Policy Statements » Letters from the President:

Ms. Joyce Howard
National Marine Fisheries Service
525 NE Oregon Street
Portland, Oregon 97232

November 29, 2004

Re: September 9, 2004 draft Biological Opinion on the operations of the Federal Columbia River Power System

Dear Ms. Howard:

The Ecological Society of America (ESA), the nation’s professional society of ecological scientists, wishes to offer comments on the draft Biological Opinion (BiOp) for Columbia and Snake River Basin salmon and steelhead.

Restoring wild salmon and steelhead to self-sustaining, harvestable populations is a national priority and of great economic significance to the Pacific Northwest region.  The ESA is seriously concerned that the draft plan abandons recovery as an objective, and is unlikely to recover wild populations from risk of extinction, let alone restore healthy populations. 

In contrast to previous decisions, the new draft BiOp claims that the operation of the Federal Columbia River Power System (FCRPS) does not jeopardize protected salmon and steelhead, and requires only that certain proposed operations do not appreciably reduce survival.  It treats federal dams as immutable parts of the environment, yet this ignores the extent to which the dams have detrimentally altered the Columbia Basin ecosystems and contributed to fish population declines.  Dam removal and other aspects of ecosystem restoration should be considered as potential options for mitigation; otherwise, federal efforts are unlikely to recover endangered populations.

The ESA is concerned that the draft’s proposed actions instead rely on expensive strategies whose benefits to fish populations are speculative at best.  For example, it remains unclear whether the addition of removable spillway weirs or downstream transportation of juvenile fish will appreciably boost fish survival.  The BiOp should place greater emphasis instead on science-based restoration of salmon to their natural habitat.

Additionally, the draft BiOp gives undue weight to recent, relatively higher salmon returns in the Columbia Basin.  Although adult return rates have increased since 2001, this has been credited by scientists to temporary ocean conditions and not to management strategies.  There is no scientific justification to conclude that current restoration efforts are sufficient, or that they can be relaxed. 

In conclusion, a commitment to restoring self-sustaining harvestable populations of wild salmon and steelhead should be the cornerstone of federal salmon strategies.  The weight of scientific evidence points to the harmful impacts of FCRPS operations.  Hence, the total impact of these dams should be taken into account in any federal strategy.  The Ecological Society of America supports the impartial consideration of all available and scientifically sound options to recover salmon and steelhead populations, including but not limited to the removal of dams from the Columbia and Snake rivers.  We urge you to revise this draft to ensure significant recovery of the Pacific Northwest’s wild salmon and steelhead.


Jerry M. Melillo