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IDFG, CRITFC Criticize A-Fish Appendix by CBB, Columbia Basin Bulletin - September 17, 1999

Two players in the Columbia Basin's salmon recovery effort have delivered unsolicited, and unkind, reviews of the draft Anadromous Fish Appendix prepared by the National Marine Fisheries Service.

Comments offered by the Idaho Department of Fish and Game and the Columbia River Inter-Tribal Fish Commission criticize the document's contents and many of its conclusions, as well as the process used to compile the information.

The document is intended as the biological appendix to the U.S. Army Corps of Engineers draft Environmental Impact Statement on their Lower Snake River Feasibility Study. The study is an attempt to assess the potential biological and economic effects of a variety of hydrosystem management schemes ranging from the status quo to dam breaching.

The release of a draft of the study is now scheduled for mid-December. NMFS is now at work revising the "A-Fish" appendix.

The federal agency requested comments on the document from the Independent Scientific Advisory Board, formed by NMFS and the Northwest Power Planning Council to provide independent scientific advice on issues related to fish and wildlife recovery.

The ISAB review is not yet complete. NMFS' lead scientist Peter Kareiva said he expects the revised A-Fish to be completed in November.

Though admitting that their comments were not formally solicited, the IDFG and CRITFC asked that their comments be reviewed and incorporated into the final draft A-Fish. Both were critical about the A-Fish development process, saying state and tribal scientists had been denied the opportunity to participate.

"NMFS' autonomous approach on A-Fish, and lack of technical review prior to release, left the state and tribal fisheries agencies little choice but to peer review the document in an open setting," the IDFG's Aug. 30 comments read. "This technical review is highly critical of NMFS' analysis of "D-values" and the implications drawn from this flawed analysis in A-Fish (Schaller et al. 1999a, Attachment A). This technical dispute could have been resolved prior to release of A-Fish if NMFS had been more inclusive."

Scientists from both CRITFC and the IDFG participated in the PATH (Plan for Analyzing and Testing Hypotheses) analyses of the hydrosystem options. PATH's product was used in development of the A-Fish, but used too selectively, assert the IDFG and CRITFC.

"The overall conclusion of A-Fish is that breaching the four lower Snake River dams is most likely to lead to recovery," wrote CRITFC scientist Earl Weber. "However, they add, the management implications of model results are unclear because the exact causes of mortality are not known. Therefore, they assert, there is a chance that continued transportation would lead to recovery.... In addition, NMFS suggests that substantial gains could be made by improving survival in areas unrelated to hydropower (i.e., the other H's: harvest, habitat and hatcheries).

"Both the uncertainty regarding the efficacy of transportation and the optimistic conclusion that improvements in other H's will lead to recovery stem largely from omissions of critical information, and a fragmentation of the included information. A lack of context and connectivity pervades A-Fish and is particularly acute when stocks other than spring/summer chinook are discussed. In short, A-Fish is narrowly focuses on certain modeling constructs and does not present a plan to save all listed stocks, or the information to do so."

The IDFG comments agree with an A-Fish portrayal of the natural river option as the most "risk averse" option for fish recovery -- the most likely to succeed under the broadest range of assumptions.

The state agency took exception, however, to the A-Fish statement that "there are plausible sets of assumptions under which breaching yields little or no improvement over transportation alone -- most notably if differential delayed mortality is assumed to be low for spring/summer chinook salmon, the advantages of dam breaching are not as compelling."

"NMFS uses this narrow assessment to derive justification of delaying long-term recovery decisions in order to continue studying these assumptions. The A-Fish infers that this delay may not substantially increase the risk to survival and recovery," according to the IDFG comments. "IDFG disagrees with these assessments for spring/summer chinook and believes this narrow approach is not scientifically defensible. In addition, this approach ignores risk to survival and recovery of Snake River sockeye, fall chinook and steelhead."

"An additional 5-10 years of research with status quo operations are unlikely to resolve the issue, contrary to the assertion in the A-Fish," the IDFG summarized. " 'D' is not a measurement, it is a model estimate with many assumptions. The combination of small numbers of wild smolts and low SARS limit the ability to estimate 'D' with precision, especially using PIT-tag groups that experience the same conditions as true in-river migrations. Even if 'D" could be estimated unambiguously, the research would not likely resolve the causes of extra mortality."

Weber likewise questions the reliance on 'D' values (delayed mortality of transported smolts relative to in-river smolts).

"By focusing on D values, NMFS overlooks more meaningful measures such as the highly accurate SARS and robust comparisons of upriver and downriver stocks. It is important, therefore, to examine the reasoning and evidence on which NMFS and the operating agencies place their belief that transportation needs further evaluation."

The real question, said the IDFG, is "Have smolt transportation, flow augmentation, dam alterations and operational changes compensated for the adverse biological effects created by the four Lower Snake River dams and reservoirs?'

"Obviously adults returns do not indicate the dams have been fixed. For NMFS to conclude the dams have been fixed requires compelling rationale and evidence for what is masking these benefits from being seen in adult returns. The A-Fish Appendix fails to provide this rationale or evidence and ignores the PATH "weight of evidence" analyses and upriver vs. downriver stock comparisons developed specifically to address these assumptions."