This is the detailed appendix to the Research Paper titled “Is Chinook Recovery Harmed by a Great Misdiagnosis?” presented by Save Family Farming.

The research paper provides an overview showing that the main cause of Chinook salmon decline is ocean mortality. This is caused by 1) warming ocean conditions which uniquely affect Chinook, and 2) by the exponential growth of pinniped predators particularly in the Salish Sea.

Citizens need to know about the abundance of most Pacific salmon, and see that dams, riparian habitat, and water use by farmers are not significant causes of Chinook decline. The solutions advocates propose such as dam removal and massive buffers would cause great harm and do little to nothing to recover Chinook runs. The studies documented here show that if the solutions proposed are implemented irreparable harm will result, with little to no Chinook recovery to compensate for the harm done.

Download Appendix
ADDENDUM: Dams are not the solution to salmon recovery
Download Testimony of Fish & Wildlife Biologist

Section 1: Most salmon species at record levels while Chinook suffer
1.1 Alaska Public Radio July 2023 report on Chinook and sockeye harvest
1.2 Historic abundance of Pacific salmon

Section 2: Chinook will not recover based on dam removal
2.1 BC science study documents Chinook decline worse on rivers without dams
2.2 Chinook returns on Elwha dam disappointing after removal
2.3 Latent or delayed mortality not likely caused by fish passage
2.4 Fish passage success: Baker Dam on Skagit river
2.5 Fish passage success on lower Snake river dams

Section 3: Ocean warming and Chinook declines
3.1 NOAA, Sierra Club and many studies point to ocean warming
3.2 Impact of the “blob”

Section 4: Predation and Chinook declines
4.1 NOAA Chasco study documents predation by protected mammals specific to Salish Sea
4.2 Congressional action against protected mammals to protect salmon
4.3 Tribal leaders, Washington scientists and a policy think tank call for predator control

Section 5: Federal agencies concluded that dams need to remain

Section 6: High cost of ineffective solutions
6.1 Dams: Costs of removing four lower Snake river dams
6.2 Dams: Replacing green power produced by dams
6.3 Dams: Impact on farms from loss of barge transportation
6.4 Dams: Environmental impact of loss of barge transportation
6.5 Dams: Impact on communities

Section 7: Contribution of hatcheries to Chinook recovery
7.1 Wild and hatchery production increasing
7.2 Pink salmon hatcheries and abundance
7.3 Chinook hatchery production in comparison
7.4 High cost of Chinook hatchery production

Section 8: False narratives of salmon recovery advocates
8.1 NOAA demonstrates politics takes priority over science
8.2 Dam advocates and media reports are primary sources of misdiagnosis

Section 9: Adjudication, water rights, irrigation and infrastructure

Section 10: Large, inflexible buffers

Section 11: Flooding and storage

Addendum: Dams are not the solution to salmon recovery

Chinook are often called “king salmon.”
Their lifecycle is complicated but results in fat content and flavor preferred by most.

As the accumulation of research documented here shows, Chinook numbers are in decline largely because of their unique challenges in dealing with warming ocean conditions. Also, because they are targeted by killer whales and protected pinnipeds such as harbor seals and sea lions.

The Salish Sea (northern Puget Sound, Straits of San Juan and Georgia) loses over 25 million Chinook to harbor seals alone. 84% of all Chinook consumed by harbor seals from Alaska to California are consumed in this one area alone. The predation problem is uniquely focused on this one small area in the North Pacific.

Section 1: Most salmon species at record levels while Chinook suffer

1.1 Alaska July 2023 public radio report

The NPR station KDLG of Dillingham, AK on July 7, 2023 reported Bristol Bay sockeye harvests and returns were at record levels. Nushagak River sockeye harvest at that time was 22 million, three times the 20 year average. In Bristol Bay there were 79 million sockeye harvested, up 80% over 20 year average. But Chinook harvest stopped due to numbers below escapement of 55,000 in Nushagak. By July 6 only 28,000 had returned.

1.2 Historic abundance of Pacific salmon, Ruggerone and Conners, 2022:

Fisheries scientists Gergory Ruggerone and James Irvine commented in a guest column on February 3, 2022:

“The numbers of Pacific salmon surviving to adulthood increased following the 1977 ocean regime shift, peaking in 2018 when approximately 950 million pink, chum, and sockeye salmon returned from the ocean. This increase was likely the result of favorable ocean conditions combined with the release of large numbers of hatchery-origin juvenile salmon. Releases of hatchery salmon into the North Pacific reached approximately 5.5 billion juvenile salmon in 2019, a sharp increase since the 1960s when approximately 0.6 billion hatchery salmon were released each year. Approximately 40% of the total salmon biomass in the Pacific during 1990 to 2015 was made up of hatchery salmon, especially chum and pink salmon. Clearly hatchery salmon are now key components of the epipelagic North Pacific Ocean.”

The North Pacific Ocean from Alaska to California enjoys an historic abundance of most species of salmon. Sadly, Chinook are not included in this abundance for the reasons identified in this appendix.

“But pinks aren’t the only salmon species that is booming. In recent years, there have been more salmon in the North Pacific than there have been at any point in the last century.”

An August 14 report in a Ballard (Seattle neighborhood) newspaper said the Ballard Locks were “chock full of salmon right now.” These include Chinook. Counts are from 16,000 salmon in 2019 to likely 50,000 this season.

Section 2: Chinook will not recover based on dam removal

This graphic shows no dams on the Fraser River in BC and numerous dams on the Columbia and Snake Rivers. But, Chinook salmon are faring worse on many of the rivers and streams without dams than those with dams. This is completely contrary to the narrative sold by media and advocates seeking to remove the four Lower Snake River Dams.

2.1 BC study shows Chinook decline widespread, worse on river systems without dams

The Kintama study shows river systems without dams or human-caused obstacles are no better, and in some cases worse, in adult Chinook returns. The study was published September 2020 in Fish and Fisheries titled: “A synthesis of the coast-wide decline in survival of West Coast Chinook Salmon”. In the course of conducting a different study, the research scientists discovered in Georgia Strait:

“that Chinook survival in many rivers of the Strait of Georgia region had fallen to levels well below those reported for Snake River Chinook.”

This is significant because the focus of Chinook advocates and the media reporting on recovery efforts is primarily on the Snake river system. The four lower Snake river dams are seen as a primary cause of Chinook decline and the greatest obstacle to recovery. This study clearly demonstrated that is not the case. If the dams were the problem then other river systems would show much stronger returns. Smolt-to-adult (SARs) is the key measurement of run strength as it shows how many adult salmon return to their spawning areas compared to the number of smolts that left. The authors wrote:

“Within the Columbia River, the SARs of Snake River populations, often singled out as exemplars of poor survival, are unexceptional and in fact higher than estimates reported from many other regions of the west coast lacking  dams.  Given  the  seemingly  congruent  decline  in  SARs  to  similar  levels,  the  notion  that  contemporary  survival  is  driven  primarily  by  broader  oceanic  factors  rather than local factors should be considered.”

The study area included the entire West Coast, and the study provided results consistent with the more recent Alaska report above:

“We show that, overall, Chinook salmon survival (SAR) has decreased by roughly the same amount everywhere along the west coast of North America and has now reached similar or lower survival levels than Snake River stocks.”

The authors repeatedly point out that the data do not support the conventional wisdom that the Snake river has unique problems with Chinook returns that are directly related to dams. The fact of general decline, including in Asia Chinook, points to ocean conditions as the Alaska fisheries scientists showed:

“The similar timing of the decline in the Salish Sea, west coast of Vancouver Island, and Columbia River Basin suggests the primary influence of a broad ocean driver (Beamish, 1993; Beamish & Bouillon, 1993; Mantua et al., 1997). The evidence for a roughly similar drop in Asian Chinook catches reviewed above also indicates that the geographic footprint of any ocean (or freshwater) driver must either be large or that many populations must migrate to common geographic regions where their survival can be similarly reduced.”

The Snake River Chinook populations are actually doing better than river systems with no dams or other human infrastructure, which they refer to as “anthropogenic freshwater habitat impacts.” In short, the conventional wisdom that habitat is the limiting factor is incorrect. The evidence suggests that especially the Snake River dams are having a minimal affect on salmon, particularly in comparison to rivers without dams. This study makes very clear a central point of this paper on misdiagnosis: removing dams would not improve salmon returns despite the very high cost:

“The recent recognition of the decline in Chinook returns across essentially all of Alaska and the Canadian portion of the Yukon River, where anthropogenic freshwater habitat impacts are negligible, is another example of how simple explanations are potentially flawed. If survival across this vast swathe of relatively pristine territory is severe enough to seriously impact salmon productivity, then there is little hope that modifying freshwater habitat in more southern regions will support a newly productive environment for salmon.”

“In fact, Snake River salmon are hardy during migration. They do as well or better than salmon on undammed rivers in the American West.”

2.2 Elwha returns disappointing after dam removal

The Washington Policy Center reported that salmon runs on the Elwha have been disappointing after the dams were removed. These dams were obsolete without the benefits and fish passage of the targeted Snake dams. The report:

“Salmon runs on the Elwha have been cited as evidence that dam removal yields guaranteed and near-term increases in population. Contrary to those claims, however, a decade of returns since the dams were removed indicates recovery is more complicated, even in a case like the Elwha where dam removal opened up a large stretch of habitat. It also makes clear that hatcheries will continue to play an important role in maintaining populations of salmon across the Northwest.”

The Elwha dam was removed in 2013. In those ten years Chinook has remained relatively stable and 2021 and 2022 levels were below ten year average. Those are substantially below the returns in the late 1980s when the dam was in place. The Seattle Times report showed Chinook returning but not accessing the habitat that was expected.

2.3 Latent mortality theory questioned by NOAA and other research

Latent mortality continues to be cited by dam removal advocates as a primary reason for removing the four lower Snake River dams. This is based on concerns about loss of smolts once they enter the ocean. The theory is that the stress of going through the dams weakens the young Chinook so they are unable to survive once they reach the ocean.

NOAA studied the issue and in 2019 reported that their investigation showed that passing through the dams was not the cause of “latent mortality”:

“Bypass systems are designed to carry juvenile salmon and steelhead around dam turbines on the Columbia and Snake rivers. The study found little evidence fish that go through these systems suffer delayed or “latent” mortality once they reach the estuary and ocean. Rather, they survive at about the same rate as fish that go through spillways and turbines.”

“The latent mortality theory—also known as delayed mortality—assumes that juvenile Columbia River salmon and steelhead suffer some kind of injury, stress or disorientation from traveling through the hydropower system that causes them to die later, in the estuary or ocean. The reason for their later death has never been determined. This research suggests that the juvenile bypass systems do not affect their survival.”

Port and shipping interests opposed to dam removal commissioned a study on latent mortality conducted by Mount Hood Environmental. Their results, perhaps to the dismay of the funders, concluded that there was indeed latent mortality, but the causes are not understood:

Until 2021 NOAA had widely promoted the success of fish survival and passage through dams. One example is the Baker Dam on the Skagit River. In 2014 NOAA said one million juvenile salmon had been transferred into Baker Lake from below the dam. In 2023 by mid-July about 30,000 sockeye had entered the lake. The success of fish passage is well documented by NOAA which suddenly changed its position after the Biden administration arrived. This raises serious questions about the credibility of the agency.

“‘We conclude that delayed mortality may be occurring in the ocean as a result of carryover effects from exposure to the Columbia River hydrosystem,’ they wrote in a 20-page paper. ‘However, mechanisms of delayed mortality are not well-defined, and the magnitude is unknown. Furthermore, it is unclear how removal of the lower Snake River dams would reduce hydrosystem-related delayed mortality because the mortality mechanism may be a function of broad-scale habitat changes caused by operation of the entire (Federal Columbia River Power System), not exposure to individual dams.’”

There appears to be an overlooked reason for this significant loss of young salmon when they reach the ocean from the rivers and streams where they were born. As noted in Section 4, in the Salish Sea alone harbor seals consume 24 million smolts each year. This very significant amount is likely, combined with ocean warming, to contribute to the ocean mortality uniquely affecting Chinook.

2.4 Fish passage through dams very successful –– example: Baker Dam

Until recently NOAA has consistently reported on the success of fish passage through dams. One example is the Baker Dam on the Skagit River in Northwest Washington: NOAA reported in 2014 that one million juvenile salmon had been transported over the Baker Dam.

“The Baker River basin in Washington State is home to many migratory fish species. Its annual adult sockeye salmon returns have averaged about 3,500 since the 1920s, but plunged to a low of just 99 fish in 1985, imperiling the stock. NOAA Fisheries, Puget Sound Energy, and others analyzed salmon habitat and migration and proposed engineering solutions.

Because conventional fish ladders are not suitable for the two tall dams on the river, a ‘trap and haul’ approach was implemented for upstream and downstream fish passage at this site. An innovative system built by Puget Sound Energy to safely collect, monitor, and transport migrating fish around the dams has been a success for upstream and downstream fish passage. The fish passage system has boosted downstream fish migration to more than 850,000 juvenile sockeye and close to one million total juvenile fish, including sockeye, coho, and Chinook salmon. Meanwhile, the project continues to produce hydropower to the grid and local communities.”

Electricity rate payers have paid $24 billion for fish passage on the Columbia and Snake River dams. It’s a great success story with fish passage higher on the lower Snake River dams than most others. This success story is lost in the advocacy and media reports claiming that Chinook and steelhead recovery depends on removing these dams. The facts show that removing the dams would cause great harm across the region and nation with very little impact on salmon recovery.

As of mid-July, 2023 nearly 30,000 sockeye were released into Baker Lake and fisheries set a limit of five per day.

2.5 Successful fish passage through four lower Snake River dams

 NOAA reported that fish passage through the lower Snake River dams was highly successful as reported by the Wall Street Journal:

“In the years since, however, the salmon population has rebounded thanks to improved fish ladders, which allow the fish passage around the dams. This is why NOAA said in 2008, and again in 2014, that it is no longer necessary to breach the Snake River dams. A 2020 report from the Energy Department and the Bonneville Power Administration (the federal agency that manages the electricity from dams on the Columbia River system) concluded that rebuilding salmon stocks didn’t require sacrificing electrical power.”

Capital Press reported on NOAA official’s commenting on success of fish passage. Quoting Ritchie Graves, Columbia Hydropower Branch chief for the National Oceanic and Atmospheric Administration:

“‘Fish survival at the Snake River dams is better than most systems in the nation and world,’ NOAA’s Graves said. For each of the four dams, NOAA maintains a separate survival standard for juvenile salmon heading downstream. The agency wants 96% survival for yearling Chinook and steelhead, and 93% for “subyearling” Chinook less than a year old. The dams are achieving those performance standards, Graves said. For adult fish swimming upstream, the survival rate is above 90%.”

The 2020 report from NOAA shows that the lower Snake river dams are among the most modern and most updated of any West Coast dams providing fish passage for about 95% of the fish through the dams. The report comments that even rivers with no dams do not have 100% survival rates due to predation and river conditions.

Bonneville Power, the federal agency which operates the Columbia and Snake river dams, has spent $24 billion on fish passage according to the Seattle Times:

“The dams have helped power the growth of the region. But that economic engine has run at the expense of salmon, which continue to decline despite more than $24 billion in ratepayer money spent from 1980-2018 on improvements to fish passage at the dams and other recovery actions, according to the report.”

The comment that the economic benefits are “at the expense of salmon” demonstrates the reporters are either ignorant of or ignoring the facts about the effectiveness of fish passage and the real causes of salmon decline despite  readily available information. is a consortium of ten federal agencies working on salmon recovery. In 2015 they provided a report that showed the success of fish passage on the Snake and Columbia dams:

“Surface passage routes such as spillway weirs are yielding survival rates of 95 percent or better at every one of the eight federal dams on the lower Snake and Columbia Rivers.”

Section 3: Ocean warming and Chinook declines

Section 3.1 NOAA, Sierra Club and many studies point to ocean warming

As noted in the Misdiagnosis paper, ocean warming is likely the most significant factor hurting Chinook. But removing dams will do nothing to help this. 2022 saw a surprising increase in Chinook returns to the Snake river. Commenting on this, the Sierra Club appears to understand that ocean temperatures have a great impact on the fate of Chinook. They are wrong about the spillover effect according to NOAA, as shown below, but they are right about the impact of ocean temperatures:

Numerous studies and experts have pointed to ocean warming as a significant factor in Chinook decline, likely the most significant. The “blob” of warm water in the North Pacific in 2014-2015 and returning in 2019 related to significant decreases in Chinook abundance. While other species have flourished due to warming, Chinook salmon’s unique feeding habits make survival difficult in warmer ocean conditions. This factor, combined with excessive predation in the Salish Sea, are the primary reasons why Chinook recovery has proved so difficult.

“So far, 2022 has offered a brief reprieve for Snake River salmon. The runs are stronger than the dire numbers seen in previous years. This is likely thanks to a legal agreement that required federal agencies to spill water over the top of the dams starting in 2019, providing salmon with a safer migration route. Since salmon often spend a few years in the ocean, the fish now returning are the first that benefitted from the spillover agreement. This summer also saw slightly cooler ocean temperatures, which could have benefitted the fish.”

The Kintama study referenced in the paper also points to ocean warming as one of “broader oceanic factors” affecting salmon:

“Given the seemingly congruent decline in SARs to similar levels, the notion that contemporary survival is driven primarily by broader oceanic factors rather than local factors should be considered.”

NOAA, the National Oceanic and Atmospheric Administration, in 2020 published an important document called “Questions and Answers on Columbia Basin salmon, Snake River dams and Southern Resident killer whales.” It shows major jumps in salmon returns to the Columbia basin which includes all the Columbia and Snake river dams. Importantly, it shows that ocean conditions, not dams, are the primary factor influencing salmon mortality:

“The last 10 years have seen some of the highest salmon returns to the Columbia Basin since Bonneville and other dams were built and, more recently, some of the lowest. Those fluctuations demonstrate that salmon numbers do not increase or decrease in a straight line, but vary widely depending primarily on ocean conditions and other environmental factors. The ocean is the ‘source of the most important and highly variable mortality’ in the salmon life-cycle, according to the Northwest Power and Conservation Council’s Independent Scientific Advisory Board.”

“NOAA Fisheries’ Northwest Fisheries Science Center used life-cycle models to predict climate effects on Chinook salmon throughout their life stages by studying one distinct Chinook salmon population. For example, the projections from the model predict that Snake River spring/summer Chinook salmon populations could decline over the next several years from climate change impacts. This may be due to an increase in ocean temperature, and variations in flow and temperatures in freshwater systems. Recent heat events, which caused changes in salmon populations, may indicate what could happen as the ocean becomes warmer. A marine heatwave from 2014 to 2015 raised ocean temperatures, and salmon returns decreased coastwide.”

The ocean is the “source of the most important and highly variable mortality” in the salmon life-cycle, according to the Northwest Power and Conservation Council’s Independent Scientific Advisory Board.

“Cold-water fish subjected to warm water face a disruption in their normal body functions, reducing the size of the fish and increasing the risk of death. Warm water also can reduce the overall production in the food web, making it more difficult for fish to find suitable prey.”

Numerous studies have pointed out the harm that the warm water “blob” in the North Pacific has caused. Chinook in particularly appear to be affected by warm ocean temperatures which likely affect their food supply. The Pacific Sound Institute notes that a recent University of British Columbia study alarmingly calculates this will have a greater impact on salmon than previously thought:

“The higher estimates of population declines were calculated by researchers at the University of British Columbia, who took into account occasional “marine heat waves” that can play havoc with the ecosystem. A recent example is the warm-water event known as the “blob,” which included ocean temperatures up to 7 degrees above average (Fahrenheit) during a two-year period beginning in 2014.”

The report about salmon abundance included in Section 1.1 included this information about ocean temperatures which benefit some species but harms others, primarily Chinook:

“This research found that a 1.5°C increase in SST was associated with a 23% increase in sockeye productivity in the Bering Sea, a 9% productivity increase in the Gulf of Alaska, but with a 12% decline in productivity in the southern region (British Columbia and Southeast Alaska). Frequent heatwaves likely contributed to the growing abundance of pink salmon in the north while also contributing to a northward shift in the adverse effects of high SST on production of other salmon species.”

A science report in early August, 2023 noted the cooling of the Pacific Ocean. While this may contribute to drought according to the study, it will be interesting to see if this continues and the potential positive impact on Chinook.

Federal legislation in the 1970s protected marine mammals including harbor seals and sea lions. Congress could not have anticipated what happened in the Salish Sea. Southern Residents, unlike other killer whales, do not feed on harbor seals and leave them to feast on their preferred food: Chinook smolts. A study led by a NOAA scientist showed that 84% of all the Chinook consumed by harbor seals are in the Salish Sea. The 24 million Chinook consumed, combined with ocean warming uniquely harming Chinook, are the primary challenges to Chinook recovery.

Section 4: Predation and Chinook decline

Section 4.1 NOAA Chasco study documents predation by protected mammals specific to Salish Sea

Predation by marine mammals is a significant factor in Chinook declines. Killer whales consume the most Chinook measured in biomass. The orca population has more than doubled in the past forty years while the Chinook population has struggled due to ocean conditions. But the greatest impact by far affecting Chinook in Northwest Washington is harbor seal predation in the Salish Sea. It is the single most important factor that can be addressed by concerted public action and political policy.

The National Marine Mammal Protection Act passed in 1972 had the unintended consequence of an exploding population of pinnipeds ––harbor seals and sea lions. The impact of these on salmon has been devastating, particularly in the Salish Sea. The study quoted below reports that of all the Chinook consumed by harbor seals from Alaska to California, an astounding 86.4% are consumed in the Salish Sea alone!

A team of fisheries scientists led by NOAA’s Brandon Chasco published an important study on the impact of pinnipeds on salmon from Alaska to California. Called “Competing tradeoffs between increasing marine mammal predation and fisheries harvest of Chinook salmon” published in, the study showed that smolt production had nearly doubled from 1975 to 2015, but that this increase was met by a dramatic increase in predators. This includes orcas which have seen numbers more than double, except for the threatened Southern Resident pod. Killer whales increased from 292 to 644 whales and consumed the largest amount of the Chinook biomass, up to 11,000 metric tons.

Southern Resident killer whales have suffered compared to other populations in large part because they are “picky eaters” as one prominent marine biologist said, choosing only the largest Chinook. Unlike Northern and transient killer whales, they do not target harbor seals. While the increase in orcas in other areas has helped keep seal population under control, by eating only Chinook Southern Residents are losing out to their primary food competitors. The report states that predators including killer whales and seals consumed 31.5 million Chinook of all ages, a 600% increase. While harbor seal numbers have increased overall, by far the greatest increase is in the Salish Sea. This has a very large impact on Chinook in the area where Southern Residents depend on for food. Here is a concise summary of relevant predation:

A study led by a NOAA scientist showed that 86.4% of all the Chinook consumed by harbor seals are in the Salish Sea. The 24 million Chinook consumed, combined with ocean warming uniquely harming Chinook, are the primary challenges to Chinook recovery.

Chinook salmon biomass consumed by the marine mammal predators was estimated to have increased steadily over the entire study period [1975 to 2015] from 6,100 to 15,200 metric tons . The estimated increase in predation was directly related to increasing predator abundance used in our model. Killer whales increased from 292 to 644 individual resident killer whales, harbor seals increased from 210,000 to 355,000, California sea lions increased from 5,900 to 47,000, and Steller sea lions increased from 74,400 to 78,500. Killer whales consumed the most Chinook salmon biomass (from 5,400 metric tons in 1975 to 10,900 metric tons in 2015), followed by harbor seals (400 to 2,500 metric tons), Steller sea lions (300 to 1,200 metric tons), and California sea lions (50 to 600 metric tons). Numerically, the predator consumption increased from 5 to 31.5 million individual Chinook salmon of varying ages. This was largely driven by increased consumption by harbor seals (from 3.5 million to 27.4 million individual Chinook salmon), followed by killer whales (1.3 to 2.6 million), California sea lions (0.1 to 0.7 million), and Steller sea lions (0.1 to 0.7 million).

Harbor seals from Alaska to California consume 27 million Chinook. But most of that consumption of Chinook salmon is in the Salish Sea:

“Harbor seals in the Salish Sea (i.e. Puget Sound, Strait of Georgia, and Strait of San Juan de Fuca) accounted for 86.4% of the total coast wide smolt consumption in 2015, due to large increases in the harbor seal abundance in this region between 1975 and 2015 (8,600 to 77,800).”

4.2 Congressional action allows removal of predators harming salmon

Public outcry against the very visible predation by California and Stellers sea lions feeding on salmon near Bonneville dam led to Congress in 2018 authorizing limited lethal removal. The sea lions were responsible for eating 3112 salmon, about 2% to 4% of the salmon and steelhead run through the dam. It is remarkable that the focus has been on these predators when it is documented by NOAA research that harbor seals in the Salish Sea (inland waters between Seattle and Vancouver, BC) are a much bigger problem and a primary reason for Chinook decline.

4.3 Tribal leaders, Washington scientists and a policy think tank call for predator control

Tribal leaders have been calling for attention to be paid to the predation issue in the Salish Sea for some time. In the March 10, 2022 issue of “Being Frank” published by the Northwest Indian Fisheries Commission, Chairman Ed Johnstone noted the sea lions eating salmon are not a native species but migrated here to consume salmon. He calls sea lions and harbor seals an “invasive species” protected by federal law. He notes that while tribal fisheries have been reduced by 80 to 90%, the seals and sea lions are taking six times more salmon in the Puget Sound and Olympic coast than tribal and non-tribal fisheries combined.

The Washington Policy Center, a policy research organization in Washington State concluded:

“… it makes little sense to refuse to take effective and low-cost steps like reducing pinniped populations while advocating for spending tens of millions on habitat restoration, or tens of billions on destroying dams.”

Section 5: Federal Environmental Impact Statement 2020

The three federal agencies responsible for the operation of the dams on the Columbia and Snake river system are the Army Corp of Engineers, the Bureau of Reclamation and the Bonneville Power Administration. These were charged with conducting an in-depth study of the 14 dams called the Columbia River System Operations (CRSO). The final Environmental Impact Statement was issued in July 2020.

The complete EIS is available here:

The Little Goose Dam is one of four Snake River dams targeted for removal by advocates. The four dams provide extremely important transportation and power benefits to the entire region. The cost of removal and replacement would exceed the $30 billion suggested, likely by billions. But, as the science studies provided here show, it would not result in any significant recovery of the endangered Chinook salmon.

The study evaluated six alternatives which included removing the lower Snake river dams. All agencies agreed on what they called the Preferred Alternative which provided for enhanced fish passage, support for tribal concerns and continued operation of the dams.

It is significant that NOAA through NOAA Fisheries, also called National Marine Fisheries Service, was involved in the study providing a BiOP, or biological opinion. As a result of this input, Bonneville was specific in their statement of support for the Preferred Alternative about improving fisheries mitigation measures. The BiOP did not include any statement reflecting the now widely publicized NOAA statement stating that the lower Snake dams must be removed for salmon. This is important in the discussion below (Section 7.1) about the politicization of science reflected in NOAA’s dramatically changed position on the dams.

NOAA’s support for the Preferred Alternative leaving the dams in place with enhanced mitigation efforts was noted in some press reports, including this one from Oregon Public Broadcasting. The report stated:

“(The EIS) finds an appropriate balance between the environmental needs as well as the socio-economic needs of the region,” Matt Rabe, a spokesperson with the U.S. Army Corps of Engineers, said. “The preferred alternative would allow for more spill over several dams as juvenile salmon migrate out to sea and less power is needed on the grid. It also includes structural changes to some dams to help salmon, steelhead and lamprey passage.”

It also noted that the report showed if the dams were removed it would result in a 25% increase in electricity prices in the Northwest. The EIS study began in 2016 and included review of over 59,000 public comments. The final report listed the various key stakeholder groups directly involved:

“The agencies conferred with tribes, public interest groups, the Northwest’s Congressional delegation and governors, as well as stakeholder groups, and Federal, state and local public service agencies. The co-lead agencies also closely read, considered, and responded to the public comments which represented diverse voices with numerous perspectives. The agencies considered the effects of making this decision, and sought to provide a balanced approach and the flexibility needed to continue operations and maintenance of the CRS in this dynamic environment”.

“The Preferred Alternative endeavors to provide the most balanced way to fulfill all of the CRS projects’ congressionally authorized purposes, meets a majority of the CRSO EIS objectives, minimizes and avoids adverse impacts to the environment, benefits tribal interests and treaty resources, and provides additional improvements for ESA-listed species.

“The Preferred Alternative assures safe, healthful, productive, and esthetically and culturally pleasing surroundings by maintaining current riparian habitat, for example, while providing safe and reliable power generation. The Preferred Alternative supports the widest range of beneficial uses of the environment, without appreciable degradation, risk to health or safety, or other undesirable or unintended consequences by providing flood risk management, power generation and reliability, navigation, and fish and wildlife conservation, including improvements to fish survival, water supply, and irrigation.”

Statement by federal agencies on unanimous agreement to leave dams in place.

The Preferred Alternative assures safe, healthful, productive, and esthetically and culturally pleasing surroundings by maintaining current riparian habitat, for example, while providing safe and reliable power generation. The Preferred Alternative supports the widest range of beneficial uses of the environment, without appreciable degradation, risk to health or safety, or other undesirable or unintended consequences by providing flood risk management, power generation and reliability, navigation, and fish and wildlife conservation, including improvements to fish survival, water supply, and irrigation. Commercial and tribal fishing in the lower Columbia and lower Snake rivers would improve over the No Action Alternatives. There would be fewer effects to cultural resources and improvements to tribal fisheries. The Preferred Alternative includes fish passage improvements, creating some job loss and potential higher power rates, as compared to the No Action Alternative. The agencies would monitor for potential shoaling at projects for unintended effects to navigation, resident fish, and anadromous adult fish passage at certain fish passage projects; this is included as mitigation.

Effects to cultural resources will continue, but would be mitigated through the FCRPS Cultural Resource Program. Viewed with respect to “the interrelations of all components of the natural environment,”9 the Preferred Alternative is deemed the environmentally preferable alternative based on its wide benefits to the environment, and the minor adverse effects compared to the other alternatives analyzed.”

Section 6: High cost of ineffective solutions 

In the Misdiagnosis paper a number of ineffective and potentially damaging solutions to Chinook decline were mentioned. These include:

  • Removing the four lower Snake river dams
  • Converting up to 30% of Western Washington farmland into massive habitat buffers
  • Restricting or eliminating irrigation water for farmers

Extensive information from multiple sources is available. Here we highlight some of the most relevant costs for each of these solutions.

6.1 Dams: Costs of removing four lower Snake river dams

In August 2022 Governor Jay Inslee and Senator Patty Murray issued a report on removing the dams titled “Lower Snake River Dams: Benefit Replacement Report.” The final report can be accessed here:

A brief version with their recommendations can be found here:

Both leaders have been adamant in their support for removing the dams, a position strongly reflected in their report and summary of recommendations. However, there was also a somewhat realistic assessment of the high cost of benefit replacement and mitigation. The Recommendations document included this in bold type:

“…we are adamant that in any circumstance where the Lower Snake River Dams would be breached, the replacement and mitigation of their benefits must be pursued before decommissioning and breaching.”

“…we are adamant that in any circumstance where the Lower Snake River Dams would be breached, the replacement and mitigation of their benefits must be pursued before decommissioning and breaching.”

Governor Jay Inslee and Senator Patty Murray

The total cost estimate from the report:

“Even as we pursue these matters, we know that the cost associated with the replacement of the Lower Snake Dams is enormous, over any timeframe. The independent consultant’s report estimates breaching costs of between $10 billion and $31 billion, with many anticipated costs still not available, meaning it will be necessary to refine our understanding of how to optimize these investments.”

With the numerous comments and critiques offered after the report was issued, including the severe underestimation of impacts on farms as noted in Section 6.3, it is likely that the costs would significantly exceed $31 billion. The report shows that the cost of removing the dams and restoring river habitat would significantly exceed $2 billion.

Bonneville Power Administration provided a separate assessment of costs of dam removal focused on energy generation:

News reports reflect the orientation (or bias) of the reporting on the Murray-Inslee report. For example, the while the Seattle Times report focused on the strong support expressed by Murray and Inslee for removing the dams to recover salmon.

6.2 Dams: Replacing power produced by dams

Dam advocates suggest that the four dams targeted produce little power and that it can easily be replaced by new green energy sources such as wind and solar. One of many examples is the statement below from the NW Energy Coalition, a dam removal group. The facts do not bear this out. The federal EIS shows that:

“to breach the dams and maintain the current level of grid stability it would need to add 1,960 megawatts of additional solar resources and 980 megawatts of battery storage.

The four dams targeted for removal can provide up to 3000 megawatts of power but to replace them in the electrical system with solar and wind, as many have proposed, would cost $6.6 billion including batteries. It would be far more likely this power would be replaced with fossil fuels meaning that a major carbon-free energy source would be replaced with natural gas with contributions to climate change. Bonneville Power states that to replace the power produced by the dams would require over 5000 MW of solar, raising the cost to more like $10 billion for carbon-free replacement.

This is only one of many costs related to dam removal. Estimates range from $10 to over $30 billion but all agree much is unknown so costs are likely to be considerably higher.

The People’s Utility District of Northern Wasco County (Oregon) commented:

“The four dams on the Snake River power up to 800,000 homes while producing zero carbon emissions and delivering power around the clock year-round. Wind and solar cannot replace that steady power because the wind doesn’t always blow, and the sun doesn’t always shine. The least-polluting steady power replacement would be natural gas—a fossil fuel. A 2015 BPA reliability analysis concluded replacement of the lower Snake dams with highly efficient natural gas generation would increase the region’s carbon dioxide emissions by 2.0 to 2.6 million metric tons annually. At the low end, this would be the equivalent of adding 421,000 passenger cars to the region’s roads each year.”

Dam removal advocates and opponents cite different studies on the impact on power generation if the dams are removed. An example is this report from the Spokesman Review:

In 2018, the NW Energy Coalition commissioned and published a study finding that the energy produced by the four lower Snake River dams could be replaced by a mix of other clean energy sources. More importantly, the study, which was conducted by a Utah-based energy company, concluded that the capacity could also be replaced by clean energy sources without substantially raising consumer costs.

In response, Northwest River Partners commissioned its own study critiquing the NW Energy Coalition’s study. It found that the pro-breaching study relied on “out-of-date” assumptions and didn’t take into account the decommissioning of coal plants around the West, which it estimated will remove roughly 20,000 megawatts of energy from the grid. The replacement energy and storage source portfolios highlighted in the NW Energy Coalition study were ‘infeasible or significantly underestimate costs.’”

The Bonneville Power Administration, the federal agency that markets the power produced by the Snake River dams, estimated that to breach the dams and maintain the current level of grid stability it would need to add 1,960 megawatts of additional solar resources and 980 megawatts of battery storage. The fact sheet by Bonneville includes these costs and impacts:

“Cost to replace lower Snake River dams’ capacity and energy while maintaining system reliability with natural gas: $274 million to $372 million per year.
Increase in CO2 emissions: 2.0 to 2.6 million metric tons — every year.
Social cost of carbon: $98 million to $381 million — every year.
Cost to replace the winter critical energy with solar energy: $7.4 billion.
Amount of solar capacity required to replace the energy of the dams: 5,311 MW. (There is 25,000 MW of solar generation installed in the U.S. today.)”

Dryland wheat farming in southeast Washington and bordering areas in Idaho and Oregon is highly productive, producing about 15% of the nation’s wheat production and about 20% of the wheat exported. Estimates of farms lost if the Snake River dams are removed range from 1100 to as many as 7000. The impact would fall not only on farmers but on farmworkers and the great many businesses and organizations that depend on the farms. Losing barging on the river would affect many more farms across the nation as this system is the number one gateway for wheat exports.

6.3 Dams: Impact on farms 

The Idaho Farm Bureau presented information on the impact on farms from dam breaching. It would result in a 50% to 100% increase in shipping costs from area farms and put 1100 farms at risk of bankruptcy:

“The study found that removing the dams would lead to higher rail rates, negatively impact air quality and cost the nation more than $2.3 billion over the next 30 years. Removing the dams, the study found, would increase diesel fuel consumption by almost 5 million gallons per year because barges would be replaced by less efficient truck-to-rail shipments. The share of goods moved to export terminals on the West Coast by barge would decrease and the amount moved by trucks and rail cars would increase. The increased reliance on truck-to-rail shipments would result in an additional 24 million miles of travel per year on county, state and federal roads.

The study also found that dam breaching would likely increase grain transportation and storage expenses by 50-100 percent and put more than 1,100 farms at risk of bankruptcy.

The Columbia-Snake River system is a 465-mile federal waterway that provides farmers as far away as the Midwest access to international markets. Besides being the No. 1 gateway for U.S. wheat exports, the system is the No. 2 gateway for corn and soybean exports and the No. 1 gateway for West Coast wood and auto exports. According to PNWA, about 14 million metric tons of wheat destined for export move through the system each year, as well as 8 million metric tons of soybeans, 3 million tons of wood products and 9 million tons of corn.”

“The National Grain and Feed Association maintains that any action to breach the dams is not a viable option. NGFA noted the investment decisions grain elevators have made over the years based on the ability to ship grain down the river.

‘Barge transportation moves about half of all grain exports to export elevators and is critical to NGFA members in the Pacific Northwest. The Columbia-Snake River System is the third-largest grain export corridor in the world, transporting nearly 30 percent of U.S. grain and oilseed exports,’ NGFA President and CEO Mike Seyfert said.

“Breaching the lower Snake River dams in the Pacific Northwest would create severe economic harm to the entire U.S. agricultural value chain.’”

The Pacific Northwest Waterways Association conducted a study of impacts on farms:

Food consumers around the nation and world depend on the low carbon, low cost barge transportation of wheat and other farm products. 60% of the nation’s wheat product goes through the Columbia system including the Snake River dams. Farmers would have to be compensated for the 50% to 100% increase in transportation costs or many would face bankruptcy. Studies show most of the 7644 farms in the region would be at risk – mostly smaller and mid-sized family farms.

The barges would have to be replaced with trucks and trains with major expenses to provide the infrastructure. As the graphic below shows, one barge tow would require 140 rail cars or 538 trucks. CO2 emissions would rise by 1.2 million tons per year. The environment would be significantly harmed as well as farmers and food consumers.

“If farm subsidies are not increased, the study estimates that more than 1,100 farms could be at risk of bankruptcy. The average regional net farm cash income was only $42,825 in 2017. With wheat prices already down near the break-even point, the study calculates that the federal government would need to increase annual direct payments to farmers by up to $38.8 million to maintain current income levels.

Highway, rail and grain elevator networks would need over $1.6 billion in capital investment. If barging were removed from the Snake River, new infrastructure or costly upgrades would be needed to accommodate the displaced cargo. This includes hundreds of miles of shortline rail track that have been abandoned, new rail, major highway improvements, and retrofits for grain elevators that do not have rail loading capabilities.”

An August 2023 study released by Pacific Northwest Waterways updated their estimate of harm to farms and showed that most of the 7644 farms in the twelve county region nearest the dams would “have very high likelihood of bankruptcy” if there were not major federal subsidies. Small and medium-sized family farms would be most at risk.

The Columbia river system of dams provides barge transportation for 60% of the US wheat exports, meaning that farmers throughout the country would be significantly impacted by losing the inexpensive, low-impact transportation.

“The study cites a $1 billion total mitigation cost as estimated by the U.S. Army Corps of Engineers. The Corps estimate is broken down into $787 million for capital costs and $218 million for the present value of maintenance costs. The summary of those mitigation costs notes that despite the breaching plan being a governmental action, all the financial pain would be borne by landowners under the conditions of the study.

The study’s mitigation estimate does not consider lost farm revenue, nor the loss of changing from irrigated to dryland agriculture. According to research from Texas A&M, irrigated agriculture returns approximately $240/ac more than dryland farming. That means the on-farm harm of destroying the dams would be approximately $769 million , a direct financial hit to the people of our state.”

6.4 Environmental impact of loss of barge transportation 

The Pacific Northwest Waterways Association published a study that evaluated the environmental cost of replacing barging provided by the four dams with other forms of transportation. Their report included:

“According to the FCS Group study, breaching the Snake River dams would cause diesel fuel consumption to increase by nearly 5 million gallons per year as barges are replaced by less efficient truck-to-rail shipments. At least 201 additional unit trains and 23.8 million miles in additional trucking activity would be required annually, resulting in increases in CO2 and other emissions by over 1.2 million tons per year. Carbon emissions equivalent to the cumulative emissions generated by a coal-fired power plant every 5-6 years would result.”

6.5 Dams: Impact on communities and individual lives

Much attention has been focused on those in the region who would benefit from dam removal. For example, a study commissioned by Vulcan, Inc., conducted by Econ Northwest concluded that dam removal would provide far more benefits than maintaining them based primarily on the economic value placed on “non-use values”:

“From an economic perspective, the public highly values the protection of salmon and steelhead. Many people are willing to pay money out of their own pocket to protect ecosystems, habitats, and resources. Our analysis shows that these non-use values dwarf the costs that the public would incur from removing the dams. Benefits accruing to the public from a restored natural river system and a reduced extinction risk of wild salmon outweigh the net costs of removing the dams by over $8.6 billion.”

It is difficult to see how such an analysis can be considered credible given the very significant impact to the lives of thousands of citizens living in the region of the dams. If such “non-use values” are to be considered, then certainly including the life-changing disruption to tens of thousands including some of Washington state’s poorest citizens must also be considered. How should one calculate losing the “non-use value” of a farm started by a great grandfather, or losing a job when one is 58 with few prospects?

The Washington Wheat Foundation shows that 3715 farms grow wheat in Southwest Washington. Almost all are family farms, most are multi-generational. As we saw in Section 6.3 many thousands of these would face bankruptcy and all of them would face higher transportation costs of 50% to 100%.

The map shows major wheat growing counties in the southeast of Washington state. The social justice impact on the lives of some of the poorest citizens of our state would be great. Whitman County’s median household income as $42,000, compared with the state median of $77,000 and King County median of $106,000.

The Washington Wheat Foundation shows that 3715 farms grow wheat in Southwest Washington. Almost all are family farms, most are multi-generational. As we saw in Section 6.3 many thousands of these would face bankruptcy and all of them would face higher transportation costs of 50% to 100%.

Whitman County is the most productive wheat growing county in the state. Taking this county alone into consideration, estimates of displacement and disruption can be reasonably made. The county population in 2021 was 47,000 with a median household income of $42,000 and about 10% of the population lives in poverty. Compare this to the state average of $77,000 and King County’s median household income of $106,000.

It is not just farm workers employed by family farmers and the family members whose lives would be disrupted by the removal. Indirect employment in farming communities is significant. In communities like Whitman county, a considerable number of families not directly employed on the farms are dependent on those farms for their livelihoods.

Those most directly affected have little voice over what happens to their communities and their lives as the political power over such decisions reside in our larger urban areas. It is a matter of social and environmental justice to take into consideration the disruption to the thousands of families and employees who are among the region’s and state’s poorest.

This only looks at the impact on one community very near the dams. But as the National Grain and Feed Association pointed out, the Columbia and Snake system of dams and the efficient and low impact barge transportation it provides affects far more farmers and farm communities than just those near the dams.

“Barge transportation moves about half of all grain exports to export elevators and is critical to NGFA members in the Pacific Northwest. The Columbia-Snake River System is the third-largest grain export corridor in the world, transporting nearly 30 percent of U.S. grain and oilseed exports,” NGFA President and CEO Mike Seyfert said. “Breaching the lower Snake River dams in the Pacific Northwest would create severe economic harm to the entire U.S. agricultural value chain.”

Section 7: Contribution of hatcheries to Chinook recovery

7.1 Both wild and hatchery Chinook production increasing strongly advocates for wild salmon as their name indicates. They show significant increases in both hatchery and wild salmon production in the Snake river as the chart shows. There has been a steady if varying increase in even wild salmon production in this river after the dams were built, with the last one completed in 1975.

Hatchery and wild production by region according to Chasco study. “Natural (hatched) and hatchery (solid) Chinook salmon production by area between 1975 and 2015 for Central California (Cen.CA), Northern California/Oregon (N.CA/OR), Columbia River (Col. Riv.), outer Washington Coast (WA), Salish Sea (Sal. Sea), West Coast Vancouver Island and coastal British Columbia (WVI/N.BC), Southeast Alaska (SEAK), and Gulf of Alaska (GoA).” Salish Sea is olive green. Wild production is much greater than hatchery.

The NOAA Chasco study referred to in Section 4.1 shows significant increases in Chinook production of both wild and hatchery stocks between 1975 and 2015.

“Between 1975 and 2015 the estimated production of wild and hatchery Chinook salmon increased from 225 to 406 million juveniles (Fig. 2). In the 1970s and 1980s this was driven by an increase in production of hatchery fish. Since the mid 1980s, a decline in hatchery production has been offset by an increase in smolt production from some wild stocks, such as in the Columbia River.”

“This report provides provisional abundance estimates for pink, chum, and sockeye salmon in major regions of the North Pacific from 1952 through 2015 in terms of: numbers of natural origin and hatchery-origin salmon returns (i.e., catch plus escapement), numbers and biomass (metric tonnes) of total returns (natural-origin and hatchery-origin)…”

The Ruggerone and Irvine article referenced in several sections above details the great abundance of pink salmon in the North Pacific and the contribution the pink salmon hatcheries to this abundance:

“Pink salmon dominate the abundance of Pacific salmon returning from the North Pacific, reaching approximately 700 million maturing fish in 2018 and nearly 640 million fish in 2019. The exceptional return in 2018 was highly unusual because pink salmon abundance is typically highest in odd-numbered years.

“Approximately 88% and 68% of the total pink salmon abundance were from Asia in 2018 and 2019, respectively. In contrast, peak abundance of pink salmon in North America occurred in 2013 and 2015 (more than 300 million fish per year). Overall, pink salmon represented approximately 74% of total salmon abundance in 2018/2019.

“Most pink salmon are of natural origin, but abundance of hatchery pink salmon during 2005 to 2015 was greater than abundance of wild chum salmon and approximately equal to abundance of wild sockeye salmon. Total chum and sockeye salmon represented only 14% and 12%, respectively, of total salmon abundance in 2018/2019. These values exclude Chinook and coho salmon, whose combined reported commercial catch was 1.5% of total salmon catch from the North Pacific during 2018/2019 and approximately 5% of total salmon catch, on average, during 1925 to 2020.”

The Hakai Magazine article titled “Too Many Pinks in the Pacific” further explains this abundance and links it to the preference that commercial fisheries have for hatchery pink salmon:

“Since the 1970s, industrial production of pink salmon has exploded, and today, hatcheries in the United States, Canada, Russia, and Japan pump about 1.3 billion pink salmon fry into the Pacific each year, leading to the production of roughly 82 million adults. About 15 percent of all pinks in the ocean originate from hatcheries, topping off a population that is already at a record level of abundance. This means there are about as many hatchery pink salmon as there are wild sockeye and more hatchery pinks than each of wild chum, Chinook, and coho. The bulk of this production comes from Alaska.”

7.3 Chinook hatchery production in comparison

Chinook hatchery production has increased as has wild salmon production including in the Snake River as was noted in section 7.1. However, this production is very small compared to the hatchery production throughout the North Pacific of the dominant pink salmon. The NOAA Chasco study referenced in Section 4.1 shows total Chinook smolt production in 2015 at about 400 million. This compares to the 1.5 billion pink salmon production.

NOAA’s press release of October 2021 positions the increase in federal funding for Chinook production as a response to the well publicized plight of the Southern Resident killer whales:

“Federal and state funding paid for more than 11.6 million additional juvenile hatchery Chinook salmon in 2020 compared to previous years. The funding also supported the release of more than 18.3 million additional Chinook salmon in 2021, although final numbers are pending.”

7.4 High cost of Chinook hatchery production

Increasing the number of Chinook smolts from hatcheries may be valuable and important, but research studies shows that without addressing the ocean mortality issues, this measure alone will not return Chinook to historic numbers.

The Kintama study cited above in Section 2.1 shows that because of high ocean mortality, the cost of hatchery production of Chinook compared to harvest is very high. The authors wisely suggest that focusing on the ocean survival issue will be necessary if the high cost of Chinook production can be lowered:

“Because of poor survival, the costs of hatchery supplementation are  now extremely high.  In  Puget  Sound,  where  the reported  survival of subyearling  (Fall) Chinook has fallen to significantly  lower survival levels than the Snake River, the cost of hatchery operations to yield one sport-caught adult Chinook  has  increased  from  ~$55 (USD) per fish  in the 1970s to $768 (yearlings) and $392 (subyearlings) in the 1990s (costs unadjusted for  inflation).

“High costs of production are also noted in British Columbia, particularly for Upper Fraser River Chinook, where costs were  estimated at $380  (CDN) per returning adult in the  1980s  (Winton & Hilborn, 1994). Given the similarity of the decline in survival, the economics of hatchery Chinook production are likely similar in other regions. Understanding the real drivers of poor survival might substantially improve the economics of hatchery production. The few regional hatchery programmes with anomalously high SARs should be investigated to determine when in the postrelease life history period survival is high as a first step to understanding why it is low elsewhere.”

Section 8: False narratives of salmon recovery advocates

8.1 NOAA’s politicization of science

NOAA’s recent claims that the four lower Snake river dams must be removed if Chinook salmon are to recover has been very well publicized despite the fact that it is in direct contradiction to the previous statements made by the federal agency. This change came about, according to the Wall Street Journal, because of the position the Biden administration has taken in favor of dam removal:

“… the salmon population has rebounded thanks to improved fish ladders, which allow the fish passage around the dams. This is why NOAA said in 2008, and again in 2014, that it is no longer necessary to breach the Snake River dams. A 2020 report from the Energy Department and the Bonneville Power Administration (the federal agency that manages the electricity from dams on the Columbia River system) concluded that rebuilding salmon stocks didn’t require sacrificing electrical power.

“But when the Biden administration took over, NOAA reversed course. In September 2022 it produced a new report claiming that ‘the science robustly supports riverscape-scale process-based stream habitat restoration, dam removal (breaching), and ecosystem-based management’ on the Snake River. The report’s claim of robust scientific support sits awkwardly alongside the authors’ admission that they can provide no ‘precise measures or quantitative estimates of the magnitude of biological benefit’ from removing the dams. They also confess that they have no evidence or authority to ‘supersede or modify existing analyses.’

“In fact, the goals of the report are political, not scientific. Radical environmentalists allied to the Democratic Party are forthright about their desires to reduce the amount of electricity Americans consume.”

8.2 Dam removal advocates and media reports are primary sources of misdiagnosis

The primary source of the information about dam removal and its impact on Chinook comes from environmental groups strongly advocating for dam removal. Unfortunately, the major media outlets reporting on salmon recovery have not closely investigated the facts and the misinformation provided by these advocates.

Joe Bogaard, Director of Save Our Wild Salmon:

“It’s been long established and recognized that if these dams remain, these fish will disappear,” says Joseph Bogaard, executive director of the Washington-based organization Save Our Wild Salmon.”

“The situation is dire: Snake River salmon and Southern Resident orcas are close to extinction. But there’s still time to restore the Snake and Columbia rivers’ once-mighty salmon runs.”

“This is why NOAA said in 2008, and again in 2014, that it is no longer necessary to breach the Snake River dams. A 2020 report from the Energy Department and the Bonneville Power Administration (the federal agency that manages the electricity from dams on the Columbia River system) concluded that rebuilding salmon stocks didn’t require sacrificing electrical power.

But when the Biden administration took over, NOAA reversed course.” (Wall Street Journal)

“Salmon and steelhead have declined by more than 90% of their pre-dam natural abundance in the Columbia and Snake rivers.”

“Just prior to the completion of the lower Snake River dams, wild Snake River fall Chinook populations reached about 30,000.  Since then, these fish have plummeted by more than 90% and now teeter below their recovery target of 3,000.”

It is reasonable to expect quality journalists such as these to not simply echo activists statements as if they are true, but verify. The information about the reduction in Chinook salmon is easily found as this Appendix reveals.

“The dams pose myriad risks to migrating fish. Many are killed or injured passing through the turbines, and they struggle to make it through the warm, still reservoir waters the dams create. (Their natural migration route would instead take the fish through cold, fast-moving waters.) The dams create choke points where predators like sea lions and pikeminnow can gather to feast on the salmon and steelhead runs. Once the fish make it through this gauntlet, they enter an ocean artificially heated by climate change.”

Section 9: Adjudication, water rights, irrigation and infrastructure

Farmers particularly in Western Washington are under increased pressure regarding water use. This pressure comes primarily from political decisions reacting to calls to protect salmon. Ironically, it is well established that farming is crucially important to protect salmon as seen in the Action Agenda of the Puget Sound Partnership. The 2022-2026 Action Agenda on page 7 includes as the second item in its vision statement the need to: “Protect agricultural lands and working forests from conversion.

Regardless, the pressure continues with the result of already accelerating loss of family farmers from one of the most beautiful and productive farming areas in the nation.

Raspberries harvested at Enfield Farms near Lynden. The Nooksack basin produces 70% of the nation’s supply of frozen and processed raspberries. Blueberries, seed potatoes, dairy, beef and other farm products are produced. A growing movement of small, organic farms adds to the mix. Every farm is threatened by the state’s water rights adjudication. A very harmful action advocates claim is to help restore salmon. Another example of the harm of misdiagnosis.

9.1 Whatcom county water rights adjudication

A Whatcom County news channel celebrated the passage of a bill in the Washington legislature that will in all likelihood doom farming in one of the last remaining viable farming areas in the Puget Sound region. The photo caption notes farm use of water during the summer and that this “may” change with adjudication.

Based on requests by the two local indigenous tribes, the Lummi Nation and the Nooksack Tribe, Washington state is suing all water rights holders in the Nooksack River basin. Tribes and environmental groups believe that there is insufficient water for salmon and the state should determine through court action who has the right to how much water.

Attorneys for the farming community have long said that the court would most likely make all non-tribal rights junior to tribal rights. This is because of the amount of flow needed in the river at low flow times of the year to protect fish. Climate change makes this even more of a problem. The impact of that will be the likelihood of junior rights holders restricted in certain times of the year. For farmers, those times would likely coincide when irrigation is most crucial. Farmers can’t farm without reliable sources of irrigation water and banks won’t support farms which cannot produce crops under these conditions.

A key issue is the inclusion of groundwater in water rights adjudication. Without justifying science, the Washington State Supreme Court ruled that taking groundwater has a “molecule to molecule” impact on stream or river flows. Most farmers in the Nooksack basin have converted surface water rights to groundwater rights. Groundwater is supplied by an aquifer which also supplies the Abbotsford area across the border in Canada. This large aquifer is replenished to overflowing every year when the rains return in the early fall as seen in the many flooded fields.

Farmers and most entities in the community involved in this issue seek to negotiate use of water in a way that will protect salmon and preserve farming and the quality of life in the community. Tribal refusal to participate in recent negotiations means that this issue will likely head to court in a decades long adjudication. In the meantime, given the uncertainty some farmers have already left the area.

9.2 Irrigation and farming infrastructure restrictions in Skagit County

Skagit Valley dairy farmer Jason Vander Kooy inspects a drainage ditch on his farm. More than 80 crops are farmed on the 80,000 acres in this valley that features some of the best soil in the nation. But the future is clouded by uncertainty over irrigation and maintenance of dikes and drainage systems. Calls for massive buffers even on streams with no connection to salmon like this ditch, and resistance to needed maintenance threatens farming in this area. north of Seattle.

Skagit County’s 80,000 acres of highly productive farmland produces a wide variety of crops including flowers, berries, potatoes, seeds, vegetables, and forage crops for the few remaining dairy farms. Many of these farms draw irrigation water directly from the Skagit river. Because the withdrawal location is just upstream from the river’s tidal zone, the withdrawals have no known impact on fish.

The tidal zone is near the mouth of a river where it empties into a body of water subject to tides. Because the tides determine the level of water in the river, fish are not affected by withdrawals in this area. The Skagit empties into the coastal Pacific waters into Skagit Bay, near the town of LaConner and in the Salish Sea area.

Despite having almost no impact on fish, some Skagit farmers are cut off from irrigating when the river level at the withdrawal location drops below 10,000 cubic feet per second. Maximum withdrawal for irrigation amounts to 8 cubic feet per second and would lower the river level by about the thickness of a credit card. As summers have become hotter with less rainfall, farmers face more water restrictions usually at times when irrigation is essential to maintain their crops.

The same reasons are offered for why environmental groups and tribes oppose the maintenance of dikes and drainage infrastructure in this same region. The area’s marshy ground was drained by farmers dating back to the last decades of the 19th century, creating what has been determined as the best farmland in the nation. Dikes were constructed along the Skagit river which, combined with the Baker and Seattle City Light dams on the upper reaches, prevent massive flooding of farms, homes and entire communities.

Opposition to maintenance threatens the viability of some of these dikes and drainage infrastructure. While the same reason is offered –– fish protection –– there is essentially no impact on fish if the farming infrastructure is properly maintained. Those who oppose maintenance have communicated they prefer to see this productive farmland be returned to native condition. Some believe this is essential for the habitat needed for salmon. But again, this is based on the same misdiagnosis of Chinook recovery problems. Taking away the most productive and beautiful farmland, converting it to development and native condition will not help return salmon.

Section 10: Large, inflexible riparian buffers

Both dam removal and riparian buffers advocated by many affect farmers but in different ways. Dam removal impacts farms and rural communities in the southeast portion of the state as well as Oregon and Idaho. Large, inflexible riparian buffers affect mostly the western farming areas in the state with more streams and a wetter climate.

Riparian buffers are very important for salmon. The streams and rivers where salmon spawn need the habitat and natural conditions provided by trees, brush, and plants in the waterways that are important for spawning. Shade helps keep water cool in the heat of summer and the planted area also protects against harmful runoff from roads or farm fields. Studies have shown that larger buffers are more important in the upper reaches of streams compared to the lower areas where farming typically occurs.

Riparian buffers provide valuable habitat. Science studies show that smaller, flexible buffers provide the major benefits. Yet, salmon advocates continue to demand large, inflexible buffers that would largely destroy farming in the Puget Sound region.

Farmers have been leaders in implementing riparian buffers. Working with the Washington State Conservation Commission and other non-profit groups, using federal and state funds, over 1000 miles of streamside buffers have been installed in mostly Western Washington with over 6 million trees planted. The size of these buffers range from about 30 feet to over 100 feet, depending on the specific site conditions.

Despite all this habitat work, Chinook recovery contrinues to disappoint. This leads some salmon advocates to call for massive, inflexible and mandatory buffers as a solution. Science studies in the lowlands where most farming occurs, show that smaller buffers in these areas provide most if not all of the benefits of much larger buffers.

A study was conducted in 2012 by a group of Washington scientists led by Washington State University scientists. The Benedict-Shaw study examined buffers in Whatcom County testing the following hypothesis:

“1. Effective shade will increase as planted buffer width increases. (Micro-climate)
2. Average daily maximum air temperature will be lower within the planted buffer than outside the buffer.
3. The wider the planted buffer, the greater the difference in air temperature between inside and outside of the buffer.”

They expected to see significant improvements in the crucial temperature benefits based on the width of the buffers. The results surprised them as there was no appreciable difference between 35’ and 180’ buffers. Even the 5’ buffers provided much of the temperature benefit of the larger buffers:

“Based on our methodology and for these particular buffer sites we can conclude that the smaller buffers (5’ and 15’) were as effective at reducing maximum air temperatures as larger (35’ and 180’) buffers. Average daily temperatures were reduced at the 15’ & 35’ buffer when compared to external (outside buffer) values. It should also be noted that minimum daily air temperatures in the 5’, 15’, and 180’ buffers were not significantly different between sensor locations as was witnessed in the 35’ buffer suggesting that these widths (5’, 15’, and 180’) cool off at similar rates over the course of a 24 hr. period.”

Instead of taking such studies seriously, the large buffer advocates continue to demand that the state implement a law that would require all streams and waterways in the state to have buffers at least 100’ wide. Many would be much larger as the width of the stream is measured from the greatest width of a river or stream in a 100 year flood. This would apply to all waterways, even drainage ditches that have no connection to salmon.

Whatcom County buffers were studied to determine if larger buffers were more effective than smaller buffers, as researchers expected. To their surprise the smaller buffers proved as effective in reducing temperature. Some salmon advocates ignore such science in their demands for massive, inflexible buffers that would destroy much of farming in this area.

As Western Washington has a wet climate with numerous streams, rivers and drainage ditches, farm organizations have estimated that this would remove about 30% of existing farmland in the Puget Sound region. A great many farms would have little acreage left. Remaining acreage would have to be sold because without sufficient landmass, farming is not viable. This ill-conceived idea would result in a much accelerated conversion to urban development in the last remaining farming areas in Puget Sound. It would mean that only the largest farms could survive.

At the heart of this is the misdiagnosis that Chinook recovery depends on this extreme measure to improve spawning habitat. Farmers, tribal leaders and environmental groups agreed in the 2023 Washington legislative session to expand the voluntary buffer program which would have expanded the existing efforts considerably. The more extreme activists succeeded in getting this bi-partisan and effective measure killed.

Section 11: Fish recovery, flooding and storage

The Nooksack River in 2021 was the scene of the twin impacts of climate change in river and stream water. In September of that year, the low flow caused the river temperature to rise and about 80% – 2500 – of the Chinook salmon returning to spawn died. Then, in November the seasonal rains came and the river flooded causing the loss of one life, tens of thousands of farm animals and over $1 billion in damage in the Abbotsford, BC area.

Experts agree that this situation is likely to worsen because climate change is significantly changing the snowpack that this river and corresponding streams depend on. A civil engineering expert with Washington State University, Jennifer Adam, who is studying this situation along with 19 researchers points to the need for storage:

“‘We have this period of time where there’s not enough water to go around,’ Adam explains. ‘In the western US, if there’s not enough water to go around, it’s water law that determines who gets it.’”

She notes that Washington state will need to change how water is stored:

“‘The shift in timing points to seasonal storage. We’re losing our snowpack and becoming more reliant on the reservoirs,’ Adam says.”

The Nooksack River is the only river in the region of comparable size and importance to farming that does not have a reservoir to store the abundant winter water and snowmelt that causes flooding. Because of this, it is likely that low flows will continue to harm fish including Chinook salmon. The misdiagnosis again encourages those seeking solutions to focus on the least productive while ignoring the solutions ready at hand that could make the greatest impact.

Low flow in streams and rivers are a major problem for salmon. In 2021 low flow in the Nooksack River claimed about 80% of the spawning salmon. But just two months later the river flooded causing the loss of one life, tens of thousands of farm animals and over $1 billion in damage. Experts agree in light of climate change storage on rivers like the Nooksack becomes crucial. Yet, salmon advocates strongly oppose storage claiming harm to habitat.

The idea that there is a great misdiagnosis involving Chinook recovery will be strongly opposed by some – particularly the great many whose income is derived from the belief that habitat is the single most important issue. But those who disagree must respond to the five key points listed here. Science, not politics or emotion, must drive this very important issue.

Summary and a Challenge

The idea that there is likely a great misdiagnosis driving salmon recovery advocates to pursue very costly and harmful solutions will be disregarded by many. The scientific proof and facts presented will be closely examined and perhaps rejected. We would like those who disagree to provide the following:

1. Explain why Chinook are uniquely struggling while other salmon species are flourishing.

2. Provide evidence of flaws in the study that showed Chinook in rivers without dams are challenged as much or more as those with dams, such as the Snake River.

3. Show documentation from NOAA that provides strong assurance – if not guarantees – that removing dams will significantly improve Chinook recovery.

4. Explain why salmon advocates are not working to get the approval needed to address the unique and obvious problem of pinniped predation in the Salish Sea.

5. Provide an explanation from the Department of Ecology why harmful actions like water rights adjudication, irrigation restrictions, and massive buffers are still being pursued given compelling evidence that ocean mortality, caused by warming and predation, are primary issues for Chinook while all other species are healthy.

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