2013 FCRPS BiOp Draft Comprehensive Evaluation
The following comments were submitted in response to the open comment period described below.
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The Action Agencies - BPA, the U.S. Army Corps of Engineers and the Bureau of
Reclamation - have produced a draft Comprehensive Evaluation on their
implementation of NOAA Fisheries’ 2008/2010 Biological Opinion for operation of
the Federal Columbia River Power System for salmon and steelhead listed under
the Endangered Species Act. The draft CE is a retrospective look at the federal
agencies’ accomplishments under the FCRPS BiOp from 2008 to 2012, including a
review and evaluation of implementation activities and the expected fish
survival improvements from those activities. For more information, go to www.salmonrecovery.gov
For More Information:
www.salmonrecovery.gov
Close of comment: 8/16/2013
- FCRPS13 0001 -
KinzerSince the middle 1990's I've been talking to fisheries biologist and reading on this topic. It is very obvious that the real problem is in the ocean. When you have the survival rates to the ocean that we have today, and then have such a low rate of return, only people with an agenda would not admit that the ocean is the problem!!! We should monitor habitat, and balance the needs of man with the needs of salmon. However, all the habitat and dam improvement in the world will not work to improve salmon numbers if we don't move the worlds fishing fleet farther off our shore, and improve the feeding grounds on the continental shelf. The judge in charge should be non-biased and look at the "REAL" problem instead of the contrived problem of dams.
- FCRPS13 0004 -
Rien/Oregon Department of Fish and WildlifeThe attached letter and materials from Mr. Bill Bradbury, Oregon's representative to the Regional Implementation Oversight Group, provide the State of Oregon's comments on the 2013 FCRPS BiOp Draft Comprehensive Evaluation of progress toward implementing the actions required by the 2008/2010 Biological Opinion, as remanded in 2010.
View Attachment
- FCRPS13 0006 -
Meira/PNWAPlease see attached document for comment.
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- FCRPS13 0007 -
Saven/Northwest Requirements UtilitiesPlease see attached document for comment.
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- FCRPS13 0008 -
Levy/bluefish.orgPlease see attached document for comment.
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- FCRPS13 0009 -
Rich/CRTAPlease see attached document for comment.
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- FCRPS13 0010 -
Whitman/Nez Perce TribePlease see attached document for comment.
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- FCRPS13 0013 -
Mashuda/EarthjusticePlease see the corrected version of the comments previously submitted. Those comments inadvertantly omitted the Federation of Fly Fishers and Idaho Wildlife Federation.
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- FCRPS13 0014 -
PaceThis comment is provided in response to the a draft “Comprehensive Evaluation” that Bonneville Power Administration, the Army Corps of Engineers and Bureau of Reclamation for implementation of NOAA Fisheries’ 2008 Biological Opinion for operation of the Federal Columbia River Power System and the 2010 Supplement thereto. To minimize duplication, I join in and incorporate here by reference comments submitted by the Honorable Silas C. Whitman, Chairman of the Tribal Executive Committee of Nez Perce Tribe, and Mr. Bill Bradbury on behalf of the Governor Kitzhaber of Oregon (see Attachment A thereto), relating to the reliance on unsupported conclusions coupled with the presentation of selective and misleading information in the draft, as well as the failure by Bonneville, et al., to provide an accurate assessment of the precarious status and lack of demonstrable progress toward improving life cycle survival of key populations of salmon and steelhead when the best available science suggests they teeter on the brink of extinction. In addition, I would like to bring two significant omissions in the Comprehensive Evaluation to the action agencies’ attention. First, in the so-called “fish accords,” BPA agreed to draw down and divert in excess of $1 billion over the 2008-18 period for the fundamental and central purpose of removing the perspective(s) of tribal and state litigants from the purview of the District Court for the District of Oregon in Civ. No CV-01-00640 (National Wildlife Federation, et al, v. National Marine Fisheries Service) and in all other forums. The Comprehensive Evaluation fails to report on how successful the payment of such “hush money” has been, e.g., in stifling the ability of fisheries biologists working for the Columbia River Intertribal Fish Commission and Idaho Fish and Game Department from pursuing lines of inquiry or raising points of dissent that might be interpreted as counter to the agreement struck between signatories to the accords. Upon information and belief, the payment of hush money has been extraordinarily effective in silencing these tribal and state scientists and ensuring that what passes for science is supportive of biological opinions that were invalidated but remain in place thru January 2014. Second, the Comprehensive Evaluation fails to report on the actual operation of the Federal Columbia River Power System for power peaking, load following and integration of wind-powered generation, all of which create extraordinary fluctuations in forebay elevations and tailrace discharges. None of these impacts were addressed in the 2008 Biological Opinion for the Federal Columbia River Power System or the 2010 Supplement thereto. And there is no indication whatsoever that the Army Corps of Engineers, Bonneville Power Administration or the NOAA Fisheries has any intention of addressing the impacts of such day-to-day and hour-to-hour operations as part of a “new” biological opinion that is currently being prepared. Finally, as BPA, et al., will no doubt recall, when he invalidated the 2008 BiOp and 2010 Supplement, then-presiding Judge James Redden ordered the federal defendants to consider additional sources of water supply for anadromous fish for flow augmentation and spill, e.g., from reservoirs sited in the upper Snake River above the Hells Canyon Complex and from the upper Columbia River. I was unable to find anything in the Comprehensive Evaluation that suggested BPA and the federal defendants have made any effort to comply with this aspect of Judge Redden’s order.
- FCRPS13 0015 -
Flores/Northwest River PartnersPlease see attached document for comment.
View Attachment
- FCRPS13 0016 -
Evans/Inland Ports and Navigation Group
- FCRPS13 0017 -
Downen/Public Power Council
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