On April 14, 1999, the National Marine Fisheries Service (NMFS) issued "An Assessment of Lower Snake River Hydrosystem Alternatives on Survival and Recovery of Snake River Salmonids".  As usual, the document is biased in favor of dam breaching, although less so than reports from the PATH process.   Members of the public are encouraged to ask the following questions about the report at public meetings.  The page numbers in the questions refer to a version of the report downloaded in Acrobat format from http://research.nwfsc.noaa.gov/afis/afis.pdf

Questions About NMFS' April 14, 1999 Report:

"An Assessment of Lower Snake River Hydrosystem Alternatives on Survival and Recovery of Snake River Salmonids"

1. Why does NMFS applaud the "flexibility and openness" of the PATH process (p. 11) when the participants have refused to disclose details of the computer models to each other and refuse to answer questions from the public?

2. Why does NMFS say that an "instructive analogy" is to compare the dams and salmon to a patient who needs bypass surgery (p. 18)? Isn't this proof of bias, in that NMFS assumes that four dams where the salmon spend a few days are at the heart of the problem for a species that lives upwards of five years?

3. What evidence does NMFS have that higher water temperatures from dams cause salmon mortality (p. 21 (citing nothing)), when the dams reduced peak water temperatures in the Snake River?

4. What evidence does NMFS have that overall predation rates on juveniles are higher because of the dams (p. 22 (citing nothing))? Indeed, given that the only empirical evidence suggests that predator densities and consumption rates are higher in the free-flowing Snake River than in the reservoirs (p. 63), why does NMFS believe it is appropriate to have each and every model runs assume substantially higher survival in a free-flowing Snake River than in the reservoirs?

5. Why is NMFS still citing the Sims and Ossiander (1981) study linking flow and survival and the Raymond (1979) study (p. 23) when its own researchers have criticized the study as outdated and inaccurate, and recent data shows no relationship between river flow and salmon survival? Why doesn't NMFS cite this new data in the discussions of flow and survival (e.g., p. 28)?

6. Why is NMFS unwilling even to consider the possibility that the strong flow/survival relationships built into the PATH models are wrong, and predict survival benefits for dam removal through reduced smolt travel time that will not really be achieved?

7. Why does NMFS cite literature reviews of 47-year old studies of turbine mortality (p. 26) instead of citing 1990s balloon-tag studies showing lower turbine mortality?

8. Why doesn't NMFS ascribe any benefits to the Snake River dams from preventing lamprey, walleye and other introduced predators from colonizing the Snake River? (Cf. p. 37 (citing improved migration conditions for lamprey)

9. What prior experiences with dam removal support NMFS' assertion that the risks posed to salmon population from massive releases of sediment during a multi-year period of dam removal will be minimal and "relatively short term" (pp. 37, 103)?

10. How can NMFS claim that dam removal will significantly reduce mortalities to migrating salmon (p. 37) when NMFS has no idea what fraction of the mortality in the Snake River reach is actually caused by the dams?

11. Why is a "dynamic, alluvial river system" (p. 37) that is constantly scouring out salmon nests necessarily better than a river managed to provide constant spawning channels for salmon? Why isn't this considered as an alternative in any of the salmon recovery processes?

12. Why doesn't NMFS consider improvements to the transportation program as an alternative to dam removal, particularly when salmon ranchers have shown that transportation past birds in the estuary could yield dramatically greater adult returns?

13. Why does NMFS believe that dam breaching will produce "more riparian vegetation" and insects for salmon food (p. 42) when historical photographs of the Snake River show little or no vegetation?

14. Since we going to have to build "fish passage structures" to get salmon through the breaches in the dams (pp. 42, 103), why does NMFS think that these are going to be any better than fish ladders?

15. Why does NMFS resort to saying that "scientists differ" (p. 45) about the accuracy of so-called delayed transportation mortality, instead of figuring out which scientists are right? Aren't the newer estimates, with lower "delayed mortality", better estimates?

16. How can NMFS declare that "there is wide consensus that the life-cycle models provide a sound currency with which to analyze salmon survival and recovery" (p. 47) when the only part of the life-cycle models that has been developed in detail is the modeling of survival during the weeks the salmon spend going through the dams?

17. When fin-clipped salmon and steelhead are sold in Far East markets and drift nets wash up on Northwest beaches, how can NMFS be confident that harvest rates on spring chinook and steelhead are small or "effectively non-existent (pp. 51, 78)?

18. Why didn't NMFS correct PATH's assumption that removing the Snake River dams would produce 50% more adults, when NMFS declares that survival would only increase from 85 to 97%—a 14% difference (p. 52)? Does NMFS agree with PATH's conclusion that only 3% of adult Snake River salmon would die while migrating up 139 miles of a natural Snake River? Given that radio-tagged adults apparently migrate as fast up the Snake River as salmon ever did, why does NMFS believe that adult survival would increase at all from dam removal?

19. Why does NMFS claim that the CRiSP and FLUSH models will "generate very similar predictions" if delayed mortality is treated the same (p. 54) when the models have very different flow/survival relationships? Isn't it true that FLUSH underpredicted survival in 1998 by a factor of two? Why doesn't NMFS present some model estimates to back up its assertions? Isn't it really because NMFS is not capable of running the model because the States and Tribes haven't made the materials available to do so?

20. NMFS declares that older, higher estimates of so-called "delayed transportation mortality" have merit because more years of data were involved (p. 57), but isn't it true that we don't have reliable survival data for the older years—just model predictions?

21. NMFS declares that one "simple hypothesis" is that "because fish migration is potentially more stressful, the fish entering the ocean are not as 'vigorous' as they would be if they did not have to proceed through the hydrosystem" (p. 59). Does anyone at NMFS have a good explanation why fish would die faster months or years after they pass the dams just because they passed the dams? Has anyone anywhere ever measured such long-term effects of transitory stress on fish?

22. Given that NMFS knows that spill mortality is greater than 2% at some projects (e.g., The Dalles), why didn't NMFS correct the PATH assumptions that spill mortality was 2% at all projects (p. 60)?

23. Since NMFS admits that all estimates of "direct survival" of salmon—survival over the river reach—are higher under present operations with transportation than with dam removal (p. 63), aren't NMFS' conclusions that dam removal is better for salmon based on pure speculation that dams or transportation are somehow killing fish in the estuary or ocean?

24. In attempting to assess the survival of adults upriver, why does NMFS take no account of unreported harvest (pp. 68-69), and overlook data that suggests that the number of "missing adults" is strongly correlated with the level of reported harvest?

25. Given that juvenile fall chinook salmon suffer greater losses rearing in the free-flowing Snake River than in the reservoirs (p. 69), why does NMFS complain about "high mortality" in the reservoirs? Why does NMFS ignore papers by Dr. Chapman and others that suggest that reservoirs may provide a superior habitat for juvenile fall chinook to rear than a free-flowing river?

26. Why does NMFS continue to use a value of 1.0 for spill effectiveness (p. 71) when every study that has ever been done has shown that spill effectiveness is greater than one? Given risks posed to salmon posed by dissolved gas, isn't it irresponsible for NMFS to continue to overestimate spill requirements (wasting millions of dollars) by using numbers for spill effectiveness that are too low?

27. How can NMFS purport to offer information about dam breaching as a salmon recovery alternative while analyzing only incremental changes in harvest of endangered salmon—for example modeling only 15% changes in the substantial ocean harvest of Snake River fall chinook (p. 73)?

28. What historical evidence supports the claim that large numbers of fall chinook salmon used to spawn in the areas currently inundated by the Snake River dams (p. 75)? Isn't it true that the vast majority of the fall chinook proceeded further upstream?

29. Why does NMFS believe that recreating a natural river will increase spawning habitat for fall chinook "on the order of 70 to 80%" when the habitat is already there, in that fall chinook already spawn in the reservoirs?

30. Why does NMFS' discussion of the dam breaching alternative and effects on steelhead omit any reference to the fact that steelhead enjoy even greater benefits from transportation than salmon (so that the steelhead would suffer more than salmon from the loss of transportation under dam breaching)?

31. Given that several of the "index stocks" of Snake River spring/summer chinook salmon have been at low levels for nearly twenty years, on what basis does NMFS conclude that low numbers mean a "peril of extinction over the short term" (p. 93)? Why does NMFS discuss extinction risk without any citation of studies that indicate almost no risk of extinction of the total Snake River spring/summer chinook salmon "ESU" listed by NMFS?

32. Why does NMFS consider dam breaching to be "reversible", while the extinction of some stocks of Snake River salmon is "irreversible" (p. 101), when salmon are frequently observed to re-colonize after "extinctions"? Isn't it more likely that salmon would disappear from a tributary of the Snake and then reappear than that Congress would vote to remove the dams and then to put them back in?

33. How can NMFS claim that "science does make it clear that breaching is the most risk-averse management option" (p. 105; emphasis added) when the only empirical evidence suggests that juvenile passage survival will be lower after breaching because of the abandonment of the transportation program?

gbstripe.gif (1558 bytes)

Return to Other Salmon Materials

Return to www.buchal.com