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"Killing more sea lions is not a solution to recovering salmon or preventing their extinction"
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| Sea lions are being scapegoated & shot for collapsing salmon populations when the primary culprits are dams |
Immediate breaching, starting this year, not only benefits all the endangered harvesters; whether they be sea lions, killer whales, birds; tribal, commercial or sport fisherman; or farmers, but also add thousands of jobs to the region and saves tax/rate payers money.
DamNation Film Can Be Viewed Online & Features Jim Waddell
To avoid the most obvious, cost effective, economically viable and by far the best environmental choice, the Corps of Engineers has spent $2 billion on fish passage "improvements" on the four lower Snake River Dams (LSRDs) that a $33 million Feasibility Study and Environmental Impact Statement (EIS) in 2002 said was...
"Less effective than doing nothing"
The Corps does not have enough Operations & Maintenance money to maintain this massive investment which in turn causes more mortality than if they had done nothing. The ever smaller numbers of fish are making habitat investments pointless (a fact that the habitat proponents are only now waking up to). Ever smaller runs and declining genetic diversity makes recovery exponentially more difficult with every year that breaching is delayed.
The overall spiraling loss of biomass into the Columbia/Snake is crashing the ecosystem from the micro biological food webs in the headwaters of Idaho to the lack of primary prey for endangered killer whales to loss of fisheries in the northwest Pacific Ocean
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| Endangered Southern Resident orcas. Photo Jeffrey Ventre #Superpod2 |
All this on top of the Corps failure to meet the fundamental federal objective Congress expected when the dams were authorized. That is, the National Economic Development benefits must exceed the cost of construction, operations, maintenance and repairs. These four dams never did and do not today.
Using the Corps own planning guidance and data, economist show the benefits to be only 15¢ on the dollar or .15 to 1. And this does not count the regional loss of thousands of jobs, indirect economic and ecosystems services benefits and higher power bills by the continued operation of these four dams.
#Superpod5: The Southern Resident Killer Whales & Chinook Salmon
This is the sordid truth that regional managers and leaders want to deflect from the public's view and elected leaders, especially those in the US Congress. The Corps and Bonneville Power Administration (BPA) is wasting ever more millions on these dams when it is much more needed on other dams and habitat programs.
We are using tax money to kill salmon
They also seem to revile in response to another federal judge telling them they have five years to come up with an EIS for the Federal Columbia River Hydro System. This is due to the federal agencies fifth failure to avoid a dam breaching decision on the LSRDs.
They, and other groups involved in the 25 years of litigation, have at least used this as an excuse to avoid discussions and actions for immediate breaching the earthen berms of the 4 LSRDs, in spite of plummeting salmon/steelhead runs and endangered Southern Resident Killer whales who depend on these Chinook runs for there survival.
The Federal and State agencies, most especially the Corps of Engineers, do not have to wait on another NEPA process that will take 5-10 years to, maybe, get to the answer they already have in the 2002 EIS and Record of Decision. This EIS is the NEPA coverage for ongoing mitigation actions on the LSRD and as affirmed by the Assistant Secretary of the Army for Civil Works, see attached letter. This EIS can be updated in just a few months because it already has breaching in it as the preferred environmental alternative.
Because the other non-breach alternatives in this EIS, used in an effort to improve salmon runs, have failed, this leaves breaching as the only recourse.
Further, since the BCR is well below 1.0 and current costs are more than power revenues meant to pay or repay the US Treasury for these costs, the Corps has a fiduciary responsibility to Congress and the American people to place these dams into a "non-operational' status.
To do so, would require removal of the earthen berm to stabilize each dam. This also restores a free flowing river around the dams' concrete spillways, power houses and locks allowing unhindered fish migration and opens 140 miles of spawning and rearing habitat. This breaching cost should be paid for by the BPA as "fish mitigation" in accordance with the 1980 Power and Conservation Act. The US Congress does not need to authorize or appropriate anything new. They should however be holding the Corps accountable and demanding immediate breach action instead of more studies of the LSRDs.I have attached a letter to the Chief of Engineers written in July of 2016 reminding him of these facts. A year has gone by and things have gotten worse for salmon, steelhead, orca, fishermen, and with HR2803, sea lions, but he has done nothing but say that they will consider breaching in this new NEPA process.
Thank you for giving me this opportunity to comment,
Jim Waddell
Civil Engineer, PE, USACE Retired
Port Angeles WA, 360-775-7799
