Failing to act decisively has long plagued this issue. Barry Espenson writes in Feds Offer Their "Four H" Approach (November 1999)

Because the biological and economic analysis of the study alternatives is producing a number of close calls, the Corps will withhold judgment in a draft study and EIS scheduled for release Dec. 17.

The draft "will not have a preferred alternative," said Col. Eric Mogren, the Corps divisional deputy commander. A final version is expected to be completed in May following a winter of public meetings. The study focuses on three hydrosystem alternatives for improving passage -- the status quo, breaching or major system improvements.

Consistency with Planned Regional Salmon Recovery Efforts -- FR/EIS Summary (February 2002)

Of all the alternatives investigated in the FR/EIS, the recommended plan (preferred alternative) most closely matches recommendations in the NMFS 2000 Biological Opinion for the Lower Snake River Project. The NMFS 2000 Biological Opinion concluded that dam breaching on the lower Snake River is not necessary at this time, but reserved this action as a contingency management alternative if the listed stocks continue to decline in the near future.
. . .
In implementing the Biological Opinions' lower Snake River actions, the Corps will also contribute to the attainment of the goals identified in the dated December 2000. This strategy was developed by several Federal agencies (including the Corps) as part of the Federal Caucus. It is a comprehensive, long-term plan to recover 12 anadromous fish stocks and other listed species (i.e., bull trout and sturgeon) in the Columbia-Snake River Basin.

Comparison with Other Alternatives -- FR/EIS Summary (February 2002)

Although Alternative 4--Dam Breaching had a number of positive benefits, it was ranked lower than the recommended plan (preferred alternative) for the following reasons:

• Determination that breaching is not necessary at this time to recover listed salmon and steelhead stocks (breaching has not been determined necessary at this time by the NMFS 2000 Biological Opinion),

• Maximum negative economic impacts to current system users (i.e., loss of power, navigation, and irrigation),

• High sediment movement in the short term,

• Uncertainty of possible harmful effects associated with the potential resuspension of contaminants in sediments,

• High degree of uncertainty in the implementation (will Congress allow it to happen?) and longest period before positive benefits to listed stocks,

• Most negative impact to low-income and minority populations
  (bluefish notes: This avoidable effect is due to the 2002 FR/EIS finding that irrigated farmland would be too costly to mitigate, and farmworkers would suffer a loss.)

3.7.1 Performance Standards -- Conservation of Columbia Basin Fish (December 2000)

The ultimate performance standard for the federal hydropower system is survival of juvenile and adult fish through the migration corridor. A survival performance standard must also take into account indirect mortality fish may suffer after leaving the migration corridor as a result of their passage experience. The Strategy establishes survival standards through the hydropower system that the Caucus agencies believe are achievable with the present system in place. Because not all mortality associated with the system can be eliminated, the Strategy also establishes expectations for off-site mitigation.

(bluefish notes: Survival of juvenile salmon did not become a performance standard of their Final FR/EIS although that possiblity was alluded to in the Response to Comments)

Comment: NMFS data suggest juvenile survival in-river is improving. Do we still need to consider removing dams?

Response: Juvenile salmon in-river continues to be evaluated through multiple programs such as tagging studies, survival estimates, and modeling. The NMFS 2000 FCRPS Biological Opinion, which is being reviewed by the Corps, BPA, and BOR, establishes performance standards and a timeline for potential dam removal. If the standards are not met, plans for breaching may proceed.

Response to Comments -- Appendix U - FR/EIS (February 2002)
The Corps identified 37 general issues as the 230,000 comment documents and 15 transcripts were read and evaluated.

Comment - 3 This study is all part of a dam removal master plan.

• Environmentalists are trying to remove all dams; this is just the beginning.
• Why would we remove these four dams, which have fish ladders, and not Hells Canyon, Grand Coulee, Dworshak, or others?
• Easterners and urbanites have something against rural living and removing the dams would make rural life more difficult in Eastern Washington.

  Response: This study grew out of the National Marine Fisheries Service (NMFS) 1995 and 1998 Biological Opinions (NMFS, 1995; 1998), which requested that the Corps investigate ways to improve juvenile salmon migration through the four lower Snake River dams. The scope of the study is limited to these dams and issues. It should be noted that dam breaching is only one of four options being evaluated to address salmon passage issues in this Feasibility Study. There is no Federal master plan to remove other dams on the Snake or Columbia Rivers, although dam breaching is a common component of any regional discussion on salmon recovery.

Comment - 4 Breach dams now. Delays spell disaster for salmon and the environment.

Response: While we understand the urgency of the situation, decision makers need sound science on which to base decisions. It takes time to develop and confirm such complicated analyses. All the issues are very complicated. We need to develop and analyze the best available technical information. This takes time and money. This is such a complicated regional issue that not only does it take time to produce and review sound analyses, but it also takes extensive time for input from all stakeholders. If input was not received and reviewed, then the decision would be made without considering the full impact of Federal actions. The intent of Congress and the laws that direct Federal actions is to involve all those who would be affected and consider all information provided. Within these goals, we are working to conclude this process and produce a Record of Decision leading to implementation of an alternative as soon as possible.

Also, NMFS, through the Cumulative Risk Initiative (CRI), has identified risks of extinction and the timeline during which actions must be taken to prevent extinction. NMFS has published the 2000 FCRPS Biological Opinion (NMFS, 2000a), which sets out a series of actions within the Pacific Northwest that are intended to prevent extinction and lead to recovery. It should also be noted that Alternative 4--Dam Breaching by itself has been determined not to be the solution to recovery.

(bluefish notes: This is due to the model's assumption that Delayed Mortality is 0%, i.e. that if the juvenile salmonid doesn't die above Bonneville Dam, then it is unaffected by the journey. Preposterous, but that was the assumption made.)

Comment - 5 Don't Breach dams now.

• Non-breaching alternatives are more prudent, less drastic choices.
• More studies are needed to resolve uncertainties.
• Try everything else before implementing dam breaching.
• Take more time to evaluate the existing system.
• Dam breaching could not reasonably be implemented.
• You can't "turn back time." The ecosystem is no longer natural.

  Response: In their 2000 Biological Opinion, NMFS determined that dam breaching alone would not be enough to recover salmon. They also recommended that the region undertake additional monitoring and studies to resolve key uncertainties regarding sources of delayed and extra mortality. The Biological Opinion outlined several major system improvements and changes to implement to try to improve salmon survival and recovery. If these measures do not result in the desired improvement, dam breaching will be reevaluated in 5 years.

Comment - 8 If the dams were removed, there would be flood control problems.

• Dams help control spring flooding.
• Dams prevented serious flooding in Portland a few years ago.
• There would be flooding in the Tri-Cities if the dams were removed.
• If the Snake River dams were removed, would you remove the Columbia River dams too and disable all our flood protection?

  Response: As is explained in the FR/EIS and associated documents, flood control is not an authorized purpose of the Lower Snake River Project. These are run-of-the-river dams/reservoirs that do not provide flood control because they do not have storage capacity. Whatever water volume enters this reach above Lower Granite Dam leaves within a very short period at essentially the same flow volume. Other dams on the Snake and Columbia River are authorized for flood control purposes. There are no studies evaluating the removal of any dams authorized for flood control in the Columbia-Snake River System.

Comment - 9 Sediment from behind the dams would cause problems.

• Breaching would release lots of sediment into the river.
• The heavy sediment load would hurt all fish, aquatic life, and wildlife downstream.
• Low water with heavy sediment would just make for a warm, muddy, shallow river.
• Breaching would allow heavy metals in silt behind dams to escape downriver.

  Response: The Corps has evaluated the potential impacts of the sediment on each of the resources evaluated in the FR/EIS. Although the exact outcome is difficult to predict because there are no relevant examples to examine, the Corps believes the FR/EIS provides a sufficient impact analysis.

  ---

  The EFFECTS Sediment -- FR/EIS Summary (February 2002)

  Alternative 4--Dam Breaching
  Dam breaching could result in significant movement of sediments. It is estimated that 50 to 75 million cubic yards of existing sediments may be eroded and moved downstream. The majority of fine-grain silts would move quickly in the first few years following breaching. The coarser sands would move slowly downstream over 5 to 10 years. These existing and future sediments could move freely downstream toward McNary Dam and may cause temporary adverse effects on food supplies for fish and bottom-feeding aquatic organisms. In addition, silt and sand now accumulated behind the dams could cause damage to pumps, valves, and other water system components.

  Resuspension of sediments following dam breaching could result in exposing chemical contaminants that have been contained in reservoir sedimentation. Total DDT, dioxin, manganese, and un-ionized ammonia are of concern. DDT could potentially affect the biological system, and un-ionized ammonia concentrations may exceed EPA water quality criteria for the protection of aquatic life.

Comment - 12 Dam breaching is not necessary to recover the four lower Snake River stocks.

• Dam removal is not necessary because juvenile fish transportation on barges works great.

  Response: There are many factors that affect the effectiveness of transport (NMFS transportation white paper [NMFS, 1999a]) making the benefits far from assured. The most obvious concern is what is known as "differential delayed transport mortality," which is measured relative to nontransported fish as a function known as "D." This factor is simply the ratio of adult survival of transported fish to untransported fish. The net result based on many studies is that there appears to be additional mortality that occurs to transported fish that does not occur to untransported fish once they arrive below Bonneville Dam. The effect is not clear at this time, but it may result in little net overall increase in survival to adult stages between transported and untransported fish.

  

  
  

• If survival is as high now as before the dams were built, there is no sense in returning to pre-dam conditions.

  Response: NMFS has determined that the lower Snake River Evolutionary Significant Units (ESUs) identified are at risk for extinction. They have prescribed measures to help encourage survival and recovery of these species.

• How would breaching help if 34 runs of salmon/steelhead listed or proposed for ESA, but only four pass lower Snake River dams?

  Response: The focus of this Feasibility Study is improving survival of the four listed Snake River species by making changes to juvenile salmon passage. Dam breaching is one alternative the Corps is evaluating to help these species. Other regional efforts are ongoing to determine a broad range of measures to improve survival and recovery of all listed species in the Columbia-Snake River Basin.

• Fish survival through each dam is higher than in the 60s. New technology will increase smolt survival even more, so why breach?

  Response: We are not recommending dam breaching at this time. However, the four lower Snake River stocks are still at risk and measures must be taken to improve their survival and recovery prospects. In their 2000 Biological Opinion, NMFS determined that dam breaching alone would not be enough to recover all salmon stocks on the lower Snake River (NMFS, 2000a). They also recommended that the region undertake additional monitoring and studies to resolve key uncertainties regarding sources of delayed and extra mortality. The Biological Opinion outlined several major system improvements and changes to implement to try to improve salmon survival and recovery. If these measures do not result in the desired improvement, dam breaching and other options will be evaluated in 5 years.

• If 94 percent of juvenile salmon pass the dams, the dams must not be the problem.

  Response: Extensive analyses (Plan for Analyzing and Testing Hypotheses [PATH], CRI) show that while dams are not all of the problem facing the four listed lower Snake River species, they are part of the problem. While other regional efforts are looking at a broad range of measures other than hydropower changes (habitat, hatcheries, harvest) that could improve survival and recovery efforts for listed species, the point of this Feasibility Study is to identify and evaluate alternatives for improving passage of juvenile salmon at the four lower Snake River dams. It should be noted that the percentage you quote is misleading. A certain percentage of juvenile salmon are lost in passage at each dam from the Snake River through the Columbia to the ocean. Cumulative losses are greater than your statistic indicates (e.g., 41 to 58 percent passage mortality of in-river migrating Snake River spring/summer chinook during 1995 to 1999 from Lower Granite Pool to Bonneville Dam tailrace). Also, there is the issue of delayed mortality and extra mortality--lower Snake River salmon adults do not return at a rate comparable to other races. Regional scientists involved in PATH and CRI believe that a certain percentage of this "extra mortality" is somehow related to "delayed mortality" from the hydropower system. What percentage is uncertain and is a major issue of debate in evaluation of the effect of the alternatives on anadromous fish. Please note that, in line with NMFS' recommendation in their 2000 FCRPS Biological Opinion (NMFS, 2000a), we are not recommending dam breaching at this time (see above).

Comment - 13 Removing the dams won't help Snake River salmon.

• The four lower Snake River dams can't be the cause of low fish returns because salmon runs are also declining on rivers and streams where there are no dams.

  Response: See response to comment GI-12.

• The fish would still have all the other dams to pass.

  Response: See response to comment GI-12.

• Breaching wouldn't open up that much spawning habitat.

  Response: The pre-dam channel of the lower Snake River was a coarse-bedded, stable river, possessing over 30 large rifle-rapid sections interconnected with large pools. These characteristics supported fall chinook salmon spawning and rearing. The 140 miles of the lower Snake River historically contained between 2.5 to 5 percent of the available Snake River spawning habitat prior to complete construction of the Hells Canyon dam complex in the 1960s. Three different modeling exercises using channel reconstruction with flow methodology indicate that the location and amount of fall chinook spawning habitat could be 23.5 up to 54.9 percent of the 140 miles of river if dam breaching occurred.

Comment - 16 Don't impose any more restrictions on harvest.

• Many commercial fishermen feel that restricted harvest would be a hardship for them.
• Many people downriver in coastal towns and in Alaska noted that fishing is integral to their survival.
• Many sports and commercial fishermen feel that further restricting harvest would not help salmon that much since not that many are harvested currently.
• The Pacific Salmon Treaty already provides adequate harvest restrictions.

  Response: Restricted harvest and other measures designed to reduce potential harvest-related impacts to salmon and steelhead are outside the scope of the Corps' Feasibility Study. We forwarded all comments regarding harvest to NMFS, and they are working with the region to begin to address these issues in a fair and equitable manner.

Comment - 17 The dams aren't the problem, predators are the problem.

• Do something about the terns on Rice Island at the mouth of the Columbia that eat a significant amount of salmon before you breach the dams.
• Do something about the sea lions and seals that eat a significant amount of salmon before you breach the dams.
• Do something about resident fish who prey on juvenile salmon in the reservoirs.

  Response: Predation management is an important variable in salmon recovery, and can not be addressed by the Corps alone. It needs to be managed by States and other Federal agencies. While predation does have effects on survival, much of the predation that occurs in the lower Snake River under current conditions would occur naturally. Stocks should be able to survive with some level of predation. Actions to address some of the major predators are underway, although some sources of smolt loss will remain.

  In terms of accounting for predation in the analysis, Appendix A, Anadromous Fish Modeling (and condensed FR/EIS discussions) includes discussion of predation rates and the PATH models included predation as a mortality source for chinook salmon. Unfortunately, although there is a great deal of data on diet, energy budget, and distribution of predators, rigorous translations of these data into rates of mortality for individual salmon races are lacking.

Comment - 18 The dams aren't the problem, habitat changes are the problem.

• Ocean, climate, and El Nino produce unfavorable conditions for salmon.

  Response: Ocean conditions are obviously a major factor affecting anadromous salmonid population growth rates. In addition, it is likely that ocean conditions have differential effects on the several ESUs in the Columbia River Basin. Snake River fall chinook, for instance, apparently have a different ocean residence than Hanford reach chinook. Many ocean conditions do signal a change in the Pacific Decadal Oscillation (PDO) in recent months. However, since Columbia River salmonids have been declining since the 1870s, ocean conditions cannot be held solely responsible for Snake River stock declines. In addition, the mechanism of the oceanic effect on salmon populations is unknown, making predictions of the effect of climatic changes on salmon populations problematic. Moreover, our power of prediction of the duration of these ocean cycles is poor. Finally, there are indications that El Nino/Southern Oscillation (ENSO) events affect salmon populations more strongly than the PDO. Most models of global climate change predict increasing frequency and duration of ENSO events.

• Poor estuarine and riverine habitat conditions are contributing to declining salmon populations.

  Response: NMFS addresses the needs for improvement in both early rearing and estuary conditions in their 2000 FCRPS Biological Opinion. Affecting conditions outside of the Snake River region is outside of the scope of the FR/EIS.

Comment - 19 There is no difference between wild and hatchery salmon.

• They all come from the same genetic stock--what's the difference?
• Scientists should include hatchery fish in counts; returning fish that spawn outside the hatchery should be considered wild.

  Response: These comments address the apparent discrepancy in treatment of wild and hatchery fish. Under the direction of the ESA, NMFS is required to consider recovered stocks as selfsustaining (i.e., if hatchery inputs were removed from the ecosystem, a stable population growth rate would result). Therefore, it is important that we assess the status of the wild component of the population (which can be both masked and affected by hatchery fish). Although the addition of hatchery fish may increase the numbers of fish in the rivers, this input does nothing to change the system to allow a wild population to reverse a declining trend. In fact, there are many reasons to believe that the addition of hatchery fish may actually harm wild populations.

Comment - 20 You can buy salmon at the store, so what's the problem?

Response: Although it is nearly impossible to selectively prevent the harvest of some endangered species because the physical differences between the stocks often aren't easily distinguishable, catch is controlled somewhat by the timing of different fishing seasons. Most often, the salmon you buy in the grocery store is not from an endangered ESU like the Snake River salmon and steelhead; they are either hatchery fish or wild fish that have more sustained populations.

Comment - 21 Try other methods of dam modification/fish passage.

• Construct a free-flowing side channel that fish can use to bypass the dams.
• Construct a system of pipes filled with water for fish to use to bypass the dams.
• Place nets upstream and downstream of the dams to catch fish and guide them to safe passage.
• Install strobe lights on the dams to help guide the fish.

  Response: Past studies of dams on the Columbia-Snake River System and exhaustive analyses written up in the FR/EIS and Appendix D, Major Systems Improvements evaluated many alternative methods of dam modification and fish passage, some of which are still in research, development, and testing stages. The major system improvements carried forward in Alternative 3 of the FR/EIS are considered to be the most effective and practical technologies we can implement as soon as possible. They mirror the measures recommended by NMFS in their 1995, 1998, and 2000 Biological Opinions.

Comment - 23 The Corps must breach dams and recover salmon species to meet obligations to the tribes. Tribes are harmed by declining salmon populations, and significant compensation for losses could be due.

Response: The Corps has taken into account the Northwest Treaty Tribes' fishing rights, the United States' Trust responsibility to Native American Tribes and its responsibility to act in a manner consistent with the trust responsibility. The actions which the Corps will implement are designed to lead to increased survival and recovery of the listed salmon species with beneficial results to the Treaty Tribes' fishery and benefits to the Northwest Region as a whole.

Comment - 24 If the dams were removed, there would be safety, maintenance, and volume issues for Northwest roads and railroads.

• The current roads aren't adequate. There would have to be major road construction.
• The roads wouldn't be safe to drive.
• The rail system wouldn't be adequate.

  Response: These concerns are addressed in Section 5.8 of the FR/EIS and Section 3.3 of Appendix I, Economics. Further discussion is provided in the Drawdown Regional Economic Workgroup (DREW) Transportation Workgroup report, which is available on the Corps website. A number of studies have also been conducted by other regional agencies. Summaries of these findings are also included in the FR/EIS, as appropriate.

Comment - 25 The transportation analysis was incorrect/incomplete.

• If the dams were removed, a lot of small companies would go out of business because it would be more difficult/expensive to move commodities
• The FR/EIS erroneously assumes 5 million tons of formerly barged commerce would continue to move to domestic and international markets. However, increased shipping costs would eliminate products' ability to stay competitive in these markets.

  Response: This assumption was employed in the DREW transportation analysis (see Section 5.8 of the FR/EIS).

• Rail rates would not increase if barging was removed as a competing form of transportation.

  Response: The DREW Transportation group disagreed. Some increase in rail rates would be expected if barging on the lower Snake River was eliminated as a means of moving commodities. Please refer to the sources cited above for a more detailed explanation.

• The current river transportation system does not make sense.

  Response: Comment noted.

Comment - 26 If the dams were removed, there would be power supply problems.

• According to the Regional Power Supply Adequacy and Reliability report by the Northwest Power Planning Council (NPPC), there is a serious threat of power shortages in the area, even brownouts, if the amount of power is not increased. This means that reducing the power supply by 5 percent with dam breaching would result in a more serious shortage.
• Our population growth in the Northwest is endangering the power supply.

  Response: The NPPC report cited identifies new additions required by 2003 to support the project population. The hydropower analysis conducted by DREW Hydropower Impact Team (HIT) recognizes that additional capacity will be required to meet load growth over time and assumes that these additions will be made, as necessary. Capacity additions required for 2010 and 2018 are shown in Table 25 of the DREW HIT report. These additions will be required regardless of whether or not dam breaching occurs. The hydropower analysis prepared for the FR/EIS addresses only the impacts associated with breaching the four lower Snake River dams. The effects of this action on the reliability of the transmission system are discussed in Section 3.1.6.3 of Appendix I, Economics.

• We should keep the dams because hydropower is a cheap, clean, renewable energy source.

  Response: Comment noted.

Comment - 27 Removing the four dams would not endanger the power supply.

• We just need to stop selling off so much power and there will be plenty to go around.
• We should encourage the conservation of power.
• We could buy from other sources.
• We should encourage the development of alternative, clean, renewable power sources.

  Response: A new section has been added to Appendix I, Economics that addresses conservation as an alternative source of replacement power. The conclusions of this new section have also been incorporated into Section 5.9 of the FR/EIS.

Comment - 28 If the dams were removed, it would affect water supply.

• If the dams were removed, the loss of irrigated acres would be 36,000 in Washington and 450,000 in Idaho (no source given).
• It would really be expensive/difficult for farmers (particularly small ones) to find other ways to irrigate if the dams are breached.
• Municipal and industrial water supply pumps would be expensive/difficult to replace.
• If the dams were breached, would the government help bear the cost of creating access to other water sources?

  Response: These issues are all addressed in the analysis presented in Section 3.4 of Appendix I, Economics; in Annex O to Appendix D; and in Section 5.10 of the FR/EIS.

Comment - 29 Changes to water supply due to dam breaching would not affect very many people.

• Only 13 farms are irrigated by Ice Harbor Dam.
• Only 13 pumps providing irrigation water from Ice Harbor Dam would be affected.
• Affected farms could get their water pumped from somewhere else.

  Response: The scope and significance of the effects of the alternatives on water supply are addressed in the analysis presented in Sections 3.3 and 3.4 of Appendix I, Economics; in Annex O to Appendix D; and in Section 5.10 of the FR/EIS.

Comment - 31 Recreational activities would change with breaching.

• The recreational opportunities have really improved since the dams have been in.
• The kind of recreation people enjoy would not be available once the dams were breached.
• There would be more recreational opportunities if the dams were breached.

  Response: The potential effects of dam breaching on recreation are discussed in Section 5.12 of the FR/EIS. The estimated recreation-related economic effects are discussed in more detail in Sections 3.2 and 6 of Appendix I, Economics.

Comment - 32 The recreation analysis was incorrect/incomplete.

• Recreational value of rivers would go down (not up) if dams were breached.
• The FR/EIS made wild guesses at future visitation that don't justify the benefits predicted.
• The FR/EIS underestimated the recreation benefits that would occur with dam breaching.

  Response: Points 1 and 3 of this comment illustrate the range of public opinion surrounding the findings of the recreation study. A number of concerns have been raised with the DREW recreation analysis. These concerns have been added to Section 3.2 of Appendix I, Economics in the FR/EIS.

Comment - 33 Dam removal would affect me, my business, and/or my community.

• Quality of life would be negatively affected.
• Way of life would be negatively affected (reversing progress).
• Barge operators would be negatively affected.
• Farmers would be negatively affected.
• Families would be negatively affected.
• Industry would be negatively affected.
• We shouldn't make a rash decision that could negatively affect a lot of people's lives/livelihoods.
• I/my family would have to relocate.
• I/someone in my family would lose my job.
• Some groups in Idaho, Alaska, Montana, and downriver fishing communities felt they woud be positively affected.

  Response: The Corps is very aware that the major decisions this study encompasses regarding controversial regional issues could have significant, personal impacts on people in our region. That is one reason we have taken such care to gather the best possible information and analyses for evaluation, and to solicit and consider input from a variety of perspectives on issues related to the study and its outcome. We believe that decisions with the potential to affect people so personally must be made carefully, and be considered and based on the best available scientific, engineering, and economic information available.

Comment - 34 If salmon go extinct, there would be serious economic consequences.

• Commercial fishing and its economic benefits would be reduced.
• Increased transportation costs would negatively affect farmers.
• Sportsfishing and associated recreation economic benefits would be reduced.
• Tourism dollars would be lost.

  Response: The FR/EIS analyzes the economic effects of the four proposed alternatives. The effects of these alternatives on commercial and recreational fishing were addressed by the DREW Anadromous Fish and Recreation workgroups and are discussed in Sections 3.2 and 3.5 of Appendix I, Economics. These analyses are based on numbers of salmon and steelhead projected to return under each alternative. These projections were developed from the 1998 PATH results. The regional economic impacts of changes in tourism are assessed in Chapter 6 of Appendix I, Economics. The results of these analyses are also summarized in Sections 5.12, 5.13, and 5.15 of the FR/EIS. The DREW Transportation Workgroup analyzed potential increased transportation costs, which are also presented in Appendix I, Economics and carried forward into Section 5.9 of the FR/EIS.

• If salmon become extinct, Native American tribes have cause to sue the U.S. government for not fulfilling the terms of treaties. The potential cost of these lawsuits is not adequately addressed in the economic analysis in the EIS.

  Response: Potential litigation and associated costs regarding treaty issues are impossible to predict, and are not included in the FR/EIS. The Corps believes the preferred alternative is consistent with its treaty obligations.

Comment - 34 If the dams are removed, those who are negatively affected should be compensated.

• Extra public funds (Federal and State) from dam removal should be put into transportation infrastructure, both for highways and railroads.

  Response: The DREW transportation analysis did not consider the ability of the States and others to finance infrastructure improvements that would be needed. This issue would be addressed in detail, if dam removal were recommended for further study.

• If the Corps decides to breach the dams, they should be required to put up bonds that would pay for putting the dams back if removal does not prove to improve fish runs.
• We should pursue lawsuits against groups that push for dam removal aimed at recovering money from crop loss or other economic impacts of breaching.

  Response: Comments noted.

Comment - 37 Salmon are valuable simply because they exist.

• Many people told stories about historically observing and fishing for salmon, and how valuable it is for them to know the salmon are part of Northwest life.
• Salmon are a symbol of the Northwest.
• Salmon were here before us.
• Salmon are a cultural symbol for Northwest tribes.
• Many people from out of the area said they wanted to come see the salmon some day, and they would like for some to be left when they do come.
• The EIS doesn't properly consider the existence value of these fish.
• We have a duty to preserve the salmon species for future generations to enjoy.
• Our ancestors would be appalled at what we have done to the species.
• We should respect and not destroy other living creatures.

  Response: The Corps recognizes and respects the value of salmon to many in our region as a cultural, historical, social, and personal symbol of the Northwest. We agree that, for this and many other reasons, we need to work as part of a regional effort aimed at promoting the survival and recovery of the species that are in danger. It is the goal of this Feasibility Study to contribute to that increased survival. The DREW economic analysis addresses the existence or passive use value of salmon, as well as the passive use values that would be associated with a free flowing river. The findings of this analysis conducted by the DREW Recreation Workgroup are presented in Chapter 4 of Appendix I, Economics and summarized in Section 5.15 of the FR/EIS. Comments ECO-33 through ECO-44 of this appendix specifically address the passive use analysis developed for this study. The importance of salmon for Northwest tribes is emphasized in numerous locations throughout the Final FR/EIS, including Appendix Q, Tribal Consultation and Coordination, Sections 4.8 and 5.7 of the FR/EIS, and Sections 3.6 and 5.0 of Appendix I, Economics.

Breaching is reversible, extinction and ecosystem collapse is not.

Many people are familiar with the Seventh Generation philosophy commonly credited to the Iroquois Confederacy but practiced by many Native nations. The Seventh Generation philosophy mandated that tribal decision makers consider the effects of their actions and decisions for descendents seven generations into the future. There was a clear understanding that everything we do has consequences for something and someone else, reminding us that we are all ultimately connected to creation.