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De-greening BiOp2000 Risk Analysis

by Robert Stokes
Wheat Life, May 2006

Salmon and Dams - Continued

Risk analysis is a technical term for thinking about the unknown. That topic should be no stranger to readers of Wheat Life. Let's "de-green" the risk analysis developed for BiOp2000, the Columbia River salmon-Endangered Species Act (ESA) enforcement program developed during the 1990s.

De-greening would make a column of its own. I adopt the term to describe retaining objective (genuinely scientific) elements of an analysis while removing subjective elements (environmentalist assumptions and value judgments). The latter are replaced with assumptions and value judgments reflecting policy views I hold and share with Wheat Life readers. De-greening allows readers to access natural resource and environmental science literature without buying into environmentalism as a political cause.

The de-greened view of Columbia River salmon conservation and management supports longstanding national and regional decisions to economically develop the Columbia River and its tributaries. ESA enforcement/compliance is seen as fitting salmon into the system created by those decisions - in "reasonable" numbers, with a "reasonable" degree of biological diversity and "reasonable" fidelity to pre-European settlement population characteristics. "Reasonable" always means being consistent with minimum cost and disruption to the hydropower system and supported communities and industries.

ESA permits cost-oblivious analysis, sometimes even requires it. Absent consideration of costs, claims of extinction risk provide legally sufficient justification for draconian corrective measures. Past ESA fiascos over snail darters, spotted owls and Klamath Basin suckerfish demonstrate this is more than a theoretical possibility. For Columbia River salmon, draconian measures include (current and proposed) requirements to sacrifice electricity production by spilling water over dams to facilitate downstream salmon migration. Other examples are proposals to sacrifice irrigation water to cool reservoirs and reduce juvenile salmon transit times through them. Deactivation of facilities has also been suggested, notably breaching the four lower Snake River dams. A less publicized measure would permanently lower the reservoir behind McNary Dam on the mainstem Columbia.

There simply is no scientific evidence of anything resembling salmon extinction occurring in the Columbia River, now or in the credibly foreseeable future. I use the term extinction as understood by the public and in general scientific discussion, not as (mis)used in NOAA Fisheries ESA enforcement documents. The conservation opportunities and challenges that actually exist in the Columbia are quite normal to fish and wildlife management - not enough salmon to accommodate recreational and commercial fishermen, not enough of every type of salmon in every location to accommodate fisheries specialists and salmon enthusiasts in the lay public. The appetites of such claimants are always insatiable. Measured against human appetites there never have been enough Columbia River salmon and never will be, not even with application of the whole suite of draconian anti-hydro measures.

Managing salmon to generate harvestable surpluses or satisfy other ambitious abundance goals are appropriate resource management topics. But their discussion belongs in other legal and political settings, where the playing field is level among participants and salmon conservation costs are compared with salmon values. Just because someone wants more salmon than are currently present or realistically expected, does not obligate others to pay for them on pain of ESA enforcement action.

ESA requires the federal government to maintain or restore populations to a condition where "measures [required] under the Act are no longer necessary." It is not clear how responsibility for doing so is shared among federal agencies. The operative requirement for Columbia River salmon is that federal agencies (i.e., hydrosystem operators) not create jeopardy, meaning increase risks of species extinction by proposed actions.

It will take many more years of litigation and political dispute to figure out exactly what these provisions mean, if that is ever possible. For now, we can say, with reasonable confidence, they have something to do with species survival. They do not mandate abundances or geographic distributions desired for other reasons. Neither do they require the creation or maintenance of "natural" environments for their own sake.

I will happily debate these propositions further via e-mail.

For now, let's look more narrowly at the "extinction" risk analysis included in BiOp2000. Citations to the administrative record and scholarly literature are listed below. They are recommended to readers with a serious interest in risk analysis and strong math/statistics background. Others should trust this summary.

The objective (scientific) part of the analysis is well done. Replicable (i.e., objective and therefore scientific) historic data on adult salmon returns are subjected to (also replicable) statistical analysis. That analysis estimates annual changes in the size of Columbia River salmon populations. The estimated values are actually statistical distributions. The single numbers used here are mean values of those distributions. Mean values are more understandable and sufficient for present purposes.

As with last month's discussion of ESA listings, we illustrate risk analysis with fall chinook salmon. Evolutionarily Significant Unit (ESU) is the NOAA Fisheries term for salmon populations separately classified for ESA enforcement purposes. Recall (my fabricated) Columbia-River-above-Bonneville-dam-fall-chinook ESU. Its most significant component is the Hanford Reach population. The risk analysis suggests long-term growth in that population, four percent per annum to be precise. Because of their overwhelming number (104,726 primarily in-stream spawners in 2004) a growing Hanford Reach population should preclude noticeable decline in the above-Bonneville fall chinook total, regardless of defensibly foreseeable events affecting other components.

Though numerically insignificant, relative to the Hanford Reach population (only 318 reported in 1991), Snake River (in-stream spawning) fall chinook salmon are the political hot potatoes. Political salience is a more believable motive for their separate treatment than the insignificant and ambiguous biological differences (from adjacent Hanford Reach fish) cited in support of their separate ESA classification and listing.

I have harped enough on population splitting. Let's give NOAA Fisheries and the salmon advocates their position, that loss of a few thousand Snake River fish would be an event of biological significance to the species chinook salmon (oncorhynchus tshawytscha). I find this an odd view as millions of chinook salmon range throughout the North Pacific Ocean and spawn from Northern California to Russia. But, it's a concession that allows us to move on. Likewise, to create happiness in environmentalist circles, I will use the term extinction to describe loss of Snake River (in-stream spawning) fall chinook salmon.

The risk analysis asserts that Snake River, in-stream spawning, fall chinook salmon will decline at an annual rate of five percent. Read the citations for numerous qualifications, particularly concerning the role of hatchery fish. Note that between the year of record for listing (1991) and risk analysis (2000), the 318 newly listed salmon did not decline. Rather they increased to 1946. Note also that more recent improvements in salmon returns suggest a recalculation (including 2001 - 2005 information) would diminish the reported five percent annual decline, possibly even convert it to a projection of annual increase.

That said, let's use the currently published five percent figure to determine when an extinction event will occur. Again, extinction only means loss of salmon meeting NOAA Fisheries criteria for inclusion in the Snake River (in-stream spawning) fall chinook salmon ESU. The math is like calculating compound interest with a negative interest rate. Each one hundred of today's spawning adults are projected to leave 60 descendants after a decade (.95 to the 10th power), 36 after two decades (.95 to the 20th power), and so on.

Where along that path does extinction occur? That depends on how many salmon you start with. More precisely, how small you make the categories. Let's illustrate with a 20-year forecast. After twenty years of five percent annual decline, the 1946 Snake River (in-stream spawning) fall chinook salmon reported in the risk analysis baseline year (2000) will leave only 698 survivors. The 318 credited in the listing year (1991) would leave only 114.

Those are scary numbers, especially when laid before a sympathetic judge by environmentalist lawyers (Earthjustice) or touted to the press and public by an environmentalist advocacy group (Save our Wild Salmon).

However, applying the same five percent annual decline to the 583,422 fall chinook salmon passing through Bonneville dam in 2004 leaves over 200,000 fish after 20 years. Starting from today, that means over a fifth of a million fish remaining in the year 2026. Granted these are a mixture of hatchery and in-stream spawning fish. However, the Hanford Reach supplies a significant in-stream spawning component. That is not projected to decline, but increase. Most hatchery fish included in the above-Bonneville total are biologically comparable to local or historic in-stream spawners. If not, they eventually will be under current and evolving hatchery policies.

The point of the calculation remains valid. The "wild salmon" are already quite well "saved." They have been for some time and will remain so, as far into the future as sensible people claim an ability to see.

It is noteworthy that, in their scholarly publication, the authors of the risk analysis make no attempt to scientifically justify choice of the 50-year projection period used in BiOp2000. That silence is entirely appropriate when adopting an acknowledged subjective assumption needed to complete a calculation. It's like an individual picking a year of death to complete retirement planning calculations. Also to their credit, the authors suggest a primary use of their analysis is comparing risk between species, rather than over time. The validity of that use is unaffected by whether, or not, one believes government biologists are endowed with the ability to peer a half century into the future.

Nevertheless, NOAA Fisheries (in BiOp2000) and the authors (in their peer reviewed publication) make 50-year projections and describe them as extinction risks. At five percent annual decline over 50 years, 100 present-day salmon yield only eight survivors. Even the half-million-plus above-Bonneville fall chinook shrink to a disconcerting 45,000. By any definition, using any base year, Snake River (in-stream spawning) fall chinook salmon essentially disappear (the 318 become 24, the 1946 are reduced to 150).

My rules of de-greening don't require refuting the choice of a 50-year projection period, only flagging it as a subjective assumption. Such assumptions are nearly universal practice in natural-resource management. However, all effected parties have a right to know how those subjective assumptions relate to chosen goals.

Those seeking to load the guns of dam-busting environmentalists will project long. That allows the administrative and scientific record to be salted with statements about extinction risk; statements which, in turn, justify draconian ESA enforcement measures, imposed administratively or through judicial action.

Those trying to conserve and manage salmon by other means, based on credible information, will keep their projections short. They may exercise even more humility concerning knowledge of the future, by designing adaptive conservation measures that permit learning-by-doing. Rock bottom on any list of adaptive, learning-by-doing measures would be tearing out dams today, based on 50-year extinction forecasts.

More next month on current (and de-greened) Columbia River salmon conservation measures.

Michelle M. McClure, Elizabeth E. Holmes, Beth L. Sanderson, Cris E. Jordan, "A Large Scale, Multispecies Status Assessment: Anadromous Salmonids in the Columbia River Basin," Ecological Applications (Vol 13, no. 4) 2003. pp. 964 - 989.
(BiOp2000) National Marine Fisheries Service (now NOAA Fisheries), Northwest Region "Endangered Species Act Section 7 Biological Opinion on the Reinitiation of Consultation on Operation of the Federal Columbia River Power System, Including the Juvenile Fish Transportation Program, and 19 Bureau of Reclamation Projects in the Columbia Basin." December 21, 2000.

Related Pages:
Snake Fall Chinook Studies Get More Complicated by Bill Rudolph, NW Fishletter, 12/20/6

'Rivers Are For Salmon'

A U.S. District Court judge recently ordered the Bureau of Reclamation to limit irrigation water to farmers along the Klamath River in drought years to, theoretically, protect migrating salmon. The Bush administration also announced a surprising change of attitude regarding hydroelectric dams on the Klamath. "Dam decommissioning and dam removal would go a long way toward resolving decades of degradation where Klamath River salmon stocks are concerned," said a spokesman for the Department of Interior and the National Marine Fisheries Service. Licenses for the Klamath dams expired last month and the feds are trying to force the dams' owners, PacifiCorp, to either demolish them or spend an estimated $200-million to refit with fish ladders and other expensive devices. Currently, the annual value of electricity produced by the four dams is only about $27-million. Dave Kvamme, PacifiCorp spokesman, said the company wants to keep the dams operational and there is no guarantee $200-million fish ladders would improve salmon runs. The feds think PacifiCorp will cave. "We have an historic doorway that is opening here," said Steve Thompson, Fish and Wildlife operations manager. "It is potentially very good for everybody who lives on the river." Well, not everyone. Greg Addington of the Klamath Water Users Association said, "Dry years are going to be very tough." - Liberty Matters News Service

Robert Stokes is a retired natural-resource economist who lives in Spokane. He holds a Ph.D. in economics from the University of Washington, where he taught in the Institute for Marine Studies from 1974 to 1994.
De-greening BiOp2000 Risk Analysis
Wheat Life, May 2006

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