Photo by Ariel Yseth.
OPEN LETTER TO THE GOVERNOR'S ORCA RECOVERY TASK FORCE
September 4, 2018
To: Les Purce and Stephanie Solein, co-chairs of Gov. Inslee's Orca Recovery Task Force
Dear Les and Stephanie, Task Force members, and friends and colleagues,
In our shared interest of helping Southern Resident whales survive I'd like to offer you some information and evidence about the feasibility of breaching the four lower Snake River dams, in the form of answers to the Orca Task Force Hydro group's questions.
Please review these answers as partial fulfillment of our value and obligation to take bold action to save the So. Resident orcas from extinction. The chronic declines of chinook, which are at least 80% of the endangered Southern Resident Killer Whales diet, has exacerbated their decline to an effective breeding population of less than 30 individuals. Without immediate increases in chinook, a few more deaths will make recovery unlikely. Because genetic diversity in wild chinook is dangerously low and spiraling downward, a breaching delay of even one more year could likely preclude any endangered Snake River salmon recovery, especially in the face of climate change. Loss of diversity will also lead to the further demise of hatchery fish.
Actions short of breaching will not recover these orca; although it may allow a few to struggle on until they are “legally” extinct 20-30 years from now. Existing studies and data show their prey dependency on Columbia/Snake runs, and the biological benefits of breaching, which yields immediate smolt survival in the millions. Nothing else can produce similar results.
As stated on the Puget Sound Partnership Task Force website, RECOVERY OF ORCA DEPENDS ON RECOVERY OF CHINOOK SALMON.
Please forward to Task Force members.
All best wishes,
The questions below were the unknowns raised at the discussion in the Hydro breakout session of the Aug. 28 Orca Recovery Task Force meeting about breaching the 4 Snake dams, in preparation for a Task Force webinar on the topic. All are important questions and all have reliable answers. In the interest of finding the best path forward to provide more chinook salmon for So. Resident orcas, some well-researched answers are provided below, prepared by a team of researchers and scientists. This is verifiable evidence on the table, presented in the interest of providing the most chinook salmon possible in the shortest possible time, with the least possible political entanglements, IF the evidence is fully considered. The facts describe a win-win solution to helping the Southern Resident Orca community avoid extinction. No stakeholder with a seat at the table at the Task Force would lose anything, and most would gain economically and ecologically by following through with breaching at the earliest window of opportunity.
Most of these topics are complex and further clarification may be found in documents and by contacting principal officials, but that material is all available. If there are any questions or comments please let's have a conversation.
I recommend that the OTF should urge Gov. Inslee to contact the USACE chain of command including Chief of Engineers and Commanding General of the U.S. Army Corps of Engineers, General Semonite, to request with all requisite urgency a Record of Decision to exercise his authority to breach the earthen embankments beside each of the 4 LSR dams to restore listed salmon and steelhead access to the upper watershed. This action would recognize the duly appointed authorities responsible for dam operations and ask them to act with all due haste in accordance with the ESA. The window for commencing dam removal is in December, and we may not have another year to avoid the pending decline of So. Resident orcas to a point of no return.
For indepth analysis of the benefits of breaching for salmon restoration see the USACE Plan Formulation
, and for current studies of the overall economic benefits of breaching see for example the 2016 report by Earth Economics, National Economic Analysis of the Four Lower Snake River Dams
The summary versions are below.
Questions and Answers:
1. What are the benefits to Chinook abundance?
Chinook abundance would increase dramatically by about 2 million adults in So. Residents' typical range within 2 years of breaching. Reservoir mortality due to slackwater immobility, predation and high temperatures is estimated to be at least 5-6% per reservoir with another 3-5% lost in each spillway or sluice, so each dam and res on the lower Snake kills around 8-11% of the 20 million yearling wild migration and hatchery chinook released each year. Thus approximately 8 million additional spring/summer Chinook salmon smolts would enter the Columbia River estuary, resulting in approximately 2 million adult chinook available to So. Residents within 1.5 to 2 years with substantial increases in following years.
At the time the spring chinook in the Snake River would leave their natal streams and hatcheries, they most likely would be 1 to 1.5 years old, so by the time they return two years later, they’re 3 to 3.5 years old and would be 15 to 20 pound spring chinook. Four year olds are up to 35-40 pounds.
According to the Army Corps of Engineers' 2002 Lower Snake River Juvenile Salmon Migration Feasibility Report/Environmental Impact Statement
(p.27) "[Alternative 4 breaching] provides the highest probability of meeting the survival and recovery criteria under the PATH analysis. ...further improvements in the hydrosystem passage are unlikely to recover listed Snake River stocks."
2. What are the impacts to hatchery production?
Hatchery production would continue to be a crucial part of mitigating Chinook population fluctuations. Between the Tribes that operate most of these hatcheries, public outcry and the fact that "mitigation" doesn't end with dam breaching but when wild runs are restored to predam levels, all hatcheries will keep operating except for Lyons Ferry on the lower Snake, which has a poor history and would be too expensive to retrofit to river conditions.
3. Who has the authority?
The US Army Corps of Engineers has the authority to place the dams into a “non-operational” or ”caretaker” status and then start breaching the dams, and does not need Congressional approval or appropriations, or a final decision to the current NEPA process, to authorize these actions. The USACE has placed similar projects (such as the Willamette Lock and Dam in Portland, OR) into non-operational status. Gen. Semonite in DC can authorize breaching. In a letter dated Jan. 17, 2017, Jo-Ellen Darcy, Sec. of the Army for Civil Works (Army Corp of Engineers) wrote: The Corps is "committed to following the guidance in the 2002 FR/EIS as a framework for its actions, which includes ongoing assessments as to the efficacy of the alternatives it has implemented to date; the results of those assessments will inform our next steps..."
4. What is the role of the BPA?
BPA sells the power from the 4 LSRDs to Public Utility Districts and other customers and is accountable for 92% of their Operations & Maintenance costs. The power these dams make is surplus and sold at a loss. Breaching these dams would help BPA’s bottom line and the SRKWs. Over the past ten years the price of surplus power has declined over 60% while the California market for BPA energy has declined significantly due mainly to extensive solar power. BPA also pays for fish and wildlife mitigation for harm caused by the dams, and for turbine rehabilitation and lock and other maintenance. That means the 4 dams are returning only 15¢ for every $1 invested. BPA would pay breaching costs from its credits included in the 1980 Power Planning and Conservation Act. The “fish credits” are an accounting mechanism tied to the mitigation benefits of breaching the dams. Corrected costs for breaching via channel bypass are $339 million, to notch the dams to allow the river to complete removal, and placement of armor stone, if required. The expense is roughly equal to an average year's expenses for maintenance and mitigations. BPA has spent nearly its entire cash reserve of over $900 million and is $15 billion in debt and facing a financial cliff. Breaching would help it avoid insolvency and save ratepayers' and taxpayers' money. The Army Corps owns and operates the 4 dams and the U.S. Bureau of Reclamation has a role in managing them.
5. What are the impacts to transportation and irrigation?
Transportation via barge would cease and grain would be moved by rail (not trucks). This has been underway over the last 15+ years as the barge industry has seen a 70% drop in shipments. Railways are being upgraded now and farmers are finding it cheaper to ship by rail, despite the highly subsidized barging rates. Irrigators would need to install extended pumps and pipes to the now flowing Snake River. This upgrade would use the same pumps currently in use and add additional pumps and pipes down to the Snake River. Irrigation mitigation costs for irrigators on Ice Harbor reservoir (the only reservoir used for irrigation) would be perhaps $150 million, to cover the construction of higher pumping costs or lower real-estate values, while hundreds of acres of rich bottomland would return to orchards and vineyard production.
6. What are the impacts to energy production and CO2 emissions?
Energy production in the region would be reduced by 4% and BPA’s energy portfolio would be unaffected, since BPA currently makes at least 17-50% surplus energy due to available wind and solar resources. There would be no need for additional fossil fuel combustion to generate electricity. The reservoirs would no longer emit tons of methane, a greenhouse gas 32-times stronger than CO2.
7. What are the implications to court rulings?
Breaching would satisfy the rulings of five federal courts over two decades. Waiting for a new Biological Opinion would delay any improvement in survival of salmon or orcas for a minimum of 5 years and more likely at least ten years. There are no current court rulings barring the use of the existing 2002 EIS
(See Alternative 4).
8. What is the current NEPA process and timeline?
The ongoing process does not affect the USACE’s obligation to implement Alternative 4 (dam breaching) in the 2002 EIS, as the dams are financially insolvent. Therefore, the current NEPA process does not preclude immediate dam breaching. Rather, the current governing EIS requires breaching as all other alternatives have failed. Alternative 4 of the 2002 EIS can be supplemented in a matter of months, and the U.S. Corp can adopt a new Record of Decision. In February 2016, experienced engineers, biologists, and economists supplemented Appendix D (Natural River Drawdown Engineers)
of the 2002 EIS. Breaching can begin THIS year, starting with Lower Granite and Little Goose, and most importantly - it is essential for the So. Resident orca who need more salmon ASAP.
The claim that "100,000 jobs depend on them. A congressional committee is coming to Pasco to see if they’re worth saving" (Tri-City Herald, Aug. 29, 2018), is false. According to the US Army Corps of Engineers: LSR Study/Appendix_I.pdf
more jobs will be gained by breaching than lost by a wide margin.
"Table ES-14. “Short-term Employment Impacts under Alternative 4—Dam Breaching (jobs)” predicts an increase of 20,821 short term jobs in the resource area. (I EIS-23).
Table ES-15 predicts a net decrease of 1,372 long term jobs in this subregion, less than 1% of the jobs in this area. (I EIS-23). The jobs provided by a thriving recreation community would replace any jobs lost by breaching. Long-term jobs as a result of breaching are not mentioned, but include robust fishing and recreational opportunities as well as resurgent agricultural economies, and cultural revitalization among Tribes and other developments when hundreds of acres of rich bottomland along the 140 miles of Snake River currently under reservoirs become habitable again.
Logistically and legally the dams could begin to be breached this year. But not politically because there's a massive, inert, slackwater of conventional belief that it would take a long time, which is the only real reason it would take a long time. It's a classic self-fulfilling prophecy. These orcas can't wait that long.
Hope for Orcas - Alt. 4 Summit
An evening with orca researcher Ken Balcomb and an urgent call to action.
The Burke Museum (UW-Seattle Campus)
Friday, September 7, 2018
6 p.m. - 10 p.m.
Hosted by Howard Garrett
Our southern resident killer whales (SRKW) are the iconic species of the Pacific Northwest and have been interconnected with local people for thousands of years. But their survival is now in peril. Their main source of food, Chinook salmon, has declined so much that these orcas are literally starving to death.
Join us for an evening with one of the world’s leading experts on the southern resident killer whales and their current situation. Our experts will dispel myths and discuss our best chance to recover wild Snake River salmon runs & help southern resident killer whales in 2018. Following our speakers, an educational exchange between groups, stakeholders, government agencies and officials will be held to encourage a frank conversation about the pros and cons of the topics discussed.