1. Alex Craven, Our Wild America Organizer Sierra Club Seattle, WA

My name is Alex Craven and I live in Seattle, Washington.

For those who say this issue is not as simple as just removing the Snake River dams to restore fish – I agree. Clearly, that kind of status quo thinking is leading us - as a region – right back down the same road we’ve been on for decades. And the cost of the status quo is expensive: we’ve spent over 16 billion dollars to recover fish and have nothing to show for it.

What we need now – and urgently – is a new approach. We need to be willing to put forth ideas and create solutions that provide for communities, invest in agriculture and transportation, allow for reliable clean energy production in the region, provide for our sport, tribal and commercial fisherman, and recover salmon and steelhead before we push them into extinction.  

We should remember the experiment is not dam removal. The experiment was putting the dams in the river. We can see the impact on fish populations and we have an obligation to bring robust salmon runs back to historic and harvestable levels. The DEIS itself acknowledges the best way to do that is by restoring a free flowing Snake River. We must follow that science and make river restoration an essential piece of any long-term plan.

I want to stress that we are talking about the Snake River as an ecosystem that spans the Northwest.  Similarly, we need to craft solutions that involve and benefit everyone in that region. This DEIS is fundamentally incapable of providing those solutions - it is our charge to create them.

2. Joseph Bogaard, Executive Director Save Our Wild Salmon Coalition Seattle, WA

Good afternoon. Thank you for the opportunity to share my thoughts with you and members of the public regarding the CRSO Draft Environmental Impact Statement for Snake-Columbia salmon and steelhead and the federal hydro-system.

My name is Joseph Bogaard. I am the executive director of the Save Our wild Salmon Coalition. We formed in 1992, in response to the first of what became thirteen populations of Columbia and Snake River wild salmon and steelhead populations that are in danger of extinction due to the impacts caused by the federal hydrosystem.

SOS’ brings together conservationists, commercial and recreational fishing people and businesses, orca and clean energy advocates to work with others to protect and restore abundant, self-sustaining and fishable populations of salmon and steelhead in the rivers and streams and marine waters of the Pacific Northwest for the benefit of people and ecosystems.’

SOS will submit more detailed comments in a written format before the public comment deadline. For the purposes of this call-in opportunity, I want to make two main points – one that is focused on the process; the other focused on substance.

I want to make a few comments regarding the public comment period – its components and its timelines. There are very serious shortcomings to the current public comment process, given the very important issues at stake and the rapidly escalating public health emergency caused by the new coronavirus. People in the Pacific Northwest and across the country are worried, distracted, disrupted, and focusing heavily on the health of their families and their communities.

This process under the extraordinary circumstances we find ourselves must be modified to accommodate these unexpected developments. The public comment period must be extended and the public hearings that were cancelled must be rescheduled at a later date when the public health crisis has passed and people can participate fully and safely.

On the substance side, I would like to make several brief remarks. The CRSO Draft Environmental Impact Statement and its Preferred Alternative is inadequate to meet the needs of endangered Columbia-Snake River Basin salmon and steelhead populations, Southern Resident orcas and Northwest communities. The DEIS perpetuates a status quo marked by continuous litigation, high costs, uncertainty for all involved, and that has brought Snake and Columbia river native fish populations to some of their lowest levels on record.

Continuing with this type of approach seems certain to fail all over again.

Columbia and Snake River salmon and the people of the Northwest and nation require a dramatically different approach that protect and recovers abundant salmon populations, invests in healthy Tribal, fishing and farming communities, and supports a reliable, affordable and increasingly carbon-free energy system. The way forward will require the leadership and engagement of Northwest policymakers – Governors and Members of Congress – working with stakeholders, sovereigns citizens to develop and deliver a comprehensive solution meets the needs of endangered salmon and steelhead, feeds starving orcas, invests in healthy communities and an affordable and reliable energy system.

Thank you for this opportunity to share these comments with you today – and for your careful consideration.

3. David A. Cannamela, Retired Scientist Idaho Fish and Game Boise, ID

The people of the Pacific Northwest and Americans-at-large will determine fate of Snake River salmon, Southern Resident Killer Whales and everything in between. It will not be the DEIS. The DEIS, despite the incongruity between what it identifies as the solution and the preferred alternative recommended, reaffirms what we already knew: the only way to restore salmon, steelhead, Pacific lamprey and the cultures, economies, ecosystem and livelihoods they support, is to restore free-flowing conditions in the lower Snake River. Secondly, the authors identify the real impediment to salmon recovery; reaching agreement among stakeholders that affordable energy and commodity transportation can be maintained without the four lower Snake River dams.

The authors could have and should have stopped at delivering the salmon solution. Instead they decided for us, that we are unwilling and unable to collaborate to solve the fish, energy, transportation equation. Several decades and $17 billion later, that’s billions with a B, with no glint of recovery in sight, I’d say that the only thing the federal government is solving for is the x-intercept for salmon, orca and the lives that depend on them. What would you say?

In essence, the federal government has concluded that, given a choice between salmon extinction and collaboration, we would choose extinction.

Fortunately, they are wrong. Political leaders in the region, namely Congressman Simpson and governors Brown and Inslee along with a host of stakeholders including the Tribes, energy cooperatives, outfitters and guides, sport and commercial fisherpeople, the Port of Lewiston, conservation groups and individuals who have a stake of their own, have put things in motion. And if history has shown us anything, its that the river never will give up.

Wendell Berry put it this way: “Man may dam a river and say they have created a lake, but it will still be a river. It will keep its nature and bide its time, like a caged animal alert for the slightest opening. In time, it will have its way; the dam, like the ancient cliffs, will be carried away piecemeal in the currents.”

And like the river, neither the fish nor the people will ever give up.

The Kennebec River, held in a choke hold for 162 years, showed remarkable rebirth following liberation: Likewise for the Elwha, White Salmon, Rogue and 1500 other rivers in this country- including three in Idaho. People made that happen!

Sadly, the DEIS, like the documents before it, serves to expedite extinction rather than promote recovery. But it matters not, because “We the people” will have the final say. We will as Congressman Simpson said “stay alive long enough to see salmon return to healthy populations in Idaho.”

4. Teri Wright, Orca Conservancy

First, I would like to stress that the comment period during this coronavirus pandemic needs to be extended or rescheduled. Wading through the more than 5000 pages of the draft environmental impact statement in order to offer thoughtful comments is challenging in the best of times. These are not the best of times.

That being said, the recovery and restoration of west coast rivers is key to the survival of SRKWs, and addressing the threat of prey abundance is a priority in recovery plans for this critically endangered population. The “preferred alternative” of increasing spill put forward in the draft EIS is merely a stop gap measure, intended to buy time until a true alternative could be identified and implemented.

Orca Conservancy firmly believes the restoration of the Snake river is vital for preserving our salmon and our Southern Residents. We must continue the discussions that have been started between stakeholders to address and ensure the wholeness of each affected community, not only on what this will look like without the Snake River dams, but how to get to that point.

We applaud Representative Mike Simpson when he recently responded before the House subcommittee on Energy and Water Development, and Related Agencies stating “that in the next 15 years, if something isn’t done, they (meaning the salmon) will be extinct. Those dams produce 3,000 megawatts of power. You can produce (power) differently. Everything we do, we can do differently. Salmon need one thing — they need a river.” Orca Conservancy would add to his comments that Southern Residents need Chinook salmon and this is why we support breaching the Lower Snake River dams.

In November of 2005, the National Marine Fisheries Service (NMFS) issued a final ruling listing the Southern Residents as endangered under the Act. As the National Marine

Fisheries Service acknowledged, “new information … confirms that … [S]outhern [R]esidents spend substantial time in coastal areas of Washington, Oregon and California and utilize salmon returns to these areas.” These coastal waters are recognized as an essential foraging area for this critically endangered population in the winter and spring. Southern Residents are dietary fish-specialists and depend on abundant populations of Chinook salmon for their survival. After over a decade of federal protection, the population has yet to show any signs of recovery. When we submitted our scoping comments in February 2017, there were 78 members. 3 years later there are now only 72 Southern Residents, so clearly the measures undertaken thus far are not recovering this population.

Orca Conservancy believes we need strong leadership from your agencies, as well as our elected officials to guide our region to a place with abundant wild salmon and steelhead supporting communities and livelihoods and honoring treaty rights; clean, affordable energy powering our homes and businesses; and thriving agriculture driving a strong Inland Northwest economy; but most importantly the wild salmon needed to sustain the critically endangered Southern Resident killer whales. We strongly support breaching the Lower Snake River dams.

Thank you.

5. Amy Grondin Commercial Salmon Fisherman Port Townsend, WA

Hello my name is Amy Grondin. I am a commercial salmon Fisherman and live in Port Townsend on the Olympic Peninsula. Salmon and steelhead have been in decline since the four lower Snake River dams went in; the same decline has been mirrored in Washington’s coastal communities.

The commercial fishermen that live on the coast have been struggling for decades. In the early 1970’s there were 3041 boats working in the ocean salmon fisheries. By 2018 that number dropped to 102 boats. In economic terms, the fishing communities over that same time have lost 90% of their economic opportunity.

Salmon fishing permits can only be owned by individuals; not big businesses. We are small-scale family businesses that produce food for other families. I feel that people forget that there is a large rural community west of Seattle. In some places the coast is six hours away from Seattle. As such, we don’t have the option to work for Amazon or Google. Salmon are an important economic driver for our blue-collar communities.

The latest DEIS fails to protect salmon and meet needs of our communities. I am tired of farmers and fishermen being pitted against each other by the media and big industries. We have more in common than we think. Both farmers and fishermen both work long, hard hours outside with variables of weather and cranky machinery.

We need to bring back economic vitality to coastal communities but it shouldn’t have to be at the expense of farming jobs. Simply said, I catch salmon but I need vegetables, bread and wine to make it a meal. I need farmers doing their jobs while I do mine so we can all eat.

People must come together to develop real solutions that work for all of us. We need to recover healthy salmon populations, meet the needs all of our communities, and support a reliable and affordable energy system. We can do this with the leadership of NW policymakers working with stakeholders and

sovereigns to solve problems, recover salmon, and bring everyone forward together – tribes, fishermen, farmers, the energy sector and all users of the river system.

Thank you for your time.

6. Rev. Dr. Marilyn Cornwell Biologist and Episcopal Priest Mercer Island, WA

I am the Rev. Dr. Marilyn Cornwell, a biological scientist and Episcopal Priest. I speak as a board member of Earth Ministry. Earth Ministry collaborates with northwest tribes, policymakers, and other stakeholders on creative, collaborative solutions that will restore salmon, steelhead, orca and meets the needs of farming and fishing communities. I have a great deal of experience working with at-risk communities. I know the power of collaboration in bringing about creative solutions to shared problems when change seems threatening but is essential.

The DEIS promotes the status quo and in no way meets the needs of northwest communities. Following it means continuing to push salmon, orca and the lives of fishing and farming communities to the edge of extinction. This failed, costly, harmful status quo is not viable.

Instead, we need solutions that are lawful, science-based, inclusive and promote healthy ecosystems for all. The DEIS won’t do so. The federal agencies don’t seem to be able to do so. And yet, it is our moral and spiritual imperative to do so.

Intimating that we must choose between a healthy environment and healthy economy is nonsense. In the northwest, river restoration has proven to be a viable solution to meet environmental and economic needs. We demand real solutions for northwest systems that come from northwest people and bring all communities forward together.

7. Robb Krehbiel, Northwest Representative Defenders of Wildlife Seattle, WA

My name is Robb Krehbiel and I am a Northwest Representative for Defenders of Wildlife.  Defenders is a national, science-based advocacy organization with over 1.8 million members and supporters nationwide focused on conserving and restoring native species and the habitat upon which they depend.

In the Pacific Northwest, one of our top priorities is preventing the extinction of the highly endangered southern resident orca. While there are many reasons that these orcas are struggling to survive, the most profound is the scarcity of their primary prey: Chinook salmon. Defenders advocates for salmon recovery actions throughout the range of the southern residents, such as reducing stormwater pollution, protecting and restoring habitat, and removing or replacing fish passage barriers.

We support breaching the four lower Snake River dams and view it as a necessary action to prevent the extinction of the southern resident orcas. However, any dam breaching action must be coupled with

infrastructure investments to support local communities and economies as they transition. Through forums like Governor Inslee's Lower Snake River Stakeholder Process, people identified investments including expanding rail lines, extending irrigation lines, installing renewable energy, and increasing energy efficiency. Unfortunately, the DEIS does not provide this holistic package of solutions and instead has chosen to maintain the status quo.

The DEIS also failed to fully or accurately consider southern resident orcas. The DEIS states that Snake River salmon runs are not important to the orcas. This is in conflict with the best available science. The country's leading southern resident orca scientists clearly state that the four lower Snake River dams must be breached if we hope to prevent the extinction of these orcas. According to a study by NOAA and the Washington Department of Fish and Wildlife, two of the ten highest priority salmon runs for the southern residents are Snake River runs. GPS data from NOAA also shows that during the winter and spring, the orcas spend a considerable amount of time at the mouth of the Columbia River foraging for salmon returning to both the Columbia and Snake Rivers to spawn.

The DEIS failed to fully assess climate change and we request that the agencies add an assessment of the impact to salmonids of increasing reservoir temperatures under various climate change scenarios.

With climate change, the number of days where reservoir temperatures reach lethal levels to salmon is expected to increase. Independent research has stated that removing these four dams would ameliorate this hot water problem and increase salmon access to over 4,000 miles of free-flowing, climate-resilient, federally protected spawning habitat in Central Idaho.

While there are several actions we need to take to recover southern resident orcas, breaching the four lower Snake River dams is the most significant and important action the federal government can take to restore a significant and critical source of food for these endangered orcas. With only 72 orcas left in the wild, there is little time to act and prevent their extinction.

Lastly, I ask that the agencies extend the comment period 45 days to comment on an 8,000 page document is too short a time for proper review, especially given the current public health crisis.

8. Margie Van Cleve Selah, WA

My name is Margie Van Cleve, thank you for the opportunity to give comments. I’ve lived in Selah, WA (outside of Yakima) for the last 25 years.

I attended Governor Inslee’s stakeholders engagement report meeting in Pasco last January and listened a bit at the “Know the Dam Facts” rally before the stakeholders meeting. While I was impressed with the enthusiasm from the drummers who were part of that rally, I also noticed there was no participation from any tribal drummers.

In central WA we just keep talking past each other on this issue. Inaccurate information continues to be repeated by our local elected Federal and state officials and there are no consequences or corrections. Instead these officials just add to obstacles instead of being part of potential solutions. … and this is on the easy stuff! The inaccurate information I refer to is their predilection for stating the four lower Snake River dams provide flood control. I’d like to note for the record that the four lower Snake River dams are run of the river dams and do

not provide flood control. We need facts, not fictions, so everyone understands the real issues that need to be addressed. 

The four lower Snake River dams must be removed. Unfortunately, this DEIS does not deliver the comprehensive solution that Snake River salmon and Northwest communities require. We need a comprehensive plan that works for salmon, orca, farmers, river communities and meets our tribal treaty responsibilities. We need agency and political leadership to advance dialogue that develops a comprehensive and durable solution.

•  The lost power can be replaced with clean renewable energy and conservation.

• We will need to invest in rail so our neighbors can get their crops to market.

• Restoring the Snake River and its abundant salmon will benefit sport, commercial and tribal fishing economies and communities, as well as the Southern Resident Killer Whales.

In summary, we need solutions that will work for everyone and there is no reason we cannot create that solution.  But we need leadership that helps rather than hinders that effort. Thank you.

9. LeeAnne Beres, Executive Director Earth Ministry Seattle, WA

Hello and thank you for the opportunity to speak this afternoon. My name is LeeAnne Beres and I’m the Executive Director of Earth Ministry and Washington Interfaith Power & Light. We are a Washington State-based organization of clergy, congregations, and individual people of faith who transform our faith into action for the well-being of our communities and the environment.

I’m glad to be able to comment on this Columbia & Snake River Draft Environmental Impact Statement today because in the faith community, we care as much about people as we do for God’s creation. It’s important to us that we all work together to craft solutions for the Columbia Basin that work for everyone. That’s why Earth Ministry has been bringing together Native leaders, farmers, fishermen, and people of faith over the last several years to discuss the future of the Snake River. Our “Loaves and Fishes” events throughout Eastern Washington have provided safe spaces for community members to share their hopes for the region and to be in conversation about potential challenges.

Unfortunately, this DEIS stops short of the necessary scope and scale to implement the inclusive change that people are calling for across the Northwest. We have a moral obligation to act. All remaining Snake River salmon and steelhead populations are in deep trouble today – the 2019 fish returns were some of the lowest on record. Southern Resident orcas face extinction due to a lack of their main prey, Chinook salmon. As caretakers of God’s creation, we must do better. We must act urgently and boldly, or we will lose these iconic Northwest species forever.

We also must care for our neighbors as ourselves. This means we should undertake the necessary planning to ensure that any changes to the river system, including potential removal of the four lower Snake River dams, is done in a way that meets the needs of those who depend on the river. We need healthy fishing and farming communities. We need a reliable and affordable energy system, and we need solutions that live up to our nation’s obligations to tribal communities.

The federal agency approach in this DEIS maintains a status quo that resolves none of these challenges and meets no one’s needs. The faith community is calling on Northwest elected officials

and policy makers to work with each other as well as Northwest tribes, farmers, fishermen, community leaders, and all other river stakeholders to develop a salmon recovery plan that actually restores salmon and ensures a prosperous region for everyone. Thank you.

10. Laura Ackerman The Lands Council Spokane, WA

My name is Laura Ackerman. I work for a conservation NGO in Spokane, but I have been involved in this issue since the early 1990s as a volunteer. (Just an FYI, I helped James Baker when he worked for SC with this work as a volunteer)

In February of 2000 I brought my 9 day old daughter to a hearing in Spokane to testify on behalf of salmon. When she was 16 in November of 2016, we went to an open house conducted by federal agencies in Spokane, on this issue. Now she is 20 and again, I am testifying.

Nothing has changed in almost 30 years. The Federal government agencies have wasted time, money and energy on the serious situation in trying to prevent the continued historical decline of salmon, steelhead and other wildlife for all these years. This DEIS is no exception.

Citizens of all different opinions have had their time and energy wasted as well. We need regional NW cooperation with all stakeholders, farmers, fishers, scientists, Tribal Nations and so on, that is supported by elected officials at the local, state and federal levels. This is what will make a difference. Clearly in almost 30 years, the federal agencies have failed. And I am sad to have to say that because they should have taken their leadership seriously instead of promoting the broken wheel of the status quo.

We need the federal agencies to please step aside while the rest of us work out solutions for tribes, recreationists, fish, fishers, and farmers The federal government agencies have never been able to facilitate a comprehensive stakeholder process. They in fact, by their inactions shown by the judicial rejection of five federal plans, have only attempted to maintain their position because that was the easy thing to. Their inaction has made the situation worse. Now we are all ready to roll up our sleeves and listen to one another.

You don't want to hear from me again, or anyone in ten years, giving you the same message.

11. Joshua Crowe Spokane, WA

Hello my name is Joshua Crowe, I recently graduated from Eastern Washington University with a Master’s degree in Sports and Recreation Administration, for my Master’s thesis I researched the recreation potential of a free flowing Lower Snake River. As an outdoor recreation professional the potential of a 200 mile free flowing Lower Snake river is vastly appealing. Having guided whitewater trips on many rivers including the Deschutes and the Lower Salmon, I have seen the potential for recreation and economic opportunities on free flowing rivers. Rivers like the Deschutes,

Salmon, and the Selway, provide opportunities to outfitters similar to what a free flowing Lower Snake River would provide. Activities like rafting, kayaking, hunting and sport fishing would bring millions of dollars in revenue to the local economies of the Lower Snake River. Healthy, free flowing rivers are rare recreational resources, compared to the vast number of lakes and reservoirs in the region. As a Spokane resident I am incredibly grateful for the flowing sections of the Spokane River that provide a variety of employment opportunities for myself, including but not limited to teaching whitewater rafting to Eastern Washington University Students, guiding whitewater and scenic floats for ROW Adventures and guiding for the City of Spokane Parks and Recreation Department. A free flowing Lower Snake River would provide residents with all of the previously mentioned employment opportunities and more. A free flowing Lower Snake River would provide an abundance of economic opportunities for the region. A free flowing Lower Snake River would eliminate the need for the flood control levees currently distancing downtown Lewiston and Clarkston from the riverfront, there are many examples nationally of revitalized waterfronts improving economic prosperity in a region. A free flowing Lower Snake River would mean a healthy riparian zone, or riverbank, zones like these are incredibly important to wildlife including game animals like waterfowl and large mammals. A healthy Lower Snake River would provide significant recreational hunting opportunities for such animals. Although fishing methods on a free flowing Lower Snake River would need to change compared to current methods used on the reservoirs, recreational fishing is projected by many to increase post dam removal. Many of the recreational activities currently pursued along the Lower Snake River would continue, examples of these activities include, swimming, boating, and camping. Today the Lower Snake River is a chain of reservoirs with sterile riverbanks, declining fish populations, limited recreational opportunities, and minimal aesthetic appeal. It is a dying river, separated from its people, with a bleak future. A free flowing Lower Snake River would be a desert canyon jewel--banks teaming with wildlife, healthy fish populations, world class recreational opportunities, a beauty that will bring life to both residents and tourists alike. As a lover of nature and the outdoors, I have spent my life dedicated to working in the outdoors, it pains me to see such a beautiful creature as the Snake River trapped behind such unnecessary impediments. As a recreation professional I implore you to look closely at the economic benefits that a free flowing 200 mile section of river would bring to the region, on a purely economic basis a free flowing Lower Snake River would greatly benefit the region, but the benefits of a free flowing Lower Snake River would extend far beyond purely the economic.

12. Antone Holmquist Moscow, ID

I am a long time resident of Idaho and an avid white water rafting enthusiast , I think it is my duty to support measures that will have a real chance of bringing back the Salmon and Steelhead to the rivers and tributaries above the four lower Snake river dams. Every year I float these rivers and ponder what was once and what could be again.

It seems that politics is the driving force behind the DEIS and its preferred alternative. As a tax paying citizen I am offended by the tremendous financial capital that has been and continues to be thrown at so called solutions while fish populations have continued to slide over time.

I am not worried about the loss of electrical power from the four lower Snake River dams. These dams provide a relatively minor part of our Northwest power supply and can and will be replaced with renewables.

The slowdown of river flow between these dams causes the fish to expend much too much energy in going downstream. This is indisputable.

The economic benefits to local communities and the entire area will be great if these dams are removed or breached. Any economic benefit from the dams is not shared widely and the massive subsidies to those that do see economic benefits are not widespread.

The Native American tribes have been the recipients of broken promises and treaties. Bringing back the wild fish would actually fulfill our treaty obligations. Throwing money on the same old same old “solutions” is not working.

It is time to do the right thing-remove or breech the 4 lower Snake river dams.

13. Terry Teigen Retired Pastor Seattle, WA

Good evening, my name is Terry Teigen. I have been a resident of the Puget Sound region for almost all my 66 years. I am a clergy person by profession, now retired. Currently, I am active as a volunteer in the work of a faith-based organization, Earth Ministry. I have decided, that of all the things I might do in these last years, trying to bring health to our waters, preserve wildlife habitat and trying to strengthen healthy communities for our grandchildren, mine and yours is my privilege and duty. I want to pass along a measure of the quality of life I have enjoyed. I am not a scientist, but I am a keen observer of the beauty and diversity of this region. I grew up fishing on “The Sound” with my father and others. I can still remember the times when we would go out early on Saturday morning and catch our limit of silvers or kings before lunch. On a couple of occasions, I remember Dad, saying, “Oh no. There are ‘blackfish’ out here. There go the salmon.” But seeing the Orca even from a distance was a thrill, and I grew up aware of the need to balance sport for some, livelihood for others, and appreciating the intrinsic beauty and wonder of salmon runs and the sleek, swimming giants who feed on them. And as the decades have passed, I have witnessed the incremental but rapid diminishment of this once vital natural community. With habitat destruction, chemical pollution, and pressure of all kinds, the ecosystems of Puget Sound, the Columbia and connecting rivers and streams have all suffered. And here we are today. What will it take to wake us up?! If it’s clear that removal of the dams on the Lower Snake will give the salmon, the Orcas, our Northwest environment the best chance at recovery, why would we hesitate? How do we put a price on that? On the other hand, as the salmon increase, as Orcas potentially recover, won’t that be a boon and invaluable benefit to those who fish for sport or livelihood and the communities that enjoy the salmon as a food source. At the same time, we will continue to feed the souls of locals and visitors who come to our region to witness one of the most amazing wonders in this world of wonders, as salmon spawn, as life renews, and the web of the Divine gift of natural diversity is on full display.

All over the world people are mourning what has been lost in the places where they live -- forests, wildlife, what humans need to sustain quality of life. If it is in our hands, right now, to defend and preserve this legacy, our legacy, right here, why would we hesitate? 14. John Rosenberg Retired Pastor tumwater, WA

My name is John Rosenberg. I am a retired Lutheran (ELCA) pastor from Tumwater, Washington. I am an avid steelhead angler and a volunteer for several salmon recovery efforts both local as well as statewide. I have a master’s degree in Pacific Northwest History from Portland State University where the focus of my research was on Columbia River Salmon and Steelhead. I’ve been following the regional conversation about Columbia River salmon since the mid 1970’s when the last of the Snake River dams was completed and brought online. So, I have some historical as well as personal perspectives on this issue.

Someone said that one definition of insanity is to keep repeating the same action over and over and expecting a different result. By that definition, the latest draft EIS from the co-lead agencies might be fairly described as an exercise in insanity or, to borrow a phrase from Yogi Berra, “It’s déjà vu all over again.”

A reasonable person might think that after five rejections by the federal court, each rejection more scathing than the previous one, the agencies might consider a different approach. However, they seem to be so locked in to preserving the status quo that, apart from some minor tinkering, they keep producing the same worn-out plan over and over again. Something needs to change if Columbia/Snake River salmon and steelhead are to survive.

The urgency to act has never been greater. Not only are salmon and steelhead threatened with extinction but

• so are the orcas that depend upon them as a primary food source • so are coastal communities in Oregon and Washington that depend upon them as

a primary source of income • so are the outfitters in Idaho that depend on abundant salmon and steelhead for their livelihood • so are tribes for whom salmon and steelhead are integral to their self-understanding and way of

life

The only economic impacts that the draft EIS takes into consideration are to the barging industry, a small number of farmers who rely on the Snake River for transportation and irrigation, and utilities who are rapidly developing alternative energy sources to replace their need for power from the four dams on the Lower Snake.

If we want a different outcome, Congress needs to take the process out of the hands of the federal agencies who have demonstrated their unwillingness to take the necessary steps to address this crisis and give it to Pacific Northwesterners who can come up with real solutions—sovereign tribes, states, ALL stakeholders (not just barge operators, farmers, and utility operators), and regional citizens who can craft inclusive, creative solutions that are lawful, science-based, and that address the concerns

of the people of the region today and not just the “open river” boosters who promoted the dams fifty years ago.

If we want a different outcome, we need a different process with some different players. If the Corps of Engineers, the Bureau of Reclamation, and BPA have demonstrated anything over the last 30 years, it’s that they are incapable of addressing this crisis in a meaningful way. How about letting some other folks take a shot? Thank you.

15. Joel Kawahara Commercial Fisherman Quilcene, WA

My name is Joel Kawahara. I am a commercial salmon troller from Quilcene, Washington.

Concerning the preferred alternative (PA). The PA is assessed as minimizing social and economic disruption. That is not true. The PA does not take not account the lost fishing revenue resulting from the development of the Columbia River power system. I’ll give two examples: Columbia and Snake River Spring Chinook are listed under the Endangered Species Act. They currently provide zero economic benefit for the Columbia River gill net fishery. Snake River Fall Chinook are listed under the Endangered Species Act and are a millstone for both ocean and in-river commercial fisheries. One pre-dam estimate for Snake River Fall Chinook put 500,000 adults at the mouth of the river.

Comment on the difference between the Comparative Survival Study (CCS) model and the COMPASS and NOAA Life Cycle Models. CSS is based on empirical data while the COMPASS and NOAA models use analytical methods to produce results. Empirical based model results are the surest way to calculate mortality of salmon. I suggest using CSS to decide on PA.

Multiple Objective Alternatives do not represent public sentiments. The public, including myself, gave very strong input on the need for salmon recovery. These sentiments are not fully addressed by the MO approach. Recommend development of a full recovery of salmon alternative for analysis before RoD.

16. Amy Daugherty Executive Director, Alaska Trollers Association Juneau, Ak

Hello my name is Amy Daugherty. I am the Executive Director for the Alaska Trollers Association and I live in Juneau, AK. The Alaska Trollers Association represents all power and hand trollers who fish in Alaska. Most years there are less than 850 active permit holders, spread out along 700 miles of coastline up to Yakutat. We are the smallest commercial boats, the ones that bring fish aboard one at a time.

As a sidebar, at least 15% of Alaska’s power troll permit holders live in Washington & Oregon. It is no secret that Washington & Oregon play a significant role in the SE Alaska fishing economy.

So make no mistake, what you do affects trollers and the folks who enjoy our carefully harvested fish. We ask that you protect salmon stocks and reverse the current population trend. It is dire.

The fish we catch and sell know no boundaries. And the stocks that return to the Columbia need help now. We believe the only way to bring about meaningful protections of the existing stocks is dam removal. Accordingly this DEIS should be revamped, or we are all looking at further imperil of Columbia River salmon, small communities and many small businesses.

I am always surprised when I see existing small business infrastructures being taken for granted. We all like the concept of creating small local and clean small economic engines, which salmon troll businesses are, but when it comes to protecting what we have in place, there is a lack of appreciation in many cases.

Alaska trollers including our Washington and Oregon resident troll participants urge you to reformulate and write a new plan to foster both farms and fish. It can be done. This DEIS as written will do very little. The time is now.

Thank you.

17. Joel Brady-Power Commercial Fisherman Bellingham, WA

Hello, My name is Joel Brady-Power. I am a commercial fisherman and direct marketer of salmon. I live in Bellingham, Washington.

Salmon are my life and my livelihood and they do not just sustain me. My wife and I market all of our catch, mostly in Washington State, to restaurants, grocery stores and individuals. Salmon send ripples throughout our local economies, communities and ecosystems.

When we return from the fishing grounds we sell our catch in our community. These fish are then sold by local grocers and served at local restaurants. We in turn take the money we earn from these sales and put it back into our community, frequenting the same local establishments that sustain us.

Every year we haul our boat out for repairs and maintenance in Port Townsend employing many local small businesses from the port, to shipwrights and mechanics. We purchase parts, pay moorage, buy groceries and fuel. All from money we earn from the salmon we catch.

Without healthy fisheries all of this goes away. The economic impacts of diminished salmon runs will be felt throughout our coastal communities and beyond.

We need to restore our salmon runs and protect the vibrant coastal communities who depend on them.

The DEIS fails to do this. It does not meet the needs of NW communities and it has threatened the survival of salmon, orcas and the livelihoods of fishermen and their communities.

Salmon returns to the Snake and Columbia are currently at all time lows.

Scientists tell us that the single best action we can take to help these endangered salmon is to restore the Snake River by removing its four dams. The time to act is now.

We need to bring back the economies of our coastal communities, but it does not have to come at the expense of the farming community.

I believe together with the leadership of our elected officials we can find a way forward that is sustainable for all. Salmon, tribes, fisherman, farmers and the energy sector.

It is time for a new approach. The DEIS has not worked, is not working and will not work in the future. It is time for the people of the NW to find and create creative solutions that will work for us all moving forward.

Thank you for your time.

18. Tele Aadsen Commercial Fisherman Bellingham, WA

My name is Tele Aadsen. I’m a commercial fisherman, & have spent 32 years trolling for salmon in Southeast Alaska. I live in Bellingham, Washington, & am co-owner of Nerka Sea Frozen Salmon, through which my husband & I self-market our catch.

My father-in-law started this family business in 1998, when he took one of his salmon to a neighboring chef in La Conner. Twenty-two years later, I still make weekly deliveries to that same chef. This is one of many enduring partnerships within our local economy. We sell the majority of our salmon here in Washington State where, as lifelong Whatcom & Skagit County residents, my husband & I share deep roots with farmland. We’ve built our livelihood on our customers’ farm-to-table values. Our chefs text me pictures of their latest specials, the Nerka’s salmon plated with locally farmed Brussel sprouts, a glass of vino from a Walla Walla winery on the side. Paired together, we enhance each other’s work.

Our customers often come to me with questions about orca & salmon. I share their concerns. If we fail to act now for healthy rivers, estuaries, & ecosystems, everyone relying on this farm-to-table chain will suffer. The essential services that fisher-families, farmers, shipping, & food service industries provide have never been so starkly illustrated as they currently are, with the COVID-19 crisis highlighting the economic value & mutual dependency our coastal & farming communities share.

Restoring & preserving salmon is critical to our region’s wellbeing. The DEIS does not meet this need. With salmon returns to the Snake & Columbia Rivers at all-time lows, scientists have repeatedly identified the removal of the four Lower Snake River dams as the single best action we can take. I’m confident there is a path forward that values the wellbeing of salmon, orcas, coastal communities, farmers, tribal members, & the energy sector. The DEIS preferred alternative is not that path. Thank you for your time.

19. Greg Friedrichs Commercial Fisherman Port Townsend, WA

Hello, my name is Greg Friedrichs. I am a commercial fisherman and live in Port Townsend.

Salmon are economic drivers that create jobs in coastal communities not just during fishing season but also all year round. During the fishing season, money earned from fishing supports other business in the ports where our fish are landed. In the off-season from fishing the money we earned from fishing filters in to our hometowns.

Local businesses like grocery stores, gas stations, restaurants, and the services that we rely on. Fishing dollars pay mortgages, college tuition and for health care. When I am not fishing I work as a shipwright in the Port Townsend Shipwrights Coop. In years when the fishing is bad fishermen don’t have the money for boat repairs and maintenance is often deferred. This means there are fewer jobs in the boatyard and the effects of the lost jobs are felt across the whole town. We need to restore the Snake River not just for fishermen like me but also for the economic vitality of coastal communities and the places we live when not fishing.

The current DEIS will not protect or restore salmon and steelhead. It does not address the needs of fishermen and coastal communities. We need the leadership of our elected officials to help us find a solution that supports the whole state and values all residents and jobs from the east to the west. Thank you for taking my comments.

20. Shari Tarantino Orca Conservancy, Executive Director Seattle, WA

First and foremost, the comment period deadline will not allow enough time to allow thoughtful and educated comments. Therefore, we request an extension to the current April 13 deadline.

Orca Conservancy has been working towards SRKW recovery since 2006. We firmly believe the restoration and breaching of LSRD are vital for preserving wild salmon including the remaining 72 Southern Resident killer whales. Discussions must continue between all stakeholders if we are committed in addressing and ensuring the wholeness of each affected community, not only what this will look like without the Snake River dams, but how to get to that point and do so successfully.

Scientific data has shown us time and time again that the recovery and restoration of west coast rivers is key to the survival of SRKWs, and addressing the threat of prey abundance is a priority in recovery plans for this critically endangered population. The “preferred alternative” of increasing spill put forward in the draft EIS is merely a stop gap measure, intended to buy time until a true alternative could be identified and implemented. The alternative is breaching the LSRD!

The Southern Resident killer whale population are the most intensively studied population of marine mammals in the world, and what we’ve learned is that healthy Chinook salmon runs are critical to their recovery. Their historic use of west coast waters qualifies this community as an important resource to the state of Washington, Oregon and California, and therefore the SRKWs should be considered when evaluating the potential impact of continued operation of the LSRD. When we submitted our scoping comments in February 2017, there were 78 members. 3 years later there are now only 72 Southern Residents, so clearly the measures undertaken thus far are not recovering this population.

Orca Conservancy believes we need strong leadership from your agencies, as well as our elected officials to guide the PNW to a place where abundant wild salmon and steelhead populations can once again support communities, livelihoods, and honoring treaty rights, but most importantly wild salmon is needed to sustain the critically endangered Southern Resident killer whales. We are here to help and support breaching the Lower Snake River dams.

Thank you.

21. Stan Kuick Tri-cities, WA

My name is Stan Kuick. I am a conservationist, serving as an officer of Tapteal Greenway in the Tri-Cities, and also an avid fisherman, primarily in the Hanford Reach of the Columbia River. I have lived in the TriCities for 37 years.

I remember when I first moved to this area and started to fish the Hanford Reach in 1983, first as a shore fisherman at Ringold for steelhead, and later on my friend’s jet boat, which led to getting my own jet boat in 1988. The Hanford Reach is such a fantastic piece of water, with rapids, deep pools, and eddies that harbor many kinds of fish and provides the exceptional

salmonid spawning conditions that it is famous for. It reminded me of the many trout streams I fished as a boy in the East and upper Midwest except a thousand times bigger! We could create another Hanford Reach on the lower Snake River if we have the vision and patience!

The long term erosion of the salmon runs, particularly steelhead, has been very depressing. Yes, ocean conditions have been a major factor contributing to this but the dams are also a big factor. I’m not advocating taking out all the dams, but it’s pretty clear that the lower Snake dams are a marginal contributor to the region’s economy but likely a major detriment to the salmon runs. All you have to do is look at the history of Snake River salmon runs just after these dams were installed in the 60’s and 70’s and the trend is obvious.

Will there be some significant costs to removing these dams? Yes. But consider this: If these dams were being proposed now would we build them? Certainly not, knowing what we know now about their negative impact on salmon. Removing these dams will speed fish passage, lower summer water temperatures, reduce smolt exposure to predators, and open additional spawning areas for salmon.

Some of the objections to dam removal have merit, but some do not. Losing the ability to barge wheat and other products on the river is the most significant negative with dam removal that can’t easily be mitigated. Irrigation, despite what you may read from other sources, would not be significantly affected. As is done in the Hanford Reach, drawing water from a large free-running river is not a significant challenge. The pipes and pumps would have to be lowered, the intake area may have to be dredged a little, and water flows at the upriver storage reservoirs may have to be managed to insure adequate late summer flows.

The other major objection to dam removal is the loss of power production. The consensus seems to be that the lower Snake River dams produce about 4% of the Northwest’s electric power. Recently I have seen claims that losing this capacity would cause an increase of 50% in power rates and brownouts and blackouts at times. This is hard to believe in an area that frequently has a power surplus and exports power to other states like California. We should also consider that there are a number of additional wind and solar farms already planned for development including right here in the Tri-Cities that will be adding to the regional generating capacity.

Trying additional incremental steps like increasing spill and pumping more hatchery fish into the rivers is not going to work. Dam removal has been successful in improving fish runs in virtually every case in rivers in the Northwest, Great Lakes, and the East Coast. When you hear people say that it won’t work, don’t believe it, because it has worked everywhere else.

22. Michael W. Shurgot, PhD Seattle, WA

Thank you for the opportunity to contribute to this discussion about a crucial environmental issue facing the Pacific Northwest. I wish to make four essential points in support of my absolute conviction that the current DEIS is not only wholly inadequate but also immoral. I ask that my comments be made part of the permanent public record of these deliberations.

First, everyone involved in the debates about whether or not to remove the four dams on the Lower Snake River knows that the eighteen billion dollars spect so far on “restoring” the salmon runs on the Snake have accomplished nothing! Today the many salmon species that once populated the Snake are in severe, if

not unalterable, decline. Each year fewer and fewer fish traverse the river, spawn upstream, swim back to the Pacific Ocean, and then return the following season. Common sense dictates that there is absolutely no reason to spend one more dime of the public’s money on these failed policies. Each previous DEIS has been declared illegal by federal courts because they have embraced and promulgated these ridiculous and ineffective attempts to restore the salmon while leaving the destructive dams in place. It is time to embrace what science and common sense dictate: if the Snake River salmon are to return to health the only possible plan is to remove the four dams on the lower stretches of the river.

Second, by refusing to remove the Snake River dams the federal agencies involved in this decision-making are literally condemning to death the Southern Resident Orca Whales in Puget Sound. These whales cannot possibly survive without an adequate food supply, and it is utterly immoral to condemn this species to extinction. Yet that is precisely what the current DEIS proposes to do. On what possible grounds do the involved agencies justify this condemnation? This condemnation is especially egregious when there are plentiful ways to supplement the irrigation, transportation, and utility needs that removal of the dams would require. By not embracing the only Page 2 ecologically proven solution to ensuring the survival of the salmon and Orcas that depend on a free-flowing river, the above agencies appear as twentyfirst century Luddites who are willfully ignoring the readily apparent technological solutions to these needs. Dumping another eighteen billion dollars into failed policies will restore neither the river, its salmon, nor the Puget Sound’s Orcas. Period!

A third and related point is the claim often made by some politicians in Washington and Oregon that they “own” the dams. Nonsense! To say that one “owns” these dams is to claim that one “owns” the river itself and its dying wildlife. No one can own a river! Such claims also ignore the historic Tribal and commercial fishing operations that have been decimated by the dams and consequent loss of fish runs. On what grounds do the federal agencies prioritize other interests while simultaneously ignoring the devastation of the fishing industry? Do their jobs not matter? Do Indian Treaty Rights not matter? Do you wonder why federal courts have consistently labeled all past DEIS illegal?

Finally, this latest DEIS exemplifies recent federal agencies’ willfully ignoring the fundamental thrust of Aldo Leopold’s seminal essay “The Land Ethic,” published in his landmark book A Sand County Almanac (1949: rep. Oxford University Press, 1987). The heart of Leopold’s argument are these sentences: “A land ethic changes the role of Homo Sapiens from conquerer of the land-community to plain member and citizen of it. It implies respect for his fellow members, and also respect for the community as such. . . . A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise” (pp. 204, 224). Retaining the four dams on the Lower Snake River obviously devastates the “integrity, stability, and beauty” of the Snake River biotic community: the river itself, its salmon, and ultimately the Orcas that depend on the fish for their survival. This policy must therefore be abandoned immediately, and federal agencies must act now to begin the process of removing these destructive dams.

23. Brian Brookes Idaho Wildlife Federation, Executive Director Idaho

I sit on the Idaho Governor’s salmon workgroup. We’ve been learning quite a lot over the last year about what we need for our fish to survive and the key indicator of recovery is reaching a 2-6% smolt to adult return ratio, or SAR. A 2% SAR will keep the fish at a plateau, not recover them. A 4% average is what is considered healthy and harvestable fish

numbers, in abundance that allows meaningful harvest for tribes, sportsmen, and the outfitting industry here in Idaho

The Preferred Alternative is a travesty for Idaho anglers and outfitters and guides. By the acting agencies own admittance, the smolt to adult return ratio for Idaho’s stocks under the preferred alternative will only reach 2% one out of every three years, ensuring we remain on an extinction trajectory. Further, the DEIS did not even account for the economic impact of fish in Idaho. In one good year the town of Riggins made $40m in primary and secondary spending from fish. With the steelhead season closure last year, Clearwater County lost of $8 million a month. We have the economic data and its omission from the DEIS is mind boggling.

We need to zoom out a little bit here and look to the future. By their own strategic plan, BPA has stated they will reach their federal borrowing cap by 2023. And the only way they’ve extended it so long is by spreading the federal debt to private debtors, totaling over $15b in debt. That does not sound like financial solvency. In fact, the impacts of their financial situation have already resulted in less money going towards fish mitigation projects in Idaho, when arguably we need more money for fish than ever.

BPA charges $36 per megawatt hour while their competitors charge $22 per megawatt hour. PUDs and other customers are leaving. One PUD in Idaho is investing in new transmission lines to leave BPA for another producer. Those who stay behind with BPA will be forced to incur the new, higher costs for every PUD that leaves.

Continuing to zoom out, we all know the four lower snake river dams will not last forever. They don’t provide flood control, they don’t provide water supply as run of the river dams, but they do provide transportation and some, but not much, electricity. I support transportation and electricity generation, but the river is not necessary to provide such services. Fish have no such choices. We transported agricultural products before the dams were built, and we are already replacing the power generated by the dams. But, to call the dams clean energy while they are causing an extinction of a species and industry, is not true.

It’s time to work together to figure out other ways to resolve these issues. Thank you.

24. Stevie Parsons National Wildlife Federation, Board Member ? , WA

My name is Stevie Parsons. I am a Board Member of the National Wildlife Federation, one of the largest conservation organizations in the U.S. I am an avid angler, hunter, and forager. I am also Native Hawaiian and Native American.

Yes, warm water blobs, poor ocean conditions, pinipeds and climate change have had effects on salmon, steelhead and orca populations, but breaching the lower Snake River helps these populations YET two decades and numerous federal lawsuits later; this DEIS still does nothing to aid our current salmon, steelhead and orca crises; it is quite simply more of the same failed science, outdated data and laziness.

Government’s role is to bring people together to solve problems. We need and can find solutions that will work for all communities – farming, fishing, native communities and industry.

To do nothing would be to allow these fish to go extinct as well as to fail small rural communities in Idaho, Oregon and Washington who depend on these fish not only as food, but also as a major income source.

It’s become very popular to argue for easy solutions saying to use alternative ones would require us to make choices between power, medicine or food; this is a false, unproven argument being used to stir up our emotions.

Public sentiment is in favor of dam removal; yet government refuses to listen. Native communities support dam removal; government still refuses to listen. Conservation organizations support dam removal; government refuses to listen. Salmon, steelhead and orca are going extinct; government still refuses to hear their voices. What do we need to do to get your attention and be heard?

Are we going to tell our children and grandchildren that we allowed these fish and cultural icons to go extinct because we valued cheap electricity more or we were afraid or too lazy, or not creative enough to find alternative solutions.

Remove the lower snake river dams.

25. Kate Murphy Columbia Riverkeeper, Community Organizer Portland , OR

My name is Kate Murphy and I am a community organizer with Columbia Riverkeeper. Representing over 16,000 members, Columbia Riverkeeper’s mission is to protect and restore the Columbia River and all life connected to it. We focus on issues including water quality so people can swim safely and eat the fish they catch without contamination, water temperatures so salmon can have the opportunity to survive and recover, and stopping pollution so the river is a healthy resource for all. We support a regional solution to Lower Snake River dam removal that brings stakeholders together rather than pitting them against each other.

Water temperature is a major problem for salmon and steelhead

• Between 1960 and 2015, water temperature in the Columbia and Snake River have increased by an average of 1.4°F. (https://www.epa.gov/climate-indicators/snake-river).

• Salmon are sensitive to water temperature at many stages of their lives. Warmer water can negatively affect fish, making it more difficult for them to swim upstream, and making fish more susceptible to disease. (https://www.epa.gov/climate-indicators/snake-river)

• In the Lower Snake River, temperatures in the reservoirs exceed 68°F for weeks or months at a time during the summer when many salmon migrate to or from the ocean. Temperatures above 68 degrees are very harmful to salmon.

• Salmon populations in the Snake River Basin are increasingly threatened by warmer rivers, including significant warming from the reservoirs behind the four dams on the Lower Snake River.

The DEIS analysis is insufficient on several levels.

• In the analysis of climate change. The EIS should model water temperatures in the Columbia and Snake rivers under the climate conditions we expect to see in 20 to 50 years.

• In addressing the challenges that salmon face in the Columbia River and estuary. Existing dams and worsening climate change are making the lower Columbia River and estuary too hot for fish. The DEIS does not explain this or provide any solutions.

• The DEIS implies that Lower Snake River dam removal would not significantly change water temperatures or improve conditions for salmon. This is not true. Summer and fall water

temperature conditions in the Lower Snake would be significantly better for salmon and steelhead with the dams gone.

The science is clear. Removing the four Lower Snake River dams is the single best action that can be taken to help recover endangered salmon and Southern Resident orcas. Snake River Sockeye and Steelhead are close to extinction; the incremental approach taken by the preferred alternative is legally and morally untenable. Restoring the Lower Snake River by returning it to its free-flowing state is likely the only action that could bring back million-strong salmon runs, benefitting sport, commercial and tribal fishing communities and helping starving Southern resident orcas.

26. Cindy Hansen Orca Network, Education Coordinator Friday Harbor , WA

My name is Cindy Hansen and I am representing the non-profit Orca Network. We would like to express our disappointment that the draft EIS did not adequately represent the importance of Columbia Basin salmon to the endangered Southern Resident orcas, and fails to recognize the biological need of Southern Residents to have continuous access to salmon from a variety of river systems throughout their range. The report states that Puget Sound Chinook salmon stocks are more important than Snake River stocks due to their availability for greater periods of the year. However, we know from a variety of research and data sources that Southern Resident orcas spend over half the year in coastal waters and that Columbia basin salmon make up over half of their outer coastal diet. We also know, as evidenced in 2018 and 2019, that Southern Residents will shift their patterns and feed off the coast during the summer when there is little to no salmon available in the Salish Sea, underscoring the importance of these coastal runs as Puget Sound and Fraser River stocks continue to decline or fail to improve.

Of the alternatives presented in the draft EIS, MO3, Snake River dam breaching plus increased spill over the Columbia River dams, represents the best chance of recovery for Snake River salmon and for Southern Resident orcas. The benefits of dam breaching were demonstrated in a recent white paper entitled Southern Resident Killer Whales & Columbia/Snake River Chinook: A Review Of The Available Scientific Evidence which was written by 5 PhDs -we urge you to read it in its entirety.

Our concern is that the preferred alternative is going to simply repeat the status quo and do little more than incorporate the interim agreement for increased spill. While this agreement is certainly a positive step for salmon, it is not enough to result in the salmon recovery needed for the survival of Southern Resident orcas, and to restore salmon and cultural resources that were lost to local tribes.

In 2018 Governor Inslee’s Southern Resident orca task force recommended a stakeholder process to discuss potential breaching or removal of the lower Snake River dams. This process was just completed and while the final report is not perfect, we do not want to see this time and effort wasted. We would like to see some of this information incorporated into a dam removal plan, and used to support stakeholders and make them whole as they transition to a free flowing Snake River that can continue to meet their needs.

Finally, we would like to request that you extend the current comment period. There was not enough time initially to read and understand a document of this magnitude; and given current events, we feel that the public needs more time to read and digest this information and give it the attention it deserves so they can prepare educated and thoughtful comments. Thank you.

27. Tim Colton Concrete, WA

I am a resident in Skagit County, WA, but grew up in Iowa and have traveled to all the states in the continental US. Having this perspective, I can say with confidence that the natural resources of Washington State are the most unique and valuable asset of this state. Unfortunately, the past century of industrialization have taken their toll on these valuable resources, one of the most significant being wild salmon.

As a farmer and Civil Engineering graduate I can have compassion on those whose lives will be disrupted by a change in the operation of the Snake River dams. But humans can change and adapt; these salmon cannot. The land of this region can be irrigated by other means or put to different use; electricity can be generated through different means or demand decreased through energy efficiencies. Rail can replace barge transportation. What other options do salmon have? They must navigate this river, and the dams increase their travel time, provide better habitat for their predators and increase the water temperatures to dangerous levels.

I implore the federal agencies to revise their recommendation for the final draft of the EIS to support alternative 3, to remove the lower four Snake River dams, the one alternative that the agencies acknowledge will be most effective in recovering wild salmon and the natural resources that rely on these salmon.

28. Dr. David Bain, Ph.D. Orca Conservancy, Board Member Bothell, WA

I would like to request an extension in the deadline for written comments. The DEIS is thousands of pages long, and restrictions on activity due to COVID-19 limit opportunities to meet with colleagues efficiently and access older and other written materials in libraries that are not readily available online, so more time is needed to provide well-reasoned comments.

A significant weakness in the DEIS is its consideration of impacts on Endangered Southern Resident Killer Whales. The Salish Sea is Critical Habitat for SRKWs, and part of the migration route for Columbia River System Chinook Salmon. Further, NMFS has proposed expanding Critical Habitat to include a much larger portion of the CRS Chinook salmon range along the Pacific coast.

The DEIS relies on an incomplete report on the importance of different river systems in providing food for SRKWs. The authors noted many sources of bias they did not have time to address. These biases lead to underestimation of the importance of CRS Chinook.

The DEIS relies on an inaccurate description of the distribution of SRKWs. In fact, the majority of SRKWs spend the majority of the year within the main range of CRS Chinook. Use of this portion of the range has increased as Fraser River Chinook runs have declined, indicating CRS runs are likely to be more important in the coming years than they were in the first 40 years of study of SRKWs.

The report fails to consider the effects of inbreeding on jeopardy to the DPS survival. Maintaining constant numbers will result in loss of genetic diversity and increased inbreeding, both of which reduce the likelihood of recovery. That is, a plan that does not contribute toward significantly increasing SRKW numbers results in jeopardy. In his ruling on the Maury Island gravel mine case, Judge Martinez noted that even small threats to an already endangered population were likely to result in jeopardy. Thus the DEIS should have concluded that the preferred alternative is likely to adversely affect SRKWs and result in jeopardy to the DPS’ survival.

Alternative M03, which calls for removal of the Lower Snake River Dams would support recovery of SRKWs but was not seriously considered. It could be combined with spill up to 125% TDG.

While it considered replacement power generation, it did not consider conservation as a means to offset the loss of power generation. It failed to consider expanding rail capacity to replace barging. It failed to consider alternate means for cooling summer flows, providing irrigation water to farmers, and ensuring that farms could remain viable without irrigation.

It failed to consider continued hatchery operation as a conservation measure rather than as a mitigation measure.

While noting that Congressional action may be required to reprioritize the purposes of the LSR dams, there have been calls by elected officials to do just that.

Identifying LSR dam removal and other measures to maximize salmon production and the likelihood of SRKW recovery as the preferred alternative would prioritize consideration of the legislative and executive actions necessary to implement it. A serious consideration of the importance of this level of action to recover endangered species, rather than just slow their decline to extinction, placing greater weight on the impact of this decision on Native Americans relative to others in the region, and a broader consideration of actions to mitigate impact on people who would be negatively affected by dam removal should be included in the final DEIS.

29. Tim Palmer Author Port Orford, OR

I'm Tim Palmer of Port Orford, Oregon. I'm the author of 28 books about resource issues, and my comments here are informed by three books I have written: Endangered Rivers and the Conservation Movement; The Snake River: Window to the West; and The Columbia: Sustaining a Modern Resource, and also by continuing research and reports from many sources.

Virtually all the research I did for these books and for work after them indicated that benefits of the four Snake River dams are grossly exceeded by the costs in public subsidies to the barging, hydropower, and irrigation industries and by the costs of allowing these dams to drive our salmon and steelhead toward extinction.

Any argument that dam removal does not provide for "certainty" of salmon recovery is logically flawed because that "proof" will only be accepted as fact after it has occurred.

Except for reports from entities paying for work that supports keeping the dams intact, and work by agencies deeply invested in sustaining the status quo, the evidence of both biologists and economists say that we need to remove these dams to sustain the salmon and to make our public agencies solvent.

The four dams provide less than 4 percent of our regional power—power that is available mostly when it is in surplus, and it is easily replaced by alternative sources without the problems that the dams are causing.

Unlike what was delivered in the past five plans, I urge you to revise this DEIS to provide a fair and accurate report this time. I urge you to consider the full costs of these dams and a full accounting of the benefits of restoring our salmon and building a sustainable economy that is not predicated on the extinction of our native fish and other valuable natural resources.

30. Liv Larson Andrews Lutheran Pastor Spokane, WA

Hi everyone.

I am a pastor of a small Lutheran church in Spokane, Washington. I represent about 100 Lutheran Christians who gather (when there is not a pandemic) to worship together about 2 blocks from the Spokane River.

I logged into the teleconference regarding the Snake River dams this evening at about 7:10, and was never permitted time to speak. So, here are my thoughts.

I am calling to speak in support of the removal of the four dams on the Lower Snake River.

I am calling to urge leaders to consider the connectivity of all creation and the sacred web of life, of which humans are but one part.

The biblical picture of human activity holds in high regard the stewardship of creation, the sustenance of ecosystems, and the holy calling we have to tend to the wellbeing of other creatures.

So many voices tonight have spoken to the science and economy of dam removal. I am here to say there is a spiritual reason to remove them. The dams inhibit the sacred interplay of species, land, water, and air.

As it is said, extinction is poor stewardship. Please remove these dams to prevent extniction and to fulfill our holy purpose as humans to participate in and sustain the sacred web of life.

Peace.

31. Edwina Allen Boise, ID

My name is Edwina Allen. I reside at 2114 E Ridgecrest Drive, Boise, Idaho 83712.

Checking my files, I verified that, since 1991, I have been submitting comments to federal agencies advocating for action to save northwest salmon. The issue was and remains the disastrous effect on salmon survival caused by the four lower Snake River dams. I have seen salmon decline to the point where they are now on the edge of extinction.

After five rejections in court of federal agency plans to manage the Columbia River Basin dams, the major objective of the current DEIS should be to produce a plan that will in fact meet legal requirements for

recovery of salmon and steelhead in the Snake River. The recommended preferred alternative fails to do this, even though the document acknowledges that removing the four lower Snake River dams is the best choice for fish recovery. Despite credible scientific information, the DEIS denies that removing those dams would increase Snake River Chinook, a critical food source for the starving Puget Sound orcas.

It is tragic that although Idaho has hundreds of miles of pristine spawning habit for salmon and steelhead, those fish face extinction because of the unnatural obstacles in the dammed lower Snake River. History shows that as the dams were built, the fish returns above them declined to levels now near extinction. Before the dams, the young salmon smolts were quickly flushed to the ocean with the spring runoff. After the dams, that passage takes perilous weeks, with no current to guide them through the slack water reservoirs. Predators in the reservoirs eat the smolts; smolts don’t eat as they out-migrate, so they lose weight; smolts that are put in barges or trucks to speed their journey have a very poor rate of return as adults. On the return trip as adults the fish must avoid predators clustered at fish ladders and, especially with climate change, survive reservoirs often reaching lethally warm temperatures.

I call on you to develop a plan that provides a pathway for solutions for fish and for people. The solutions are available. Fish in the river; rail to transport agricultural products; clean solar and wind to replace the small amount of hydro power produced by the dams. Imagine a restored river teeming with salmon as in the old days, with vibrant economies in local communities dependent on recreational and commercial fishing. Imagine orca pods flourishing, giving birth to healthy calves that survive rather than immediately dying of starvation.

Current economic studies show we are spending more to kill the fish than what it would cost to both save them and replace the transportation and hydropower services the dams provide. This DEIS is your opportunity to craft an innovative plan that offers a pathway to a comprehensive solution that works for all affected interests. Please take advantage of the moment.

Thank you for this opportunity to testify.

32. Harry Jageman moscow, ID

Idaho is about to lose its iconic salmon and steelhead and now is the time to act. Returns of salmon and steelhead to the Snake, Salmon and Clearwater basins are at an all-time low and in need of assistance. The recently released Columbia River System Operations EIS is totally inadequate to provide for salmon and steelhead recovery. The Preferred Alternative in the EIS just promises more of the same ineffective management actions that have failed to recover salmon and steelhead in the Columbia River basin in the past.

We need a new and bold approach that can only be delivered by congress and the president. Salmon and steelhead are part of the fabric of Idaho, and we will all be impoverished without them. Much debate has centered around the removal of the Lower Snake River dams and arguments for keeping the dams have largely focused on economic considerations. Unfortunately for the fish and Idaho, removal of the dams is not just an economic consideration. The dams threaten the very existence of salmon and steelhead in Idaho and the opportunity for our grandchildren to enjoy this tremendous resource.

Salmon and steelhead in the Columbia River Basin have maintained native people for centuries, and continue to offer economic stability to a variety of communities today such as Riggins and Orofino. The fish are good for our soul and we have a moral obligation to protect them. All of the current methods of moving fish through the Columbia River Dam Systems such as barging, spill and dam modification have not proven effective in recovery of the species. It is doubtful that slightly improved modifications in the EIS Preferred Alternative will offer much change.

The smolt-to-adult ratios (SARs) are really a telling measure of the impact of dams on salmon. Fish biologists consider a ratio of two adult fish per 100 smolts as minimum number for maintaining the existing population. For recovery, biologists consider would like to see SARs exceeding average SARs values of greater than 4%. Average SARs counts for wild steelhead (2006-2015) where 5.94 in the Deschutes River (2 dams), 6.06 in the John Day River (3 dams), 4.58 in the Yakima River (4 dams), and 1.84 in the Snake River Basin (8 dams) (Idaho Conservation League 2019).

Steelhead in the Deschutes, John Day and Yakima Rivers face the same ocean conditions and encounter the same predators at Bonneville Dam (terns and sea lions) as steelhead in the Snake River system, but have much higher SARs than populations in the Upper Snake River. The slow-moving pools behind the Snake River dams retard flows and significantly increase the time required for smolts to move to the ocean. Slow-moving pools also cause increased temperatures that can be lethal to salmon and steelhead. The pools favor fish species like bass, walleye and the pike minnow which prey on the smolts as they move downstream.

Yes, salmon and steelhead face other problems, but right now their biggest problem is the dams. Significant amounts of pristine and understocked spawning and rearing habitat exists in Idaho’s roadless areas. Places like the Salmon River, the Selway and the Lochsa River all offer opportunities for increased production of wild fish if they can just get there and if their offspring can make the return trip back to the ocean.

Finally, the economic problems associated with the removal of the dams are all solvable. Wheat can be moved by railroad, power can be generated by wind, solar or run of the river turbines, and irrigation pipes can be extended. Dam removal will also save money by reducing operation costs for dam maintenance, dredging and expensive bypass systems. Recovering the fish also has many positive economic benefits. Fishing guides, restaurants, hotels and the tourism industry will all benefit from strong fish runs. It is past time to remove the costly and lethal dams on the Snake River!

33. Jacob Schmidt Spokane, WA

(Commented on the 25th and the 31st)

Over the past few years I have heard an increasing concern about climate change and our ability to meet renewable energy goals from people and groups that have been silent on these issues in the past. I welcome the newfound interest in combatting the effects of a warming planet on our region, but would like to call attention to an issue with the hierarchy of their values.�

Climate change is a real threat to our region, but we must understand why that is. Warming temperatures mean warmer rivers and an increasingly acidified ocean. The series of dams on the lower snake and lower columbia rivers nullify the cooling properties of a free flowing river, creating a homogeneous body of slow, hot water. I have tracked the temperatures at the forebay of each dam and cross referenced it with the fish counts at those same dams and there is a clear correlation between hot water and dead fish that should be obvious to anyone who takes the time to look.�

While the power produced from hydro dams is cleaner than coal or gas fired plants, the dams themselves are accelerating the negative effects of climate change on endangered salmon and the hundred species that rely on them for food (including humans).�

Combatting climate change is not simply about shutting down coal plants and turning down the global temperature, it is about preserving ecosystems, food systems, and biodiversity. It is the salmon dependent communities of fishing towns, particularly those on native american reservations, that will suffer first and most if we do not put our values in the right order and take action to restore the lower snake river.���

-��

I am a citizen of Spokane Washington and I would like to voice a few issues I have with the CRSO Draft EIS. Having read the executive summary, I believe that this process is flawed from the outset. The stated objectives of this EIS are to operate the system in a way that "improves" fish survival [and you've divided that out into four parts] and also to provide low cost electricity with minimal GHG and a reliable water supply. The failure to meet Endangered Species Act benchmarks for salmon recovery is what instigated this renewed process in the first place, yet your own objectives fall far short of what would be required to achieve that and stay out of court for the 6th time. If you only seek to "improve" fish survival, rather than setting a more reasonable goal of "achieving fish recovery" you will never develop a plan that meets the ESA requirements. Why is it that when it comes to the power supply and the shipping channel, there is no room for failure, but when it comes to the fish, we give out points for trying?�

The preferred alternative draws heavily from the 2008 BiOp that was ruled inadequate, establishing the survival goal of 96% for juvenile migration at each dam in the Spring, and 93% at each dam in the summer. While that might sound like an impressive survival rate, when you multiply that over the 8 dams that Snake River basin fish must traverse, you get a 32 - 56 % die off of juvenile fish across the system, and that's IF you meet the goal that you have set for yourself. Allowing for that level of mortality at the projects themselves, not to mention the mortality that occurs at other points in the reservoir chain, we will never get close to recovery in the Snake Basin.�

The improvements at each of the four lower snake and four lower columbia dams have helped to achieve the survival rate that federal entities set as a goal, yet the salmon, steelhead, and the whole web of life that relies on them for food are still slipping toward extinction. Continuing down the road of installing extremely expensive bypass systems rather than taking an honest look at the value of the projects themselves makes neither biological nor fiscal sense.�

If the federal entities, and by extension, the tax and rate payers, ever want to be free of the high costs of ESA mandated salmon mitigation, then they need to work with regional stakeholders, sovereigns, and legislators to fund replacement infrastructure for the four lower snake river dams so that those dams can be removed. This action alone would be capable of reducing the river temperature from Pasco to Lewiston to a survivable level, which in turn would reduce predation of juvenile salmon and steelhead in that section of the river. I see this as a tremendous opportunity for the people of Eastern Washington, Oregon, and North Idaho to have a say in the overhaul of their road and rail network with federal and state money, while also receiving the benefits of a boom in recreation and ecology spending in their region. After all, it will take a lot of hands to replant the riparian zone of a free flowing Snake River and someone is going to have to feed all of the tourists who will come to catch steelhead.�

There is a bright future to be achieved, but the structure of this process will never bring us there.

34. Laurie Kerr Battle Ground, WA

Hello! My Name is Laurie Kerr and I live in Battle Ground, Wa. I grew up in PNW and visit San Juan Islands every summer. I am concerned about the potential loss of two keystone species, the Southern Resident Killer Whales and the salmon populations in the Columbia River. It is time to come together to come to a long term solution. The DEIS falls short of recommending dam breaching on the Lower Snake, which is the preferred action by scientists to help restore the salmon. Over $17 billion have been wasted as well as precious time in which we could have spent tax payers dollars more wisely and helped fishing communities along the coast. The federal agency approach only maintains a status quo and fails to resolve the core of the problem.

1. In the DEIS, a number of alternative strategies are listed. The Corps, Bureau and BPA have picked “MO4”. With respect to Columbia Basin salmon and steelhead recovery, the CRSODEIS preferred alternative (MO4) basically calls for a continuation of the status quo on the lower Snake River and lower Columbia River system and is, therefore entirely inadequate.

2. As stated in Chapter 2 of the Comparative Survival Study (CSS) Annual Report for 2019, "Among the federal alternatives, MO3 (the four dam breach alternative…) resulted in the highest SARs( Smolt to Adult Return) and in-river survivals…” In light of looming salmon and steelhead extinctions, MO3 (4-dam breach) must be implemented. Nothing less will enable fish survival.

3. The time has come for our 3-state governors and members of Congress to take leadership on this issue. The DEIS preferred alternative makes clear that our Federal agencies have failed to dramatically change course in order to meet the Northwest's fish-recovery challenge.

We also need to help farming and fishing communities, address climate impacts, and promote clean energy, as well as meeting our obligations to Tribal communities.

Fish hatcheries cannot meet the needs of restoration of wild fish populations due to the specific DNA characteristics of the wild salmon. Small river towns in Idaho rely on the salmon for their outdoor recreation industry, and generate $7.8 billion in consumer spending annually. This also provides 78,000 jobs and $2.3 billion in salaries and wages spread over the state.

The dams on the LSR only provide 4% of the needed power to this region. Studies by the NW Energy Coalition indicate that power from the LSR dams can be replaced by new renewable resources such as wind and solar with little or no increase in rates or greenhouse gases.

The solution is clear that we need to come together and address this salmon crisis with nonsense science-based solutions. Breach the dams to save our salmon before they become extinct in our lifetimes.

35. Daniel Drais Seattle, WA

My name is Dan Drais. Thanks to the action agencies for holding this session. I am a retired federal employee. As an environmental protection specialist at the Dept. of Transportation, I prepared and oversaw the preparation of dozens of environmental assessments and a number of Environmental Impact Statements. I also assisted our regional counsel in defending environmental documents. I have also worked on EISs as a lawyer in private practice and on the staffs of nonprofit organizations. Knowing what is involved in putting together an EIS, I have to say that I do not envy the team that had to prepare this one.

First, I agree with commenters describing the need for an extended comment period. My agency would likely have allowed an extended comment period for a document of this scope and importance even without a global pandemic interfering in the ability of the public and tribes and agencies to review and comment on it. I believe it is unwise and inefficient not to take advantage of the input at this stage of the process to make a better Final EIS, especially since you are on such a tight timeline, because the flaws that are not raised and addressed now may well lead to successful appeals further on. In my experience, robust and well-informed comments lead to much better final environmental statements.

Second, the EIS repeats over and over how it attempts to balance a number of competing demands. The Exec Summary summarizes them as (irrigation, navigation, recreation, power generation, fish and wildlife, fish migration, water supply, water quality, and flood management. But to the extent that the Endangered Species Act comes in to play, the action agencies do not have the authority to “balance” other interests. The ESA allows for the creation of a God Squad to determine if the government may violate the strictures of the Act; without the Squad, the agencies are bound to “conserve” the listed species, and “conserve” under the Act means to use all methods and procedures which are necessary to bring any endangered species or threatened species to the point at which the measures provided pursuant to this Act are no longer necessary. This is why the action agencies’ five Biological Opinions have all been rejected by federal courts – because they seek to justify doing something that is not lawful. And like the previous Biological Opinions, and as a prior commenter noted a few minutes ago, this EIS likewise falls fall short of bringing the listed species to recovery and satisfying the law.

Similarly, the action agencies must respect tribal sovereignty and the resources that those sovereigns deem critical. In its relations with tribes, the United States “has charged itself with moral obligations of the highest responsibility and trust” (Seminole Nation v. United States, 1942). It must similarly meet all of its treaty obligations to tribes. I can’t help but believe that many of the affected tribes will find that the Preferred Alternative falls far, far short of meeting those moral obligations and treaty commitments. Previous failures to treat the tribes fairly do not justify the continuation of such failures.

I will submit the rest of my comments in writing. For the record, I do not believe that the EIS is not now legally adequate to support taking an action. In closing, I’d like to quote Idaho congressman Mike Simpson: “Those dams produce 3,000 megawatts of power. You can put small modular reactors or other things in there. You can produce (power) differently. Everything we do, we can do differently. Salmon need one thing — they need a river.” Cong. Mike Simpson

36. Pete knutsen Commercial Fisherman Seattle, WA

I’m Pete Knutson, commercial fisherman. My family business, Loki Fish Company, supplies Seattle farmers’ markets with wild salmon. Additionally, we supply southeast Alaska and Puget Sound salmon to the West Coast and Midwest.

I began commercial fishing during the time that the Snake River dams were being constructed, in the early 70’s. Since then I have trolled off the coast of Washington, gillnetted and purse seined in southeast Alaska and longlined for halibut. I have a good overview of the state of West Coast fisheries, having served on the boards of the United Southeast Alaska Gillnetters, and the Puget Sound Harvesters. I also currently serve as a Commissioner on the Puget Sound Salmon Commission.

Our fisheries have been enormously impacted by habitat destruction. On the Columbia River, the declines have been precipitous. Beginning with Grand Coulee dam built 350 feet high with no fish ladder and later with the Snake River dam construction, the impacts on salmon have been felt up and down the West Coast of the US and Canada.

We need to understand that dam construction was not only an addition to the agricultural economy, but was also a subtraction from an existing economy, an economy of tribal nations and fishery dependent communities. Dam construction was subsidized not only by Federal dollars, but also by the destruction of the river’s wild ecosystem and the impacts on fishery dependent communities. It’s now time to begin rectifying that heedlessness.

Dam removal should be thought of as an economic development project. They are hundred of miles of blocked habitat above the Snake Dams. And then there’s the Salmon River, without dams, and without salmon. Consider the quick restoration that has occurred with the removal of the Elwha Dams on the Olympic Peninsula. 

We’re in a planetary climate crisis. We must evaluate our impacts in terms of long lasting sustainability. Humans could never invent a machine as efficient as wild salmon. They go out to the ocean, harvest the photosynthetic work done by the plankton and bring it right back to our doorstep. That cannot be improved on, only restored and protected.

It’s time to give the fish on the Columbia system a break and breach the unnecessary and damaging Snake River dams.

37. Kat Murphy Commercial Fisherman Port Townsend, WA

Hello. My name is Kat Murphy and I am a commercial fisherman.

I own a power troll fishing permit through the state of Alaska but Port Townsend, WA is my home. I purchased my boat and permit two years ago and started a small direct market fish business.

I could only afford to purchase one permit and I had to decide between purchasing a permit in my home state of Washington or in Southeast Alaska. I chose Alaska because I came to the conclusion that I could not make a living as a young entrepreneur in my own home state. A sobering fact that I hope can change in the future.

I would like to see more economic opportunity for young people like me in Washington State’s rural coastal communities. There are limited job opportunities where I live and direct marketing a portion of my frozen catch from Alaska is my only way of contributing to the bolstering of my local economy. I am a one-fish-at-a-time, hook and line operation, and I am a CHOICE people make when they purchase their fish. I’d like that choice to be able to continue for future generations.

Recently, I participated in a panel discussion on jobs in food production at a local high school. It was hard to know that if we don’t do our part now I cannot guarantee these kids a future in my industry or food from the waters of the Pacific Northwest, something that should be their birthright.

The latest DEIS fails to protect salmon and in turn orcas. I am asking you to remove the lower Snake River dams and restore critical salmon habitat. Simply stated: Wild animals need wild lands and the United Nations Conference on Sustainable Fisheries deemed eating wild fish the greenest way to ingest protein on the planet. Let’s do our part to keep it that way!

Thank you for your time and consideration.

38. Rebecca Sayre ?, WA

Good afternoon, my name is Rebecca Sayre. Thank you for this opportunity to speak today. I am a concerned Washington citizen.

Findings show that only dam removal will restore Chinook runs in the Snake-Columbia River system. The preferred alternative uses outdated data and is woefully inadequate; essentially a continuation of policies that have been failing science and repeatedly found illegal for well-over 25 years. I'll say it again, dam removal has been found to be the best way to restore the salmon runs of the Columbia-Snake system. This option is the appropriate action in this time of extinction crisis for both salmon and our orca. Can you believe we've come to this? We must solve this problem, including providing thoughtful mitigation of the impacts to the communities that have to deal with the brunt of the changes. Yes, this means we must accomplish big, complex things; which we can do when we work together.

This unprecedented time we are in, dealing with the Corona virus, is showing us how our communities can work together in the face of big challenges.

The benefits of the dams and the barriers to updating systems are exaggerated. Barging, wheat farming, irrigation and the utilities financial crisis can be addressed. Furthermore, studies show that the 7-8 % of statewide energy that these dams produce can be produced through the growing and evolving technologies of solar, wind, and conservation. Our state is a leader on these fronts and we should be embracing our future, as opposed to clinging to the past.

Also, we can redirect moneys currently being wasted on fish barging and maintenance of these crumbling structures to transition our systems and support the local communities in their efforts to modernize. We need to be bold - now is the time. We can come together and do this. In so, we will collaboratively restore lands, rapids, recreational business, fisheries, tribal treaty rights and more in the process. We can all thrive and it is time to create region-wide solutions as opposed to fighting over parochial concerns.

I want to address a few earlier comments. The Southern Resident Killer Whales feed at the mouth of the Columbia and Klamath rivers during winter and spring. Yes, we must clean up the Puget Sound and curb fishing, as others have said, but that is a red herring. The food source needed must come from this river system. Also, dam removal is not radical. In fact, it is occurring the world over as communities factor in new knowledge about the impacts of these 20th century technologies. Yes, these are technical and complex problems to solve, but not as difficult, or even impossible, as some would convey. We are innovators in this state, are we not? We can fight to retain a failing status quo or we can lead the way towards a healthy and balanced future.

I leave you with this - What is the legacy you want to leave? Do you create a system that has room for people and wildlife or do you want to preside over the extinction of one of the world's greatest ecological systems because of lack of vision and for short-term gain? What is the story that you want your grandchildren to remember?

39. J Michael Short Pullman, WA

This is my statement regarding the Lower Snake River, submitted as part of the DEIS public comment process which I gave on March 31, 2020.

My parents, Jim and Kelma Short, moved to Pullman from the Midwest in 1951 when my father took a position on the faculty at the Washington State College. They immediately fell in love with the region and fully took advantage of its abundance of natural treasures. My father and several of his closest friends and colleagues from the college spent considerable amounts of time hunting and fishing along the nearby Snake River, supplementing what their meager salaries could purchase with abundant fish and game. They loved every minute of it. I have the old black-and-white photos that show their pride and joy.

I was born in 1955 and grew up hunting and fishing, hiking and camping along the Snake River when it ran wild and free. We picked fruit from the orchards at Wawawai. I have memories of stopping in at the Wawawai Store for a candy bar on many a hunting trip, and of swimming in the current of the river while waiting for the Lyons Ferry to arrive and take us across the river at a time when an archaeological crew from WSU was frantically excavating Marmes Rockshelter before it was flooded out by the rising waters behind Lower Monumental Dam.

I learned to technical rock climb at Granite Point, but by that time, in the early 1970s, clearing and construction for Lower Granite Dam was well underway. The orchards, where only a few years earlier we had picked peaches and apricots were gone. The old Wawawai Store was nothing more than a ruin, soon to be completely demolished.

I watched as a river, once wild and free, was turned into a series of slack-water reservoirs. A once wondrous and thriving river community and semi-wild ecosystem turned into something that looks almost lifeless to me. To this very day it breaks my heart to see.

I would hope by now that we might have learned that natural systems are the most productive and abundant systems. We can't completely turn back the clock on 2 centuries of various forms of habitat destruction, but removing the 4 LSR dams would be a great start to restoring healthy populations of our wild salmon and steelhead runs.

Attempting to over-engineer these systems with dams, hatcheries, fish bypass systems and the like has not worked and will not restore these fisheries.

Reflecting on the place of the Snake River in my life, I quote from author David James Duncan on his relationship to the Pacific Northwest:

“I would describe my relationship with that region as an endless love affair, full of heartbreak. But there is wonder even in heartbreak. In my experience, the heart doesn't just break into pieces. It sometimes

breaks open, increasing empathy; increasing our sense of connection to others; increasing a fierce capacity to see clearly, grim as it is, and still love.”

I remain hopeful that connection, empathy and love will prevail... that I may live to see the Lower Snake River once again with healthy salmon and steelhead runs, wild and free.

40. Whitney Neugebauer Whale Scout, Director BOthell, WA

My name is Whitney Neugebauer and I am the Director of Whale Scout. We’re a nonprofit based out of Bothell, Washington.

The majority of our work is focused on protecting whales through education, advocacy, and on the ground salmon habitat restoration projects. Volunteers spend close to 1,000 hours each year directly working to plant trees and otherwise reverse environmental damage to benefit salmon and therefore salmon- eating orcas.

Governor Inslee’s Orca Task Force launched a stakeholder process looking at the lower Snake River dam issue and found that local communities are wanting to engage in constructive dialog outside of a cycle of back and forth litigation. This federal report is too constrained to reach the creative solutions our region (both the people and the fish and wildlife) need. We need leadership from our elected officials to move through this together.

That being said, the DEIS Prefered alternative does not set us up for salmon recovery nor does it make meaningful benefits to federally listed killer whales.

The DEIS underrepresents the importance of Columbia basin salmon in the diet and fitness of Southern Resident killer whales.

• Southern Resident killer whales need salmon from a variety of river systems throughout the entire West Coast - they cannot depend on 2-3 river systems or seasonal periods of abundance to provide adequate prey resources

• Southern Resident killer whales spend over half of the year in coastal waters • During that time, Columbia basin salmon comprise over half of their diet • Spring Chinook are of particular importance for Southern Resident killer whales • We will follow up with additional written comments providing sources of scientific information

not sited in the DEIS.

Dam breaching (MO3) gives salmon the best chance of recovery of the alternatives presented in the DEIS. However, agencies should also consider another option to breach the four lower Snake River dams and utilize “spill” at the Columbia River dams to 125% TDG. This results in the best scenario for salmon recovery. This management option is outlined in detail as the “MO34” alternative proposed by the Fish Passage Center in Chapter 2 of their Comparative Survival Study 2019 report.

Regional communities including those coastal towns in OR and WA can and should benefit from breaching of the lower Snake River dams

• Tribes have been unfairly impacted by the hydropower projects and loss of resources including salmon.

• Investments in clean energy can address the needs of the energy grid moving forward • Investments in transportation and irrigation can help offset potential losses for local farms

Thank you for your thoughtful consideration.

41. Felice Kelly (@felice_outdoors) Great Old Broads Portland, OR

Time is running out for wild salmon, which are an essential part of the heritage and the ecosystem of the pacific northwest! The preferred alternative in this plan, M04, perpetuates a status quo that has that has completely failed to restore wild salmon populations. The option to breach the dams, M03, has the highest rate of predicted smolt-to-adult returns, the key measure of whether salmon can recover. The warm water in the reservoirs above dams is not significantly addressed by M04, and this problem will get worse as global warming progresses. Please choose the to breach the lower four Snake River dams and give wild salmon a fighting chance. 42. Bob Francis Professor Emeritus, School of Aquatic and Fishery Sciences, University of Washington Port Townsend, WA

My name is Robert Francis, Professor Emeritus in the School of Aquatic and Fishery Sciences, University of Washington. From 1986 – 1992, I was Director of the UW Fisheries Research Institute (FRI) which, for over 60 years, has carried out substantial research on the sockeye salmon resource and fisheries of the Bristol Bay region of Alaska. I was a member of the PFMC SSC from (aprox) 1990 – 2000 and a board member of Pacific Marine Conservation Council from (aprox) 2000 – 2005. Starting in the mid 1990s, my research involved developing an understanding of the effects of 20th century climate variability on the marine resources of the coastal NE Pacific Ocean and E Bering Sea, culminating in the discovery and naming of the Pacific Decadal Oscillation (PDO), a large scale climate process significantly affecting coastal marine resources extending from California to Western Alaska.

I have been retired for over a decade and I have no direct connection to the issue being addressed by this DEIS. However while I was still active, my colleagues in FRI and Atmosphere Sciences and I have published on the relationships between climate and biocomplexity of sustainable salmon resources.

Over 60 years of FRI research in the Bristol Bay region of Alaska combined with detailed records of harvest for over a century has showed that biocomplexity, a portfolio of diverse life history characteristics and local adaptations to the variation in spawning and rearing habitats in the Bristol Bay region, has enabled the aggregate of populations to sustain its productivity despite major changes in climatic conditions affecting the freshwater and marine environments. This research has been able to demonstrate that biocomplexity of fish stocks is critical for maintaining their resilience to environmental change.

Prof Daniel Schindler and colleagues at FRI show that biocomplexity at the species level buffers year to year variability in total resource and fishery variability. In a 2010 paper in Nature, Schindler and colleagues used years of FRI fish counts to show that even though annual fish numbers fluctuate dramatically in individual streams or river systems, the overall numbers in Bristol Bay hold remarkable steady. That’s because, most years, some waters somewhere are producing salmon even when others

aren’t. They dubbed this resilience the portfolio effect, which is analogous to the effects of asset diversity on the stability of financial portfolios.

Furthermore, they write, “Variability in annual Bristol Bay salmon returns is 2.2 times lower than it would be if the system consisted of a single homogeneous population rather than the several hundred discrete populations it currently consists of. Furthermore, if it were a single homogeneous population, such increased variability would lead to ten times more frequent fisheries closures.”

Based on detailed sampling from 2011 to 2015 of sockeye and chinook salmon in one of the major Bristol Bay watersheds, Brennan and colleagues at FRI show how shifting habitat mosaics are a central feature of what makes salmonid ecosystems resilient. The implications of their pioneering research is that “conservation of the processes that generate and maintain heterogeneity and connectivity across landscapes (e.g. fires, floods, and migration) is as important as the biological communities that they support.”

My collaboration with Dr. Nathan Mantua (now with NMFS Santa Cruz) has shown that natural climate insurance for PNW salmon and salmon fisheries can be enhanced by restoring and maintaining healthy, complex, and connected freshwater and estuarine habitat and ensuring adequate spawner escapements, thus promoting the expression of biocomplexity of individual resources. We wrote, “If we are interested in purchasing long-term climate insurance for wild salmon so they can better cope with changing (unpredictable) ocean conditions, we will likely get the best return on investments aimed at restoring the health and integrity of our beleaguered watersheds.”

Quoting SOS, “Scientists tell us – and DEIS agrees – that the single best action we can take to recover endangered salmon is to restore the lower Snake River by removing its four dams.” The habitat that would open up is just what is needed to generate an explosion of biocomplexity needed to create healthy, complex and connected spawning and rearing habitat, a stable portfolio, for wild PNW salmon.

References:

Brennan, S.R. et al. 2019. Shifting Habitat Mosaics and Fish Production Across River Basins. Science 364.

Cornwall, W. 2019. Minefield. Science 365

Hilborn, R. et al. 2003. Biocomplexity and Fisheries Sustainability. PNAS 100

Mantua, N.J. 2015. Shifting patterns in Pacific Climate, West Coast Salmon Survival Rates, and Increased Volatility in Ecosystem Services. Proceedings of the National Academy of Sciences (PNAS)

Mantua, N. and R.C. Francis. 2004. Natural Climate Insurance for Pacific Northwest Salmon and Salmon Fisheries: Finding Our Way through the Entangled Bank. Am Fish. Soc. Symp. 43

Schindler, D.E. et al. 2010. Population Diversity and the Portfolio Effect in an Exploited Species. Nature 465.

42. Rick Putnam and Madeleine Wiley Bellevue, WA

I spent a lot of time this past weekend, reading a great deal of the EIS report, looking at the various alternatives, and then I got to chapter 7 titled, ”Preferred Alternative” But wait a minute, I thought, where is there some kind of analysis that takes all the pros and cons of the alternatives and evaluates them again the goals. How can you just jump to the “Solution” without considering the

choices? Especially in something this complicated… where is the objective, numerical, quantitative, repeatable analysis?

Ok, there isn’t any such analysis, there is only the subjective, intuitive discussion, but let’s see what it says… Chapter 7.2 says: (slightly edited for brevity)

“The co-lead agencies determined that the No Action Alternative, MO1, MO2, and MO4 allow for the operation of the projects (meaning dams) in furtherance of all of the congressionally authorized purposes to varying degrees. Alternative MO3 would not meet the congressionally authorized purposes of operating and maintaining the four lower Snake River dams for navigation, hydropower, recreation, and irrigation. New congressional authority through new laws and associated funding would be required to implement dam breaching measures.”

So… to summarize what I just read, the three agencies, do one thing. They build and maintain dams. That is their life. That is their “congressional authorization” (MAGIC WORDS). If you want to remove the dams, go get Congress to authorize that and get some money, because it will not happen with the local Corp of Engineers, or BPA, or Bureau of Reclamation.

That’s their story, but it is totally wrong. Those magic words: “congressional authorization” are a smoke screen by the local lead agencies to make us believe that they can’t take out the dams. In fact, they could do that very thing without additional “congressional authorization”.

It doesn’t take congress to decommission a Navy ship, like it didn’t take Congressional action for the Portland Corp of Engineers to decommission the Willamette Lock and Dam in Portland. It’s part of what they are responsible for.

Let me say this in simpler terms. This EIS was a huge waste of time. Waste of our time reading and responding to a sham EIS, and four-year waste of government time and money to put out a 4000-page report that could have been written in ONE simple paragraph.

I’ll give you an example of what the report could have said:

We, the Corp of Engineers, the Bureau of Reclamation and the Bonneville Power Administration, are the three lead agencies in charge of a subset of dams on the Columbia and Snake Rivers. We like Dams. They are what we do… we build them, maintain them, and manage them. We could decommission them and breach them if we wanted to, but we don’t want to.

And we are going to try to convince you that “congressional authorization” is required to do that . In the meantime, we are going to continue with the status quo with a few modifications to the spill rates and fish ladders and some other minor tweaks to make it look like we are solving the salmon problem.

We only did this EIS because the court ordered us to, and we included dam breaching as one possible alternative, because the courts said we had to, but we will never recommend that.

PS: Sorry about your fish. Good luck with that.

See, that was a lot simpler, and has a much more honest result. Could have been done four years ago, saved a lot of time and money, and it would have given the rest of us a four-year head-start on trying to save the salmon and the Orcas.

I got angry when I realized that the three agencies have just been kicking the can down the road again, but they actually did us a favor. They stated as clearly as they could in just a few sentences that they are not interested in really solving the salmon recovery problem.

We have been talking to and expecting help from the wrong people. Those three agencies are people that are motivated to keep the dams, their jobs and control of the lower Snake River. What we really need is some pressure put on the Corp to work for the good of the country and the salmon and the Orcas. We need help from people like Senator’s Murray and Cantwell, and Representative Simpson of Idaho and

governors Brown and Inslee to put pressure on the Corp to breach the dams NOW… using the Corp’s own authority, not additional Congressional authorization.

We are smart people… when President Kennedy said that we (the USA) was going to go to the moon, he meant it and we did it. It was 1962 when he said:

“We choose to go to the moon. We choose to go to the moon in this decade and do other things, not because they are easy, but because they are hard, because that goal will serve to organize and measure the best of our energies and skills, because that challenge is one that we are willing to accept, one we are unwilling to postpone, and one which we intend to win…”

It wasn’t something that took 25 years of debate and obfuscation and lawsuits and a hundred million dollars of EIS reports. Neil Armstrong stepped out onto the moon less than 8 years later.

Finally, we need to find some people that like fish, not just dams. This damn situation is not more complicated than going to the moon for heaven’s sake.

43. Colleen Wheiler Whale Dolphin Conservation Newport, OR

My name is Colleen Weiler, I am the Jessica Rekos Fellow for Orca Conservation with Whale and Dolphin Conservation, and I live in Newport, OR. I would first like to say that the short time allowed for this comment period, particularly in the midst of a global crisis, is insufficient for the public to review and provide important input. The rushed timeline adopted by the agencies also limits their ability to fully consider the extensive ecosystem impacts of the CRSO, and the DEIS is lacking information in several key areas – especially on the Southern Resident orcas. The primary threat to the survival of this unique population is a lack of their main food, Chinook salmon, throughout their range.

Data increasingly shows that salmon from various river systems in the Pacific Northwest and California are important to the Southern Resident orcas at different times of the year, and the movement of the orcas through their habitat is tied to the return of Chinook salmon to major river systems, including the Columbia. Research from the National Marine Fisheries Service shows that the mouth of the Columbia River is a hotspot for the orcas, and that more than half the time they spend in coastal waters is in the area between the Columbia and Grays Harbor. Chinook salmon from the Columbia Basin specifically comprise more than half of the Chinook consumed by the orcas when they are in coastal waters. However, the DEIS does not include any of this information in its review, and therefore grossly underrepresents the importance of Columbia and Snake River salmon to the survival of Southern Resident orcas.

We support breaching the four Lower Snake River dams and maximizing spill at other dams to improve salmon survival and increase prey availability for Southern Resident orcas. The Preferred Alternative in the DEIS is only a minor adjustment to status quo conditions, which has not been sufficient to support the recovery of Columbia Basin Chinook or Southern Resident orcas. The DEIS does not offer the region-wide discussions or solutions that will be necessary to support this transition, and will not be enough to support NW tribes and communities. A restored Snake River provides ecosystem-wide benefits that support a healthy river, habitat, and communities, but the DEIS and federal agencies alone cannot

accomplish this. This is a time for NW policymakers, stakeholders, leaders, and communities to work together to create inclusive, science-based, supportive solutions to these region-wide issues.

Southern Resident orcas need more salmon. Salmon need healthy rivers. And PNW communities need certainty. This process is a stepping stone in moving toward a solution that works for all parties, but it alone will not support endangered species recovery or solutions for transitions. Thank you for the opportunity to comment and I yield the remainder of my time.