Select Area Fisheries Enhancement Project
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
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Bonneville is proposing to fund the SAFE Program to achieve maximum production levels of Chinook and coho salmon as proposed from three fishery co-managers (Washington Department of Fish and Wildlife, Oregon Department of Fish and Wildlife, and Clatsop County Fisheries) and as authorized by the National Marine Fisheries Service.
The SAFE Program would rear, acclimate, and release up to 4.25 million spring Chinook salmon smolts and 4.3 million coho salmon at four in-water net pen sites in off-channel areas (Select Areas) in the Lower Columbia River estuary located between river miles 10.0 and 27.0 (Figure 1). Eventually, these fish would return to these Select Areas for commercial and recreational harvest. Thus, the SAFE Program’s overall objective would be protection of natural origin salmon through reduced harvest pressure. Your comments will help BPA determine the issues that should be addressed in the environmental review.
For More Information:
http://www.bpa.gov/nepa/safe
Close of comment: 2/2/2024
- SAFE24240001 -
paceProviding fish for harvest in the lower reaches of the Columbia River is not allowed under the Northwest Power Act, which requires BPA ratepayers not be responsible for other parties; funding obligations that have nothing to do with mitigating the effects of the federal Columbia River power system. In addition to providing opportunities for commercial and recreational fisheries ten miles from the Pacific Ocean will likely provide increased harvest opportunities for terns and cormorants.
- SAFE24240002 -
paceI do not believe BPA funding for this proposal can proceed under the Federal Water Pollution Control Act, 38 U.S.C. 67 and 167; 1251 et seq., which prohibits discharging pollutants into navigable waters without a permit. Additional considerations are imposed by the constitutions, general statutes, and common laws of the states of Washington and Oregon. It is also unlikely that this proposal can be funded by Bonneville without violating the in lieu; provisions of the Northwest Power Act. Given these considerations, it would be imprudent for Bonneville to participate in this proposal. If, however, BPA moves forward with providing support, it should expect that it will be challenged and become the subject of extensive litigation. It would be foolish to embark on such a course of action.
- SAFE24240003 -
paceI am writing this second comment to ensure the BPA is aware of the Nov. 18, 2022, announcement by the Commissioner of Washington Department of Natural Resources banning net pen aquaculture in Washington waters. According to the news release, Commissioner Franz Ends Net Pen Aquaculture in Washington’s Waters and similar bans are in place in Oregon. Please see the link below:
https://www.dnr.wa.gov/news/commissioner-franz-ends-net-pen-aquaculture-washington%E2%80%99s-waters#:~:text=Commissioner%20of%20Public%20Lands%20Hilary,of%20Natural%20Resources%20(DNR).
- SAFE24240004 -
paceI am writing this third comment to ensure Bonneville is aware of a NOAA biop that found net pen aquaculture: (1) degrades water quality from discharged fish waste and other pollutants; and (2)reduces foraging production for juvenile and adult salmonids and other protected fish due to bio-deposits and contaminants Please see the following link to a news release by the Wild Fish Conservancy date July 19,2022: https://wildfishconservancy.org/new-federal-analysis-finds-puget-sound-commercial-net-pens-are-harming-salmon-steelhead-and-other-protected-fish/
- SAFE24240005 -
paceI am writing this fourth comment to ensure Bonneville is aware of the fact that under the permitting requirements of the Clean Water Act,,net pen facilities are considered to be point sources (40 CFR 122.24 and appendix C of 40 CFR part 122). EPA also produced effluent guidelines for the
industry in 40 CFR Part 451. For more information see the link below the Washington Department of Ecology website: https://apps.ecology.wa.gov/publications/documents/2206008.pdf
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