This draft Salmon BiOp falls well short of progress in the restoration and recovery of imperiled wild Snake River Basin salmon and steelhead and it will be challenged successfully in court should it not be drastically changed between now and January 1, 2014. In short, I am extremely disappointed in the effort that has been put into this plan.
If you are going to direct people to a website called salmonrecovery.gov then the plan you release had better offer a plan for recovery rather than a plan for mitigation, which is what this plan is.
First off, the endangered or threatened wild salmon and steelhead of the Columbia/Snake river basins need those agencies charged with their restoration and recovery to actually approach any plan with the goal of restoration and recovery of the imperiled stocks of fish. This plan makes it clear you are not approaching this problem in the appropriate manner. You are simply trying to squeak by with mitigation for the hydrosystem and you give no agency, yours or agencies who are actually interested in recovery any chance of success. You've failed for 20 straight years, you need something new, this plan isn't new. You must approach this with idea of successful restoration and recovery for our wild fish.
You are not doing that in any shape, manner or form. If you were at all serious about restoring and recovering these populations of fish you would take a macro view of what these fish need, like the successful doctor who looks at the body scan and addresses all of the problems, especially the most pressing problem. You have not done that with this plan. Your patient has come to you with massively blocked arteries (blocked for almost 40 years now) and you are handing your patient bandages for skin abrasions, the same bandages you've been handing out for 20 years.
Wild salmon and steelhead require habitat improvements in not just their spawning and rearing waters and in the estuary, they require migratory habitat be restored. I applaud your spawning and rearing water restoration work, but if you do not, as you haven't, address the migratory corridor, then these spawning and estuary improvements will not help in wild salmon and steelhead recovery.
Again, this plan does not address migratory habitat appropriately. In fact, this plan takes a huge step back with less spill and new triggers that could decimate outgoing and incoming salmon after August 1. Why would you work so hard to have hatchery runs of fall chinook (currently the highest since counting began at Bonneville Dam in 1938) if you plan to give them hot water for the years 2014-2018 so some poor performing dams can produce a small share of their capacity during this time of generally low water? The main problem exists in the migratory corridor, the hydrosystem. Failure to acknowledge this doesn't make the problem go away.
This plan also, as all plans have, fails to adequately tackle the "unknown" ocean years. We know more about these fish in freshwater (except in key places that if we had proper arrays set up, your hydrosystem survival theories would be blown out of the water, your hydrosystem begins killing them when the slackwater begins, so your so-called survival through the hydrosystem improvements do not impress me. Anyone can change the parameters and claim success) Anyway, we put more electronics into these fish (than are housed in a Best Buy stock room) wild and your pets from the concrete runs and you are going to waste another five years telling us you lose track of them 30 days after they are in the ocean? You are also going to tell us you conveniently can't account for how many actually die in the river system before their first reservoir and how many die in the first reservoir before going over or through the dam. I fail to see how, beyond willful resistance, that you NOAA and the action agencies refuse to put in place the proper sensory arrays to track these fish that are loaded to the gills with electronics throughout their habitat. Who knows, you might even be able to use that information to buoy your hydrosystem arguments.
Are you going to continue to waste taxpayer and ratepayer money studying hatchery fish, which are not even in the conversation when it comes to restoring and recovering WILD salmon and steelhead? They are not the same fish and yet you study them some tenfold more than you study the wild fish. Also, change the website with the counts to include a count of natural/wild chinook and sockeye. If you can do that for steelhead then you can do it for chinook and sockeye. It's important information that people need to see that way when they see wild fish make up no more than 20 percent of the run, perhaps they might be rightfully alarmed rather than happier than a camel on Wednesday that they get to fish for hatchery fish shoulder to shoulder for three days in July.
You have no study of lower Snake River dam removal. Why is it not in there? It has to be in there? Retired Judge Redden, before he retired, was crystal clear about that in 2011. Now, I know, knowing your poor record in court, but even with a new judge, courts tend to work off precedent and previous orders and they follow the law (can you do that this time?) and when you ignore them you will continue to be beaten in court. This is why I know you are not serious about restoring and recovering these fish. You profit from these fish remaining as endangered or threatened. Is it a half billion dollars (tax and rate dollars) spent each year on your (NOAA and the so-called action agencies) anemic effort for the past 20 years or is that just how much money the Bonneville Power Administration pays each year to not recover salmon? And you've never had a plan pass the muster of the federal courts and you dare put up a plan that doesn't even meet your previous illegal plan!?! In some small way you work for me and your are failing me and 320 million other Americans enormously. Not to mention you are failing mankind and it goes without saying just how much you are failing wild salmon and steelhead and the 137 species that rely upon them for survival.
Maybe, and likely, you have brought forth this inadequate plan simply because you believe a new judge will approve your never-ending inquiry into how we can keep a species on life support while those tax and rate dollars continue to fund the cottage industry from which you and others profit. It is irresponsible for any government agency to invite lawsuits with your plans. It is egregious to invite lawsuits where you have a high probability of failure. You know this plan is DOA in the federal courtroom and yet you have put it forth!?!
If you were serious about restoring and recovering our soon to be extinct stocks of endangered and threatened wild salmon and steelhead, you would have put forth a more serious plan for the next five years.
Salmon and steelhead aren't some minnow with an extra gill raker only occupying twenty yards in some natural wetland in some farmer's field that some graduate assistant discovered three weeks ago, they are a keystone species that impact the life cycles of 137 other species in the Pacific Northwest (including us) and you continue to play Russian Roulette with their existence. I don't get it.
You have not made any mention of helping facilitate a collaborative effort that could get all stakeholders invested in an actual restoration and recovery plan for our wild salmon and steelhead. This is a terrible omission.
This BiOp is an opportunity to actually begin restoring and recovering these great fish in our generation rather than what you have put forth here that will ensure that this generation will have the dubious honor of being the last generation to see the last of the wild salmon and steelhead in the Snake River Basin.
This plan reeks of a bunker mentality present with NOAA and the action agencies. It is obvious NOAA and the action agencies believe they have all the answers and no one else has anything to offer. You lose so often in court, one would think that eventually you might get it and ask those who beat you every time out what it is you should be doing differently, but you don't. You keep trudging out the same old turd while you tell us it is a cupcake. Look I understand that any fiscally responsible approach with a successful outcome (actual recovery and restoration of wild salmon and steelhead) is falling on the deaf ears of federal bureaucrats (your partners at the Corps waste $16 million on a draft sediment plan that has been scrapped in hopes your script doctors can resurrect it, meanwhile they spend billions over on the Ohio River on a dam that has nothing to show for it after 25 years beyond a concrete section sitting on the bank) So I know the idea of being fiscally responsible, removing dams that are easily replaced on the energy production side and not worth keeping for irrigation, transport and recreation and actually succeeding at restoring and recovering salmon is a foreign idea to all of you. Wild salmon and steelhead are far too important, so either get out of the way or get with the program.
I read your habitat improvement projects and great, those will help, but tributary improvements without migratory habitat improvements or estuary improvements without migratory improvements and you're simply rolling the boulder up the hill to watch it roll down again Sisyphus. Another thing this plan does not address and it is very important that you consider and address it. In the implementation plan that was released earlier, there were some barriers being addressed, I assume removed or improved for fish passage, anyway one caught my eye because it was on the East Fork of the South Fork of the Salmon River and while it is good that this plan will address three barriers for the benefit of the wild, sorry natural, fish, this plan is silent on various things such as a huge gold mine on that river that plans to place one mile of that stream, actually eight-tenths of a mile, into a pipe for more than a decade, which can't be good for wild salmon. I wonder how many other places have competing uses that will negate any habitat improvements that are in this plan. You need to identify these potential threats, because I am sure there are more out there. I saw no reference to potential multiple use threats listed and that must be a part of this plan.
Various actions that are ongoing such as bounties for pikeminnow, harassing and killing sea lions, the Corps' comical studies and relocation involving terns and cormorants in the estuary are simply diversions, and you know they are, to actually confronting the real problem head on. Barging smolts, admits the problem is in the hydrosystem and yet since it is a program it apparently will be green lighted in perpetuity and that's great for federal employees and contractors, but it does nothing for our imperiled fish, beyond confusing and killing them. All of these programs point to an insanity embedded in this "effort." Let's work toward actual restoration and recovery and stop creating strawmen (sea lions, terns, cormorants) when we know who the true culprit is in the salmon decline.
This plan should have more spill than it calls for at the very least. This plan should not have any early spill cutoff triggers. Asking nature to meet arbitrary quotas has no scientific basis behind it and will only allow the poor performing hydrosystem that time of year to determine the fate of entire runs of fish that might simply be a week or two later than "normal" as if these fish have calendars and clocks. This plan has to have a serious study of lower Snake Dam removal including economic analysis where the public is given actual figures for the costs of these dams and the actual revenues their existence supports. The ports that are all heavily subsidized and do not justify their existence in any serious economic analysis should also be included in this economic analysis giving citizens the actual cost benefit ratios at play here. This shouldn't be the responsibility of a guy in Kooskia, Idaho, who is doing a great job pointing out just how poor these ratios are.
This plan has to have a collaborative process plan that creates the framework for how all stakeholders in salmon restoration and recovery go forward to come to an actual solution. This plan needs to study hatchery fish less and wild fish more. As a rule, we really don't need to continue to study the hatchery fish, these studies do not aid us in solving the problems of wild fish. Your band-aid approach to habitat improvements was inadequate in 2011 and is inadequate again today. You have no framework for addressing other uses that would negate any habitat improvements you have planned and therefore you need to get back to work identifying potential threats that are likely to happen due to the Mining Law of 1872 having supremacy and the uptick in mining operations throughout these river basins that hold salmon. You cannot ignore the migratory habitat to the extent at which this draft plan ignores it and expect success simply by going to the tributaries. The fish have to get to and from the tributaries and we need a 2-6 percent SAR and you've never come close to that number. You certainly cannot say you've ever had that number eight consecutive years, and therefore you have put forth a plan that is doomed to the same failures you've been constructing for 20 years. Change it.
Get back to the drawing room, as it stands now, this plan is a non-starter.