HIGHLIGHTS

• Bonneville Power Administration is starving the Comparative Survival Study (CSS) – one of the most important programs for long-term monitoring of salmon and steelhead populations in the Columbia Basin.
• BPA has not only rejected requests for increased direct funding for the CSS, the agency has also refused collaborative proposals to re-allocate existing funds from other Fish and Wildlife programs to the higher-priority CSS. Instead, BPA transferred savings from other programs to the US Army Corps of Engineers.
• The CSS establishes Smolt-to-Adult (SAR) ratios – measurements of juvenile survival and adult returns in the Columbia Basin. CSS analyses have shown that¹ dramatic increases in SARs are only likely if the Lower Snake River Dams are breached and spill is maximized at the lower Columbia River dams. With SARs remaining well below targeted recovery thresholds, and salmon and steelhead populations continuing to decline towards extinction, BPA is trying to kill the messenger.

The CSS is a large-scale, management-oriented, collaborative, life-cycle monitoring program for salmon and steelhead in the Columbia Basin. The program is coordinated by the Fish Passage Center (FPC) – an independent government agency providing technical assistance and information related to salmon and steelhead passage through the hydrosystem in the Columbia River Basin.

The CSS is a critical database – the foundation of our ability to understand the status of anadromous fish runs in the region. Annual estimates of Smolt to Adult Return survival (SAR) for steelhead and salmon populations throughout the Columbia River Basin are key to evaluating risk of extinction, as well as progress toward recovery goals. Restoring populations of salmon and steelhead require SARs of 4%; endangered Snake River populations remain closer to 1% SAR – well below recovery thresholds.

The Bonneville Power Administration (BPA) markets hydropower from the Federal Columbia River Power System (FCRPS). BPA is responsible, in part, for funding a regional Fish & Wildlife Program designed to mitigate for the impact of the FCRPS. In 2017, under pressure to control rising operational, maintenance, and financing costs amidst declining revenues and cash reserves, BPA announced a cap on spending for the Fish and Wildlife Program despite ongoing endangerment of salmon and steelhead populations.

Passive Integrated Transponder (PIT) tagging efforts constitute 85% of the CSS budget. In the last five years BPA has approved three price increases for PIT tags from the supplier, but has not approved a budget increase for the CSS dependent on those PIT tags – quite obviously and intentionally creating a problem for the program.

Tribal, state, and federal stakeholders, along with the Fish Passage Center, have barely maintained the CSS project. Measures to repurpose PIT tags and otherwise control costs are short-term patches, insufficient to sustain program viability. BPA has rejected requests to increase funding for the CSS.

In July, 2021, state and tribal fishery managers described for BPA a “portfolio approach” in which the two primary Fish and Wildlife Programs – The Smolt Monitoring Program (SMP) and the CSS – would be managed together, and stakeholders would keep combined total program costs within the constraints of BPA’s flat funding decision:

“The problem facing these projects is that they have been flat funded by the Bonneville Power Administration (BPA) Fish and Wildlife Program, since 2017 and as a result of increasing base costs, such as cost of tags and overhead rates, funding for these projects has in reality been reduced since 2017…In addition, since 2017 BPA has agreed to [three] separate increased cost for PIT tags in their negotiation with the vendor, but have not increased the funding for projects that use PIT tags, to reflect these agreed upon increases by BPA”

In the proposal from states and tribes, savings from the SMP would be transferred to the CSS, ensuring the continuity of critical long-term data series. A restatement of the problem, proposed solution, and detailed budget for the portfolio approach was delivered to BPA the next month.

BPA rejected the collaborative proposal. The SMP was reduced by $612,000, but BPA transferred approximately $330,000 to the US Army Corps of Engineers Operations and Maintenance budget – and none to the CSS. There should still be funding left for the CSS, and state and tribal fishery managers are actively pursuing these issues with BPA. Fisheries managers from Idaho, Oregon, and Washington expressed their frustration with BPA’s delays and approach:

“BPA has delayed discussing the proposal with the States three times since early August. Furthermore, recent communication between BPA staff and the Fish Passage Center addressed the reduction of the SMP budget, but instead of shifting the funds to CSS as directed by the Fish Managers, BPA is suggesting that Fish and Wildlife Program funds made available in the portfolio process be used to fund fish condition monitoring at two of these sites for at least the next three funding years. We do not feel that this is an acceptable approach. Fish and Wildlife Program funds should not be used to support activities that are clearly part of the Operations and Maintenance program and just as clearly the responsibility of the Action Agencies to fund as part of operating the projects. “

In February, 2022, the Fish Passage Center submitted a contract modification request including $243,000 of increased funding for the CSS. The memorandum explicitly stated the effect of BPA’s decisions:“The Bonneville Power Administration ‘flat funding’ policy, in place since 2017, has made it impossible for the CSS project to continue.” And the Fish Passage Center again noted that BPA is directing Fish and Wildlife Program funds to the US Army Corps of Engineers Operations and Maintenance budget:

“BPA preliminarily rejected the fishery managers portfolio proposal, in part because BPA needed F&W Program funds to pay for USACOE Operations and Maintenance costs. The SMP has been reduced but contrary to the fishery managers initial recommendations, BPA has transferred Fish and Wildlife Program funding to the USACOE Operations budget to conduct facility condition monitoring. “

The following week, a memorandum reminded BPA that “condition monitoring is a USACOE operations budget obligation” – not something that should be paid by re-allocated Fish and Wildlife program funds.

Also in February, 2022, as BPA squeezed the CSS of less than $250,000 needed to continue critical monitoring of in-river survival, BPA reported that its recent strong financial performance suggests about $280 million higher net revenues than previously forecast.

While small in absolute financial metrics, this issue has massive implications for salmon and steelhead monitoring and recovery in the Columbia basin. As the Fish Passage Center describes, “The CSS is a highly productive project and a high priority for the state, federal and tribal fishery managers. The CSS project contributes to a broad scope of prevailing adult and juvenile salmon and steelhead migration, passage and mitigation management issues”. Restoring salmon and steelhead populations in the Columbia and Snake River system is now one of the most protracted, expensive, and ineffective species recovery projects in U.S. history. Obstructing the CSS will directly impair our understanding of population trends and take measures that might actually benefit fish.

This issue is also important as an expression of BPA’s fundamental, intractable conflict of interest: BPA is an unappropriated hydropower marketing division of the federal government, dependent on sales of electricity from a portfolio of aging, ecologically destructive dams. BPA is also in charge of allocating hundreds of millions of dollars of “mitigation” funding as part of an endangered species recovery program that nearly every fisheries biologist has told us will ultimately depend on removing and/or significantly modifying the operations of those same dams. BPA doesn’t like what the CSS tells us about the impacts of the hydro system on endangered salmon and steelhead, so they are trying to quiet the program.

BPA certainly has the flexibility to amend, increase, and extend contracts. In fact, at the very same time BPA was freezing Fish and Wildlife program spending in 2017, the agency contracted for a study which would argue, conveniently for BPA and in opposition to 30 years of expressed scientific consensus, that the hydro system isn’t the limiting factor on salmon and there’s not much we can do for endangered Columbia Basin anadromous fish in the freshwater portion of their life cycle. Even personnel at NOAA Fisheries, in a division dependent on BPA for a large slice of its budget, noted the curious decision to fund the David Welch-led project amidst a “stingy” funding environment (DOC-NOAA-2021-001245):

Yet the contract value was increased twice, from $110,000 to $319,000, and a related $75,000 contract added – for a total value of almost $400,000. BPA even made the peculiar decision to fund the contract from its Technical Services division, which placed the Scope of Work outside the Northwest Power and Conservation Council’s review. The contract’s conclusions were thoroughly debunked in a scathing memo by none other than the Fish Passage Center, which summarized (boldface in original)

“Our overall conclusion of this review is that Welch et al. (2020) is technically flawed. Therefore, their contentions that Columbia River rebuilding targets may be unachievable, that broad oceanic factors are a primary driving force in Chinook salmon survival coast- wide, and that freshwater management and mitigation activities are misdirected are not supported by the considerable body of available scientific information. Quantitative analysis of their own selected data sets does not support their conclusions. Our primary conclusions are listed below, followed by detailed discussions of each point…”

Apparently, then, the Fish Passage Center / CSS has committed two offenses in BPA’s eyes: consistently enumerating the deleterious impact of the hydro system on endangered salmon and steelhead populations, and criticizing the special project for which BPA contracted amidst a programmatic spending freeze. This context is inseparable from BPA’s rejection of CSS budget increase requests, commensurate with BPA-approved cost increases from hardware vendors. This context is also inseparable from the agency’s rejection of the collaborative “portfolio approach” to sustaining the CSS. And this context is further inseparable from BPA extending a giant bureaucratic middle finger to CSS partners by instead allocating savings within the Fish and Wildlife program to the U.S. Army Corps of Engineers – for activities the USACE is supposed to be conducting, regardless.

BPA isn’t accountable for this behavior. The agency has purchased lots of influence in the region, and its control over scientific research, monitoring, and habitat restoration funding gives it profound leverage over the organizations and agencies needing allocations to do the work. Among many other distortions, this power dynamic produced the 2008 Fish Accords (and their 2018 renewal) – BPA’s “legal bribe“of dependent Tribal and State fisheries programs, which signed away their right to advocate for dam removal in exchange for habitat restoration and hatchery program funding that BPA is unambiguously required to provide, anyway. And now this dynamic threatens the region’s priority program for monitoring salmon and steelhead through the hydro system and what’s left of the river.

1. “In relative terms, the greatest benefits are seen when the four Lower Snake River dams are breached and the four Middle Columbia River projects spill to 125% TDG levels in the tailrace “ 2019 CSS Annual Report, pg. 54