ISAB Critiques A-Fish Process, Conclusionsby Barry Espenson
Columbia Basin Bulletin, November 19, 1999
Neither initial conclusions reached in large part from PATH analyses, nor an addendum to National Marine Fisheries Service's Anadromous Fish Appendix, utilizing the agency's own scientific analysis, are the stuff from which dam breaching decisions should be made, according to reviews penned by the Independent Scientific Advisory Panel.
The 11-member ISAB completed reviews over the past month of NMFS' draft appendix to the Corps of Engineers "Lower Snake River Juvenile Salmonid Migration Feasibility Study," which was released April 14, and a draft Cumulative Risk Analysis addendum to the appendix. The latter document, which describes the NMFS' science center's developing analytical initiative, was submitted for review on Aug. 9.
The comments of the ISAB and from the Columbia Basin Inter-Tribal Fish Commission, the Idaho Department of Fish and Game and others will be responded to in the AFA's next incarnation. That rewrite is under way and will be presented with the release of the Corps' draft EIS in December, said Will Stelle, NMFS regional director.
"We have made major revisions to the A-Fish appendix based on those reviews," Stelle said.
Both documents have their technical shortcomings, according to the ISAB, and give unsubstantiated weight to a "delay" option for decision makers. A summary of the ISAB comments on the original draft Anadromous Fish Appendix (AFA) follows. (See summary of the Cumulative Risk Analysis addendum.)
The team of scientists was formed jointly by NMFS and the Northwest Power Planning Council to provide independent scientific advice on fish and wildlife recovery issues. It was called on to critique the biological appendix to the Corps' $20 million study of how to improve juvenile salmon passage down through the four Lower Snake River hydroelectric projects.
A draft of that EIS is due out just before Christmas. The Corps study aims to portray the biological and economic costs and benefits of three primary hydrosystem alternatives -- continuing the status quo operations, making major improvement in bypass systems or breaching the four dams.
The study was called for in NMFS' 1995 biological opinion on the effects of federal hydrosystem operations on salmon listed under the Endangered Species Act. NMFS so-called Anadromous Fish Appendix to the EIS is titled "An Assessment of Lower Snake River Hydrosystem Alternatives on Survival and Recovery of Snake River Salmonids." Plan for Analyzing and Testing Hypotheses (PATH) was formed with representation from tribes, state and federal agencies, academia and other entities to provide scientific analysis of ESA issues.
NMFS' biological appendix to the EIS made three primary conclusions, according to the ISAB review:
The ISAB expressed doubts about the validity of those conclusions.
"The AFA seems to imply that it provides a basis for the salmon extinction risk considerations that bear on the decision that eventually needs to be made about dam breaching and transportation. Further, the AFA seems to imply that it provides a basis for evaluating the merits of possibly deferring any commitment on the dam breaching decisions on grounds that important uncertainties may be resolved in the interim. We are not entirely comfortable with that message."
Later in the document the ISAB notes that "PATH did not formally analyze the 'delay option' so it is all the more worrisome that the AFA throws this option on the table without sufficient analysis." The AFA's discussion of delay, "which will doubtless prove attractive to hard-pressed decision makers, is much too casual."
The ISAB went on to say that, given the uncertainties, delay is an option to be considered but must be done so in much greater detail.
Among the uncertainties cited in the AFA are "differential delayed transportation mortality," the effect of estuary and ocean conditions on fish and unexplained or "extra mortality" that may or may not be tied to the hydrosystem. Delayed mortality refers to negative effects barge and truck transportation may have on fish that could reduce their ability to survive. The AFA stated that delaying decisions to try solve those uncertainties involves risk to fish survival.
The ISAB in its review said they suspected the "uncertainties have been understated, and we are very concerned that insufficient attention has been paid to trying to quantify analysis of the third conclusion, advancing a delay option."
"The implicit argument in the AFA in favor of delaying the hydrosystem decision does not adequately evaluate the biological costs or benefits of delay, and does not specify the substantial commitments and investments that would be necessary in order for the benefits of delay to be realized."
The ISAB advised NMFS and its scientists to sharpen their pencils.
"The inadequacy of the AFA analysis for evaluating the "delay" option, which the AFA puts on the table, is even more stark. A decision maker who wishes to responsibly weigh the merits of choosing "delay," needs to know that the following quantities that should be supplied by technical analysis:
"With the answers to these questions in hand, the decision maker could take this technical scientific information, considered in its social and economic context, and decide whether the balance of biological risks and economic costs favor delay, or argue against delay," the ISAB wrote.
Early in its review document the ISAB leveled criticism at the analytical approaches and methods used.
"Perhaps the most disturbing of the shortcomings of the AFA analysis, in our opinion, is the attempt to isolate decisions about the hydrosystem from decisions about environmental management affecting the rest of the Columbia ecosystem as it impinges on the life cycle of salmon," the ISAB wrote.
The AFA analyses focused on breaching or not breaching with maximized transportation of juvenile fish past the four dams.
"Implicit in this analysis is the proviso, 'all other things being equal,' where the list of all other things includes hatchery operations, harvest regulations, tributary habitat conditions subject to potential restoration or additional degradation, estuarine habitat conditions subject to the effects of flow management, mainstem predator populations, and ocean conditions.
"We note that the common currency of results of the analysis reported in the AFA are predictions of the "relative probability of recovery" and "relative probability of survival" of index stocks. Poor management of the rest of the Columbia ecosystem could result in essentially zero probability of survival and recovery, regardless of the decisions to breach or not, or transport or not.
"Similarly, it is at least imaginable that extreme investment in ameliorating losses and enhancing the rest of the ecosystem might essentially guarantee survival and recovery, regardless of the decisions to breach or not, or transport or not.
"Thus, the implicit assumption of status quo with respect to management of the rest of the ecosystem is, at a minimum, disingenuous," the ISAB wrote.
The panel also frowned on an "over-reliance on optimistic scenarios" accorded to populations' recovery prospects and questioned success criterion used in the analysis.
"We do not believe that the 'survival criterion' and 'recovery criterion' used in the AFA are in tune with current best scientific understanding for crafting survival criteria and recovery criteria for ESA applications."
The scientific panel went on to chide the federal agency for "insufficient NMFS ownership of the analysis."
"Given the probable role of the AFA analyses in an eventual new "hydropower decision" that is solely NMFS' responsibility under the ESA, it would be appropriate for NMFS to be in a better position to explain, take responsibility for, and make accessible, the modeling assumptions, the modeling results, and underlying data analyses that it will use at that time," the report reads.
The independent scientists called PATH's modeling "extraordinarily convoluted" and said that it would be difficult to duplicate by NMFS or anyone else.
"Full ownership" of the process by NMFS is all the more important given the several alternative assumptions or assumptions sets used by PATH.
"This puts a premium on carefully diagnosing the influence of the assumptions on the model results, dissecting the evidence supporting the respective alternative assumptions, weighting each alternative appropriately, and dealing thoughtfully with the impasse that results if the choices cannot be resolved on the basis of statistical evaluation of available data.
"It is difficult to carry out such investigation at arm's length, which, however, was the relation between NMFS and PATH," the report continues.
ISAB A-Fish Review
learn more on topics covered in the film
see the video
read the script
learn the songs