August 9, 2023
Ms. Brenda Mallory
Chair
Council on Environmental Quality
722 Jackson Place, NW
Washington, DC 20503
Via regulations.gov
Re: Columbia River Salmon and Other Native Fish, Docket No. CEQ-2023-0002
Dear Chair Mallory:
On behalf of the American Fisheries Society (AFS), we thank you for the opportunity to submit comments supporting a long-term strategy to restore Columbia River basin salmon and other native, migratory fish populations to healthy and harvestable abundance levels.
AFS is a scientific organization of over 7,000 professional fishery scientists and resource managers across the world, many of whom live and work in the western United States and have long-studied salmon and their declining populations. AFS promotes the conservation and sustainability of fishery resources and aquatic ecosystems through dissemination of fisheries science via scientific journals on fisheries, conferences, and continuing education.
The science is clear and compelling; removing the lower four Snake River dams is necessary to restore critically at-risk populations of wild Snake River salmon and steelhead that hover on the brink of extinction. Today, only 1–2% of formerly abundant, historic wild salmon and steelhead return to the Snake River to spawn (Winters 2023). Recent reports demonstrate that 42% of Snake River wild spring/summer Chinook Salmon and 19% of steelhead populations have declined to the threshold where extinction is highly likely (O’Toole 2021).
Climate change will continue to worsen conditions for these and other coldwater species. Ensuring access to intact and high elevation habitat in the Snake River basin provides the best opportunity for broadscale population recovery and persistence in the face of a changing climate (Storch et al. 2022).
Because the science is clear and compelling and effective action is urgently needed, in January, AFS adopted a policy statement in support of breaching the lower four Snake River dams (Winters 2023). We attach it here for your consideration. The policy statement concludes that “[i]f Snake River basin salmon and steelhead are to be saved, then policymakers and stakeholders at all levels will need to implement appropriate processes and funding provisions to breach the four dams on the Lower Snake River, as well as implement all necessary habitat rehabilitation. There are other services that must be accounted for if dam breaching were to occur.”
In addition to this policy statement, we ask you consider the following information as you formulate actions to restore wild, anadromous salmonids and other native fishes in the Columbia/Snake River system:
- Why is Hydropower not a “green” energy source?
Hydropower dam/reservoir systems are actually not ”green” because of their profound effects on water quality, cyanobacteria, instream flow, habitat blockage, and greenhouse-gas (methane/nitrous oxide) emissions (Storch et al. 2022; Twidell 2022; Winters 2023).
- What constitutes “restoration” of the lower Snake River and what steps should the federal government take to restore the lower Snake River?
Restoration of wild anadromous fish to healthy and harvestable levels is an appropriate restoration goal. In Idaho, recreational harvest of wild Chinook Salmon has been closed since 1978, a 45-year period. Endangered Species Act (ESA)-driven minimum requirements for recovery are insufficient to achieve agreed-upon socially, culturally, economically, and ecologically grounded high range goals as established by the Columbia Basin Partnership (CPB; https://www.fisheries.noaa.gov/vision-salmon-and-steelhead-goals-restore-thriving-salmon-and-steelhead-columbia-river-basin).Decades of science showing lack of effective recovery (Jaeger and Scheuerell 2023) demonstrates the need to breach the lower four Snake River dams to reach this restoration goal (Hatch Magazine 2021; Storch et al. 2022). The need to breach these dams is confirmed by a comparison of smolt-to-adult returns (SARs) versus the number of dams anadromous fish must pass. Recent SARs for Snake River wild spring/summer Chinook Salmon have averaged 0.7% above eight dams, in comparison to SARs for non-ESA listed, wild spring Chinook Salmon above fewer dams in the mid-Columbia River that have sustainable SAR objectives (McCann et al. 2019). From 2000-2017, wild Chinook Salmon SARs averaged 3.6% in the John Day River above three dams, 2.5% in the Yakima River above four dams, and 0.7% in the Snake River above eight dams (op. cit.). The John Day, Yakima, and Snake River populations experience the same treaty and nontreaty fisheries, pinniped predation, and ocean conditions; the primary difference among them is the number of dams they must pass (Storch et al. 2022).
Dam removal will also help meet ecological benchmarks for anadromous fish restoration (Storch et al. 2022). In 2020, the Northwest Power and Conservation Council “reaffirmed the prior benchmark of smolt-to-adult returns (SAR) averaging 4% (range: 2%–6%) for spring/summer Chinook Salmon… (A) minimum SAR of 2% is required to consistently maintain existing populations, whereas SARs > 2% indicate degrees of population growth… Smolt-to-adult return rates ≥ 4% achieved on a regular basis should promote a high likelihood of recovery (i.e., consistent generational increases in abundance… The Independent Scientific Advisory Board…has reviewed…the 2–6% SAR objective and identified extensive evidence to support these goals…”
Connectivity in the lower Snake River is further critical for steelhead, Bull Trout, White Sturgeon, and Pacific Lamprey. Restoring the Snake River will reestablish opportunities for repeat spawning to maintain their populations (Vadas 2000; Vadas et al. 2016; Storch et al. 2022), as dams and low/warm flows negatively affect immigrations of adults and outmigration of both juveniles and spent adults that survive and may spawn again in future years. This approach has been successfully used in Maine, where dam breaching increased abundances of repeat spawning Atlantic Salmon and nonsalmon species (Chelminski 2015; Whittum et al. 2023; Winters 2023).
- What considerations should inform the federal government’s approach to restoring the lower Snake River?
The science on the need for and efficacy of dam breaching is clear. The billions of dollars spent to date on recovery of Snake River anadromous fish have not been effective (Hatch Magazine 2021; Storch et al. 2022; Jaeger and Scheuerell 2023; Winters 2023).In the 1990s, 30 scientists from state, federal, tribal, and other entities participated in the PATH (Plan for Analyzing and Testing Hypotheses) process that evaluated SARs and the probability of achieving the interim survival and recovery standards of National Oceanic and Atmospheric Administration (NOAA) Fisheries (Marmorek et al. 1998). The PATH analyses concluded that the Natural River option to restore the Snake River (via breaching the four lower Snake River dams) was the only option that would provide recovery. They stated that this option has the “highest certainty of success and the lowest risk of failure.” (Storch et al. 2022). The PATH conclusions have been reaffirmed by scientific review panels, agencies, and scientists for the past 25 years; here are examples:
- The CSS (Comparative Survival Study 2019) predicted a two- to threefold fold increase in salmon abundance with the Natural River option and a fourfold increase if dam breach is coupled with maximum spill over the remaining four downstream Columbia River dams.
- In 2021, emeritus scientists with decades of experience working with anadromous fish wrote to the Northwest Governors, “based on overwhelming scientific evidence, restoration of a free-flowing lower Snake River is essential to recovering wild Pacific salmon and steelhead in the basin” (Hatch Magazine 2021).
- NOAA Fisheries (2022) concluded that breach must be the centerpiece action to achieve CBP goals, as dam spills are inadequate to sustain native fishes with consistently clean, cold water, particularly in the face of climate change (cf. Storch et al. 2022). Last October, NOAA Fisheries (2022) reported, “To make progress towards healthy and harvestable stocks it is essential that the comprehensive suite of management actions includes: Significant reductions in direct and indirect mortality from mainstem dams, including restoration of the lower Snake River through dam breaching.”
- What information should the federal government develop to support discussions in the Northwest and in Congress on the restoration of the lower Snake River?
For policymakers to move forward in breaching the dams, it is crucial to develop a clear roadmap for ameliorating the economic (energy/transportation) impacts of breach on those who rely on the dams (Hatch Magazine 2021; Storch et al. 2022; Winters 2023).
- What considerations should inform the federal government’s approach to supporting the Upper Columbia River Tribes’ reintroduction plan?
Restoring access and reintroducing anadromous fish must be a centerpiece action to achieve CBP goals for upper Columbia River stocks (NOAA Fisheries 2022). Actions should include restoring Pacific Lamprey runs to Columbia River tributaries (Storch et al. 2022) and improved passage past Chief Joseph and Grand Coulee dams for Chinook Salmon and other native migratory fishes (Hanrahan et al. 2004). These goals serve the purposes of First Nations like the Colville Confederated Tribes.
Thank you for your consideration. For additional questions, please contact Drue Banta Winters, dwinters@fisheries.org.
Sincerely,
Douglas J. Austen, Ph.D.
Executive Director
References
Chelminski, M. 2015. Why did the dam cross the river? Getting to the other side of small dam removals (abstract and presentation). Prepared for the American Fisheries Society and American Society of Civil Engineers, Joint Committee on Fisheries Engineering and Science. Bethesda, Maryland; and Reston, Virginia. Available: https://units.fisheries.org/fishpassagejointcommittee/activities/webinars (August 2023).
Hanrahan, T.P., D.D. Dauble, and D.R. Geist. 2004. An estimate of Chinook salmon (Oncorhynchus tshawytscha) spawning habitat and redd capacity upstream of a migration barrier in the upper Columbia River. Canadian Journal of Fisheries and Aquatic Sciences 61:23-33. Available: https://doi.org/10.1139/f03-140.
Hatch Magazine. 2021. Scientists draft letter calling on governors to tear down the lower Snake River dams: for salmon and steelhead to survive, the dams must go. Hatch Magazine (San Diego, CA), January 14. Available: https://www.hatchmag.com/articles/scientists-draft-letter-calling-governors-tear-down-lower/7715196 (August 2023).
Jaeger, W.K., and M.D. Scheuerell. 2023. Return(s) on investment: restoration spending in the Columbia River Basin and increased abundance of salmon and steelhead. PLoS (Public Library of Science) ONE [online serial] 18(7):e0289246. Available: https://doi.org/10.1371/journal.pone.0289246.
Marmorek, D.R., C.N. Peters, I. Parnell (Eds.), PATH Final Report for Fiscal Year 1998, Bonneville Power Administration, Portland, OR (1998). Available: http://www.essa.com/documents/1998_Final_Report.pdf
McCann, J., B. Chockley, E. Cooper, B. Hsu, G. Scheer, S. Haeseker, R. Lessard, T. Copeland, E. Tinus, A. Storch, D. Rawding Comparative survival study (CSS) of PIT-tagged spring/summer/fall Chinook, summer steelhead and Sockeye. Annual Report to the Bonneville Power Administration, Contract 19960200. Portland, OR. (2019). Available: http://www.fpc.org/documents/CSS/2019_Final_CSS.pdf.
NOAA Fisheries. 2022. Rebuilding interior Columbia Basin salmon and steelhead. U.S. National Oceanographic and Atmospheric Administration, National Marine Fisheries Service. Silver Spring, Maryland. Available: https://www.fisheries.noaa.gov/resource/document/rebuilding-interior-columbia-basin-salmon-and-steelhead (August 2023).
O’Toole, P., editor. 2021. Nez Perce Tribe staff presentation on their analysis of Snake River basin Chinook and steelhead—quasi-extinction threshold and call to action (memorandum and presentation). Northwest Power and Conservation Council. Portland, Oregon. Available: https://www.nwcouncil.org/sites/default/files/2021_05_4.pdf (August 2023).
Storch, A.J., H.A. Schaller, C.E. Petrosky, R.L. Vadas, Jr., B.J. Clemens, G. Sprague, N. Mercado-Silva, B. Roper, M.J. Parsley, E. Bowles, R.M. Hughes, and J.A. Hesse. 2022. A review of potential conservation and fisheries benefits of breaching four dams in the Lower Snake River (Washington, USA). Water Biology and Security [online serial] 1(2):100030. Available: https://doi.org/10.1016/j.watbs.2022.100030.
Twidell, J. 2022. Renewable energy sources. 4th ed. Routledge. New York. Available: https://www.routledge.com/Renewable-Energy-Resources/Twidell/p/book/9780415633581.
Vadas, R.L. Jr. 2000. Instream-flow needs for anadromous salmonids and lamprey on the Pacific coast, with special reference to the Pacific Southwest. Environmental Monitoring and Assessment 64:331-358. Available: https://doi.org/10.1023/A:1006486920036.
Vadas, R.L. Jr., H.A. Beecher, S.N. Boessow, and J.H. Kohr. 2016. Coastal Cutthroat Trout redd counts impacted by natural water supply variations. North American Journal of Fisheries Management 36:900-912. Available: https://doi.org/10.1080/02755947.2016.1173138.
Whittum, K.A., J.D. Zydlewski, S.M. Coghlan, Jr., D.B. Hayes, J. Watson, and I. Kiraly. 2023. Fish assemblages in the Penobscot River: a decade after dam removal. Marine and Coastal Fisheries: Dynamics, Management, and Ecosystem Science [online serial] 15:e10227. Available: https://doi.org/10.1002/mcf2.10227.
Winters, D.B., editor. 2023. Statement of the American Fisheries Society (AFS) and the Western Division of AFS about the need to breach the four dams on the lower Snake River. Fisheries 48:215-217. Available: https://doi.org/10.1002/fsh.10906; and https://fisheries.org/policy-media/recent-policy-statements/statement-of-the-american-fisheries-society-afs-and-the-western-division-afs-wdafs-about-the-need-to-breach-the-four-dams-on-the-lower-snake-river (August 2023).
