed to benefit key prey species, combined with improvements to Chinook spawning and rearing habitat in the tributaries and Columbia River estuary, and continued hatchery production) ensure that remaining Chinook mortality from all sources in the mainstem migratory corridor will continue to be more than offset, resulting in a net gain in Chinook salmon abundance available as a prey source for SRKW.

Finally, the 2019 NMFS Fisheries BiOp included increased spring spill operations that are similar to operations evaluated in CRSO EIS, and NOAA validated that the hatchery production of Chinook salmon mitigates for the impacts of operating the Columbia River System and total mortality through the mainstem migratory corridor from all sources.

bluefish counter response:
Did you notice that NOAA did not mention the loss of Fall Chinook spawning habitat, inundated due to the existence of, the configuration of, the LSR dams?
"NOAA validated that the hatchery production of Chinook salmon mitigates for the impacts of operating the Columbia River System."

Elsewhere, we learn that Remove Snake River Embankments would increase by 15 times the available spawning habitat for Snake River Fall Chinook. Implementing this hotly debated Alternative, would bring about the de-listing of Fall Chinook.

Would not the SRKW receive major beneficial effects when Fall Chinook, a top five priority Chinook stock, are once again flourishing?

Orcas and Idaho's Chinook, comment by bluefish.org, response by CRSO.info

Federal Response:
SRKW analysis is described in the EIS including in the FEIS Chapter 3 (Vegetation, Wetlands, Wildlife, and Floodplains) which has been updated for SRKW (Section 3.6.2.6 and Table 3-102) and FEIS Chapter 7 (Preferred Alternative) with additional analysis information on SRKW and potential increase in forage fish, in particular, Chinook salmon in Section 7.7.8. The co-lead agencies utilized current high quality information and best available science in its analysis of the effects of the operation, maintenance, and configuration of the CRS projects.
bluefish counter response:
Ranking high on NMFS Priority Chinook Stock list for critically endangered SRKW, the recovery of Fall Chinook would have a major effect. That would be a reasonable estimattion, but the CRSO EIS posits a minimal effect from MO3, (better than the negligible effect from their Preferred Alternative).
Chapter 3, Multiple Objective 3
"Breaching the four lower Snake River Dams is estimated to increase the available spawning habitat for fall-run Chinook from 226 acres to 3,521 acres, an increase of 15 times the area available today."
In no way, does the production of hatchery salmon compensate for the "configuration" of the Columbia River System. Fact: Remove Snake River Embankments increases spawning habitat for fall-run Chinook by 15 times.

The CRSO NEPA document chooses to downplay this reality. Let the SRKW be damned to extinction.

Let's go ahead and assume populations are fine as they are, allowing us pleny of time to tinker around. Experiment with "Flex Spill", a mixed-variable evaluation will take years, maybe decades, to find meaning. Just gives us time, we got this. Does this sound familiar?

Quite apparently, the co-lead agencies feel no obligation, moral or legal, to meet their own low bar of not "diminishing the likelihood of recovery" of the starving Southern Resident Orcas. Their aim, is merely to obfuscate their shameful stance.


"I think we need to take those dams down. Trying to take out a dam is not, not very difficult. It's a lot easier than it is putting them up. You don't just take the whole thing down, you just let the water go around it. You just dig out the ditch and let it go around."

-- Federal Judge James Redden, Outdoor Idaho Interview, 2012
Struck the 2000 BiOp, and the 2004 BiOp, and the 2008/2011 BiOp

Orcas and Idaho's Chinook, comment by bluefish.org, response by CRSO.info

Federal Response:
The co-lead agencies recognize that data is being developed and refined in an ongoing manner. The agencies believe that the Priority Stock List is current high quality information and best available science as utilized in the CRSO EIS analysis, recognizing the caveats and assumptions made in the compilation of that list.
  • NMFS and other regional experts are collaborating with scientists to answer the unknowns, fill in the gaps in data, and lowering the assumptions regarding SRKW diet.

  • Currently, current high quality information and best available science indicates that the diet of the SRKWs includes a variety of food sources based on the most available runs.

  • The co-lead agencies agree that the quantity, quality and timing of prey availability is important in health of SRKWs.

  • 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.

  • NMFS and 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 whales (NOAA 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.
    Southern Residents 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; SRKWs 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).

  • There is no evidence that SRKWs feed or benefit differentially between wild and hatchery Chinook salmon.

  • The co-lead agencies agree that the quantity and quality of prey is one of the limiting factors identified by NMFS in recovery of SRKWs, along with vessel traffic and noise, and toxic contaminants.

Priority Chinook Stocks for the starving, critically endangered Southern Resident Killer Whale, aka. Orcas.

The operation of the Columbia River System 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 SRKWs. However, according to NMFS, in terms of the overall abundance of Chinook salmon available to SRKW for prey, numbers of adults form 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 differentially from hatchery and wild fish. Hatchery fish today likely make up the majority of fish consumed by SRKW (NOAA BiOp 2020).

bluefish counter response:
A hole-ridden Environmental Impact Statement (EIS) and NMFS' agreeable Biological Opinion (BiOP), tells us that "the configuration of the CRS is not likely to adversely affect SRKW",

The same NMFS agency that has been in court for a quarter century, with their past five Biological Opinions thrown back by the Federal Court, is on track to make this one their sixth. Should we trust them?

Six times now and the story line remains the same: Populations are doing pretty good, and trending declines are slight, so give us some time, we are trying some things.

Are the co-lead agencies and the complicit NOAA worthy of our trust? We have read this book before, why are we buying their same old story? The song remains the same.


"NMFS also failed to articulate a rational connection between the facts, circumstances and myriad of factors contributing to the decline of the listed species and the choice of a standard by which to measure future success against. Instead, NMFS focussed on the system capabilities tending to the status quo rather than stabilization of the species.
. . .
"But the process is seriously, "significantly," flawed because it is too heavily geared towards a status quo that has allowed all forms of river activity to proceed in a deficit situation -- that is, relatively small steps, minor improvements and adjustments -- when the situation literally cries out for a major overhaul. Instead of looking for what can be done to protect the species from jeopardy, NMFS and the action agencies have narrowly focussed their attention on what the establishment is capable of handling with minimal disruption."