Hi James,

Once again, your forceful advocacy sparked my interest in a response. While I truly appreciate your perspective on the issues, I would like to not only address the CRI issues you raised but also pose an alternative theory as to where to find the waste in the salmon-industrial-process process. First, though, the standard disclaimer: my views do not necessarily reflect the views of the Columbia River Inter-Tribal Fish Commission.

You stated that the effect of CRI is to "replace centuries of Western water law with a Communist-style system of rationing designed gradually to grind away private water rights, so as to increase river flows in the mighty Columbia." The tribal perspective is that the CRI is not about taking private water rights, but about protecting the existing senior rights (which includes the 1980 instream flow right for fish), encouraging a system of conservation, and granting new rights to withdrawals on the mainstem while protecting adequate flows for fish.

You further state that "as to effects on fish, for twenty years, untold millions of dollars in federal and state funding has been shoveled into 'biologists' in a ceaseless quest to prove some sort of relationship between the river flows in the mainstem Columbia and salmon survival. All these efforts have failed."

There actually is a plethora of information that shows how fish need flow in a very complex and delicate system. Flow aids in migration timing (both outmigration and inmigration), temperature control, pollution dilution, and predator control, among other benefits. For example, studies have shown that the longer it takes for the fish to migrate, the lower their smolt-to-adult ratio. Studies have also shown that faster moving (rather than stagnant) water cools the summer hot temperatures quicker.

With regard to the NAS report, the panel itself was comprised of respected, capable and independent scientists. Moreover, the NAS report was a narrow review of specific issues furnished by Ecology and related to the management of water resources by the agency. In their preface they noted: "the State of Washington Department of Ecology requested the National Research Council to conduct a study addressing specific issues given in the Statement of Task provided in the body of this report. Our committee avoided the temptation to go beyond the tasks we had been assigned..." The NAS panel wasn't asked to review (or conduct) research on the flow-survival relationship; that was beyond the scope of the report.

Instead of using the CRI as an example of rampant waste in the system, I suggest you look elsewhere. You may recall that Senator Gorton, in 1997, called for comprehensive hatchery reform in that year's Energy appropriation bill. However, undermining this intent is the need to ensure that the state and federal fishery agencies' harvest management programs continue. What was begun in July of 1997 by what is now called the Northwest Power and Conservation Council (NPCC) has yet to result in hatcheries being reformed. I can assure you this process has done nothing but help maintain the status quo since it began in 1997. I still believe if the NPCC had taken us up on our offer to complete the congressional directive for one dollar by the June of 1998 deadline, we would be well underway implementing reform.

The solution is clear from the basin's successes; if you rear fish properly and use the right broodstock, as the tribes have advocated since 1982, hatchery programs can be improved and can contribute to rebuilding as is now occurring in the Yakima, Clearwater, Umatilla and other subbasins under tribal management.

I believe it may be time to once again remind the NPCC that this process has been ongoing since 1997 and little has been done other than more process. If the NPCC is serious about encouraging reform, then its members need to ask the federal and state fishery agencies whether they have modified their programs in the manner requested by and required of tribal restoration programs. All river interests need to bring agency directors to the public forum and have them explain why changes are not occurring and what should be done to correct the situation.

The NPCC needs to examine each of the agencies' hatcheries and see how many have modified their programs to implement programs like the tribes are implementing. For example how many programs follow the adult trapping and spawning protocols of the Yakama facility? How many follow the rearing programs using structures in the raceways or modified the raceways to mimic a stream or underwater feeding? These are programs the NPCC required in the tribally operated hatcheries because the agencies told them they were important. As we begin to seriously look at the agencies programs and not just listen to their happy talk, we will hear more talk rather than see action. As for funding to implement the changes, agencies are attempting to use BPA funds to modernize the Mitchell Act hatcheries that, since their inception, have been funded by federal appropriations. If ratepayer funds area used to modify these facilities then the NPCC needs to see real plans, not HGMPs that reflect little more than status quo operations. Where will they trap broodstock? How will raceways be modified? Where will releases occur? . . . In the habitat or some concrete holding pond? These questions should be asked of every facility.

I understand the Mobrand model (AHA) will be presented to the Fish Four next week. If they accept it I'm sure more money and time will be wasted as another modeling effort is implemented followed by no decisions.

Subbasin planning is another example of planning processes conquering the substance of salmon rebuilding. In 1987, what was then called the Northwest Power Planning NPCC initiated a $5 million, four-year process of subbasin planning that was intended to provide an integrated system plan as an amendment to the Fish and Wildlife Program. Though the agencies and tribes submitted an integrated system plan in 1991, the NPCC never acted on that plan which could have furnished the basis for recovery planning under the ESA listings that were announced later that year. Incidentally, one reason the plan was not adopted was because it contained a protocol for using hatcheries to rebuild naturally spawning runs that was derived from and provides the basis for successful tribal restoration and rebuilding programs.

In its 2000 Fish and Wildlife Program, we had another moment of déjà vu. Prior to the NPCC's decision to undertake another subbasin planning process, Bruce Lovelin and I (in an unprecedented display of cooperation at an NPCC meeting in Tacoma) argued that the NPCC only had to approve and implement the plans developed during the first process. Instead the NPCC initiated a second subbasin process spending another four years of planning at a cost of over $15 million dollars and, in this case, specifically instructed the planners not to include projects or budgets despite clear policy in the 2000 Program to the contrary. Now we have subbasin plans that are useless for the purpose of designing the BPA Fish and Wildlife budget or providing budgets and actions under ESA Recovery. A copy of the Commission's comments attached amplify this theme.

In both the areas of hatchery reform and subbasin planning, the salmon-industrial-process process provides the region with great expectations and little results. Whether you agree or disagree with what needs to be accomplished in the area of protecting, mitigating or enhancing fish and wildlife under either the ESA or the Regional Act, I'm sure you would agree that scarce dollars should not be used for planning that results in minimal outcomes without clear objectives.

As you may know, Dr. James Lannan, a renowned fisheries scientist at OSU, recently died leaving a legacy of profound thought about how this region could protect its wild salmon heritage. His arguments favoring the use of hatchery surplusses to rebuild runs contributed to the Alsea decision as well as to the education of Oregon legislators about stock restoration, rebuilding and recovery. In fact, there are a number of thoughtful and reasonable people who support these ideas; unfortunately, they do not seem to be the people who currently hold the keys to the salmon-industrial-process process. Perhaps you can assist us in taking the keys away and placing them in the hands where they belong.

John Platt

CRITFC