Guidance for Sportsmen Commenting on the Columbia River Draft EIS
The recently-released Draft Environmental Impact Statement on Columbia River System Operations will have serious consequences for the future of Idaho’s salmon and steelhead. The Draft EIS perpetuates the status quo and completely ignores the far-reaching economic impacts the salmon and steelhead fishing industry has in rural Idaho and other Northwest states. Rather than using this chance to make meaningful changes to prevent the extinction of our fish, the federal action agencies have decided to kick the can down the road once again.
It is imperative that Idaho’s sportsmen and women speak up during the EIS process to let the government know the current analysis and preferred alternative are unacceptable. The best way to do this is by submitting written comments to the CRSO website before the deadline of April 13th. Below is a helpful guide to commenting with suggested language you can copy and paste directly into your comment.
Make sure the action agencies hear us loud and clear: We want our fish back.
Guidance for Commenting on Columbia River System Operations
Draft Environmental Impact Statement
The federal government recently released a Draft Environmental Impact Statement for the operations of all hydroelectric projects (dams and waterways) on the Columbia and Snake Rivers. This Draft EIS is a critical piece in the recovery of Idaho’s declining salmon and steelhead runs because it describes key actions that will impact our fish populations over the next 30 years.
All public meetings on the Draft EIS have been cancelled and replaced with nationwide conference calls due to the threat of COVID-19. It is more important than ever to submit written comments online before the deadline of April 13, 2020. You can submit your comments at https://comments.crso.info/. The Draft EIS is almost 5,000 pages; you can access the executive summary through the CRSO website (link above) or view a summary PowerPoint through the Governor’s Office of Species Conservation at https://species.idaho.gov/governors-salmon-workgroup/ (click on Nampa meeting materials).
Tell the Action Agencies that the Preferred Alternative is unacceptable because it does not result in Smolt to Adult Return rates approaching 4%.
Suggested language: “The Preferred Alternative in the Draft EIS does not adequately provide for salmon and steelhead populations because it will not improve smolt to adult turn rates (SARs) to levels identified by scientists as necessary for harvest or recovery. Harvestable populations need a SAR around 4%, meaning 4 adults return for every 100 juvenile fish that head to the ocean. Under the Preferred Alternative, SARs for Snake River spring Chinook will reach 2.7% at best. The predicted SAR is even lower for Snake River steelhead at 2.4%. At worst, The Life Cycle Model predicts an extinction trajectory under the Preferred Alternative with a SAR below 1%. I do not support the Preferred Alternative, or any other alternatives, that continue to contribute to the extinction of salmon and steelhead.”
The Draft EIS did not take into account the economic impacts of the Northwest’s salmon fishing industry.
Suggested language: “When evaluating the economic impacts of each alternative, the analysis completely ignored the sportfishing economy and it’s estimated contribution of over $757 million in Idaho alone (over $2 billion region-wide). The Draft EIS relied on a qualitative, rather than quantitative, analysis to evaluate impacts despite the existence of several current studies on the economic contributions of outdoor recreation and sport fishing in states with salmon and steelhead. This is in contrast to water supply, irrigation, navigation, and hydropower generation, which were all evaluated quantitatively. It is unacceptable that the Draft EIS did not use publicly-available data sources to quantify the devastating financial impacts of declining salmon and steelhead populations on rural communities in Idaho and the Pacific Northwest.”
The following two slides summarize predicted annual smolt to adult return rates (SARs) for Snake River spring Chinook and Snake River steelhead evaluated by two models under each alternative presented in the Draft EIS. The Preferred Alternative is only expected to produce SARs between 0.81-2.7%, depending on the model evaluated. These slides were presented by the Action Agencies to Idaho Governor Little’s Salmon Workgroup on March 5, 2020.
This slide shows that the economic impacts of sport fishing were not quantitatively assessed by the Action Agencies in the draft EIS, despite the availability of economic data and the substantial impacts each alternative can have on rural, recreation-based economies. According to Kelly Baxter, an economist at the Army Corps of Engineers, these “effects were outside the scope of the EIS,” despite the fact that these effects were quantified for every other resource evaluated in the analysis. This slide was presented by the Action Agencies to Idaho Governor Little’s Salmon Workgroup on March 5, 2020.
