Has the Obama administration gone schizophrenic on salmon? Wild-salmon advocates who were disappointed when the Obama administration defended the last Bush Biological Opinion on Columbia River dam operations say that the government not only could have done better, it did better, just a few months back. They point to the government's recent Biological Opinion on operation of the Central Valley Project and California State Water Project as examples of what NOAA should have done here.
The California opinion looks at impacts on salmon and other fish in the Sacramento and San Joaquin river systems, and on the Southern Resident Killer Whales (aka Puget Sound orcas) that eat some of those salmon. It is 'êbetter and I would say significantly better'ê than what the government has done on the Columbia, says Earthjustice attorney Steve Mashuda. It's 'ênot necessarily a road map'ê for dealing with all the Columbia's particular problems, but it does address some crucial issues 'êprobably in the best way we know how.'ê You can expect salmon advocates to use some of the approaches and some of the science that NOAA employed in California to attack what NOAA has done — or failed to do — in the Northwest.
Arguably, nothing much has changed scientifically or politically since the first Snake River salmon populaton was listed in 1991, except that there have been more listings, fewer salmon, and some shuffling of the political deck chairs. But there are two major new considerations: the acceptance of climate change coupled with the recognition that many spawning streams may become too warm for salmon; and the listing of Southern Resident Killer Whales (SRKWs) coupled with a recognition that their survival is tied closely to that of chinook salmon, the whales' favorite food. The Central Valley BiOp prepared by the Obama administration takes both of those factors prominently into account. The Columbia River BiOp defended by the Obama administration does not.
The government's proposals for recovering salmon in California 'êstand out in stark contrast'ê to its proposals for the Columbia, says Mashuda. He finds the difference 'êmost perplexing.'ê
On June 4, NOAA announced that it had 'êreleased its final biological opinion . . . that finds the water pumping operations in California'ês Central Valley by the federal Bureau of Reclamation jeopardize the continued existence of several threatened and endangered species. . . . Federal biologists and hydrologists concluded that current water pumping operations . . . should be changed to ensure survival of winter and spring-run Chinook salmon, Central Valley steelhead, the southern population of North American green sturgeon, and Southern Resident killer whales, which rely on Chinook salmon runs for food.'ê The agency was not recommending a cost-free approach, or one that had any chance of avoiding litigation. It observed that 'êchanging water operations will impact an estimated 5 to 7 percent of the available annual water on average moved by the federal and state pumps.'ê
In the weeks before NOAA Fisheries formally embraced the Bush BiOp on the Columbia, groups of scientists wrote to NOAA chief Jane Lubchenko and Commerce Secretary Gary Locke urging a different approach — an approach much like the one they had already taken farther south.
A group of orca scientists including Kenneth Balcomb executive director of the Center for Whale Research at Friday Harbor, and Samuel Wasser, director, of the U.W.'s Center for Conservation Biology, focused on climate change and killer whales. Climate change models suggest that within a few decades, Northwestern and California weather will make some spawning streams too warm for anadromous fish. In general, higher places stay cooler, so habitat at the highest elevations will probably have the coolest water. As a long-term strategy for California, NOAA Fisheries told the federal Bureau of Reclamation to come up with ways to get fish into the habitat above Shasta and Folsom dams.
By contrast, the orca scientists wrote, the Columbia River BiOp, 'êfails to account for the impacts of climate change on Columbia Basin salmon and steelhead. While the BiOp generally concedes that climate change will likely affect Columbia Basin salmon, it also assumes that the Pacific Northwest'ês climate conditions will be no worse than conditions experienced in a 'êbase period'ê of 1980 to 2001. As you know, this assumption runs counter to the conclusions of scientific bodies ranging from the UN Intergovernmental Panel on Climate Change to the Northwest Power and Conservation Council'ês Independent Scientific Advisory Board. . . . It also contrasts sharply with NOAA'ês approach in the 2009 [Central Valley] BiOp. In fact, the 2009 BiOp employed detailed Snake River [emphasis added] climate scenarios to illustrate the range of potential consequences of climate change on California salmonids.'ê
In the Columbia River basin, a lot of high-elevation habitat lies in Idaho wilderness above the lower Snake River dams. Salmon advocates suggest that this strengthens the case for breaching those dams. Government spokespeople — and Governor Chris Gregoire — say that the administration has just put dam breaching back on the table. Maybe it has — the judge made it clear that he wanted breaching included, just in case — but at best, the option lies so far back on the table that no one can reach it in a hurry. 'êI don't think it's really putting dam breaching back on the table,'ê Mashuda says. The government won't have a breaching strategy ready to go. All the government promises, he suggests, is that 'ê'if fish populations crash, we'll make a plan to do a study.''ê
The Central Valley opinion also took a hard look at the impact of depleted chinook salmon populations on Southern Resident Killer Whales Everybody knows that Puget Sound orcas eat chinook salmon, and they swim all the way down to Monterrey Bay to get them. The Columbia River BiOp doesn't deny or ignore that. It just reasons that orcas don't care whether the fish they eat are wild or hatchery-raised, that hatcheries will make up for the chinook lost at the dams, and that therefore, the orcas won't suffer. 'êThey're sticking with the 'no harm, no foul' approach,'ê Mashuda says, 'êeven though they rejected that approach on the Sacramento."
If both orcas and their prey are on the endangered species list, Mashuda observes that NOAA is starting from 'êa degraded baseline that is not, by definition, supporting a sustainable whale population.'ê Just keeping the orca population where it is won't be good enough. It has to grow. And more killer whales will require more salmon. You can't get there from here if all you do is hold salmon numbers steady by pumping more fish from the hatcheries. 'êThe NOAA Recovery Plan anticipates that SRKWs would be considered recovered when they reach about 100 adults,'ê the orca biologists wrote Locke and Lubchenko, 'êalthough as you are well aware, a population of that size is normally considered critically endangered. Even this minimal level of recovery would require a doubling in prey availability range-wide.'êAnd it turns out that chinook aren't interchangeable. Columbia River salmon may be better. The scientists noted that 'êwith the decline of Columbia River salmon, the Fraser River system has become the major source of prey for SRKWs. These salmon acquire high levels of industrial toxins during the early part of their time at sea spent in the contaminated waters of Puget Sound and Georgia Basin. The Sacramento River was another important source of prey for SRKWs, and SRKWs still carry the agricultural toxins from these fish. So not only is the Columbia Basin the river system with the biggest potential for producing the Chinook salmon needed to recover SRKWs, the fish produced there may be cleaner than fish produced in the Fraser or Sacramento.'ê
The orca scientists argued that the Columbia River BiOp 'êsimplistically relies on a flawed comparative approach to evaluating the dams'ê impacts on SRKWs.'ê They wrote: 'êTo gauge the effects of the Columbia/Snake hydro system on Southern Residents, [the BiOp] asks only whether the percentage of salmon killed by the dams will be offset by the number of salmon produced in the Basin'ês federally funded hatcheries. After finding that the hatcheries will produce more salmon than the dams kill, NOAA concludes . . . that the dams 'are not likely to adversely affect' Southern Residents." The BiOp, they continue, 'êdoes not examine whether the current salmon population is adequate for SRKW recovery, it does not assess whether changes in the spatial or chronological distribution of hatchery fish align with orcas'ê needs, and it does not assess the risks to salmon or orcas posed by long-term reliance on hatcheries."
In contrast, the orca scientists go on, 'êNOAA takes a very different — and appropriately cautious — approach in its recent Biological Opinion for the Central Valley Project. There, NOAA first finds that it is not clear whether present salmon abundance in the ocean is sufficient even to sustain the current depleted orca population. NOAA . . . finds that changes in either prey availability or prey density that decrease foraging efficiency, and could thus reduce the reproductive capacity of even one orca, would jeopardize the SRKW population. Significantly, as in the 2008 [Columbia River] BiOp, NOAA determines that hatchery production included in the Project would more than offset the number of salmon killed by the Project; however, in the [Central Valley] BiOp, NOAA . . . finds that reliance on long-term hatchery production poses unacceptable risks to both salmon and orcas.'ê
How can one defend both approaches simultaneously, much less do it in the name of science? The Central Valley BiOp came out in June, just as the Obama Administration was "reviewing" and "strengthening" the Columbia/Snake BiOp. 'êHow can they possibly defend the science that lies behind their 'not likely to affect' determination regarding orcas, in light of the science that they published [in the Central Valley BiOp] during this review period?'ê asks Save Our Wild Salmon's associate director, Dan Drais. 'êHow can NOAA say that it has 'strengthened' this BiOp when the agency has employed lower standards in it than in other . . . documents it was simultaneously finalizing? Now that Lubchenco has taken ownership of the new plan, it's not that Obama's science conflicts with Bush's science — Obama's science conflicts with Obama's science.'ê