Recommendation 029 Save Our Wild Salmon

Recommendation 29
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May 12, 2000

Larry Cassidy, Chairman
Northwest Power Planning Council
851 S.W. Sixth Ave., Suite 1100
Portland, OR 97204

RE: Recommendations for Columbia Basin Fish and Wildlife Program

Dear Sirs

On behalf of the Save Our Wild Salmon coalition and the individual organizations listed below, this letter provides recommendations for the comprehensive revision by the Northwest Power Planning Council of the Columbia River Basin Fish and Wildlife Program. Although our focus remains at the Basin level, these recommendations otherwise follow the format requested by the Council offering recommendations for (a) a vision for the Fish and Wildlife Program (b) biological objectives, (c) strategies for achieving the vision and objectives, (d) a general scientific framework, (e) a criterion for prioritizing fish and wildlife projects, and (f) improvements III program management, evaluation, and coordination. If the region does not address the fundamental basin level problems it is improbable that the even the most aggressive sub-basin strategy can work for endangered stocks.

Prior to discussing recommendations in this format, we want to advise the Council of a few broad-based recommendations that do not fit simply within the Council's commenting for mat. First, SOS strongly urges the Council to recommend partial removal of the lower Snake River dams in time for the Lewis and Clark bicentennial anniversary. The Council should not assume that this action need take more time when the actually physical removal will take less than two years. Second, the Council must recommend and implement actions that fully comply with all federal laws and treaties, including the Clean Water Act and the Endangered Species Act. Anything less is both legally and scientifically unjustified. With these broad overarching comments, we submit the following recommendations.

A. Vision

The Columbia River Basin Fish and Wildlife Program should (1) prevent any further extinctions of species or genetically differentiated subspecies of fish and wildlife; (2) and resident fish populations to sustainably harvestable numbers; (3) fully comply with all applicable federal laws and treaty obligations as well as tribal fish and wildlife programs; and (4) invest strategically in infrastructure to maintain or strengthen the regional and local economics. This set of strategies must be implemented within the next five years to avoid further extinctions.

With specific regard to the federal Endangered Species Act, the Program should promote pro-active steps to protect and restore fish and wildlife populations in the Columbia Basin in order to avoid the need for any further species listings and to allow for the eventual de-listing of currently threatened and endangered fish and wildlife. Additionally, in light of the recent Environmental Protection Agency comments regarding water quality problems associated with dams on the Columbia and Snake Rivers, the. Council should pay special attention to ensure that its actions and recommendations correct current water quality violations.

B. Biological Objectives

(1) Reproductive Success: Productivity of all fish and wildlife should reach population replacement in all years, and for declining species, population increase in most years. For anadromous fish specifically, stocks of salmon and steelhead should achieve a smolt-to-adult survival ratio of at least 2 percent in all years, and 4-6 percent in most years. Ratios for up and down river stocks (i.e., lower or Mid-Columbia stocks) should be equivalent in all years to ensure that up river stocks (i.e., Snake River stocks) needs are not inadvertently masked by improvements in down river stocks

(2) Habitat: The Program should result in healthier, more diverse, more productive, and better connected habitats for fish and wildlife. This includes, but is not limited to developing 250-300 foot buffers in all fish bearing and rearing streams; developing buffers on non-fish bearing streams to provide clean water and control flooding; maintaining temperatures of not more than 20 degrees Celsius throughout salmonid ranges; and increasing connectivity within the ecological system.

C. Strategies

Based upon the best available biology, SOS respectfully recommends the following actions in the "4Hs" of human impacts -- hydropower, habitat, hatcheries, and harvest.

(1) Hydropower

Partially remove the four Lower Snake darns;
Permanently drawdown the John Day reservoir to spillway crest;
Improve dam and reservoir passage at the four Lower Columbia and five mid-Columbia mainstem projects, including controlling spill;
Add significant flow augmentation in the Columbia and Snake Rivers; and
Provide strategic investments in energy conservation and renewables, transportation infrastructure, and irrigation pumping facilities in order to mitigate economic impacts and strengthen the regional and local economics.
End fish trucking and phase out fishing barging.

(2) Habitat

Partially remove the four Lower Snake dams;
Permanently drawdown the John Day reservoir to spillway crest;
Provide near-term protection and restoration of riparian zones on all fish-bearing streams in public lands, including 250-300 foot buffers;
Provide long-term protection or restoration of riparian zones on all fish-bearing streams in private lands;
Retain the "Protected Areas" rule;
Protect and restore salmonid habitat in the Columbia estuary by acquiring habitat within the estuary and restoring historic wetland areas;
Cancel the Lower Columbia River Federal Navigation Channel Deepening Project;
Maintain and achieve high water quality and quantity throughout the Columbia Basin. This includes meeting or exceeding all temperature and sediment water quality standards within the Basin;

Eliminate livestock grazing on all water quality limited streams through such measures as fencing requirements and buyout of current grazing permits;
Provide strategic investments in land purchases, conservation easements, incentives, and infrastructure in order to implement habitat restoration at fastest possible rate. Areas of special importance include the Columbia River estuary and the John Day River; and
Acquire water rights in key salmonid rearing, spawning, and migration areas.

(3) Hatcheries

Operate hatcheries for species conservation and diversity, mitigation, and research, with stocking programs derived from and consistent with wild fish protection and ecosystem carrying capacities;
Reform existing hatchery operations to minimize adverse impacts on native stocks;
Devise fish culture that is less domesticating;
Reject artificial production in lieu of habitat protection and restoration;
Ensure that future artificial production acitivities work inconjunction with subbasin habitat plans;
Reduce artificial fish production as fish populations and harvests recover; and
Redirect funds saved from downsizing hatchery programs to other essential improvement programs, especially habitat preservation and restoration.

(4) Harvest

Maintain harvest for native peoples consistent with treaty rights;
Develop river-by-river, species-by-species, stock-by-stock spawning escapement requirements for wild fish populations; and
Assure harvest plans which meet these escapement requirements.

D. General Scientific Framework

The Fish and Wildlife Program should rigorously follow the basic ecological principle of providing and/or restoring healthier, more diverse, more productive, and better connected habitats for fish and wildlife. For anadromous and resident fish, the Program should adopt the "normative river" concept of the Independent Scientific Group (1996), and should reject technological fixes.

E. Criterion for Prioritizing Fish and Wildlife Projects

Priority should go to fish and wildlife projects which protect and restore healthier, more diverse, productive, and better connected habitats for fish and wildlife, and which implement the "normative river" concept. The Council should give priority to the protection of healthy populations and focus on rebuilding weak stocks.

F. Improvements in Program Management, Evaluation, and Coordination

The Northwest Power Planning Council should carefully and fully implement section 4 (h) of the

Northwest Power Planning Act, particularly section 4.(h)(6)(B) that all Fish and Wildlife Program

measures "will complement the existing and future activities of the Federal and the region's State fish and wildlife agencies and appropriate Indian tribes."

Thank you for this opportunity to offer recommendations for the comprehensive revision of the Council's Fish and Wildlife Program. If you have questions or need further information, please do not hesitate to contact us.

Sincerely,

Pat Ford
Save Our Wild Salmon
Shawn Cantrell
Friends of the Earth
Glen Spain
Institute for Fisheries Resources & Pacific le Coast Federation of Fishermen's Associations
Tim Stearns
National Wildlife Federation

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