Washington Business Summer 2017 | Washington Business | Page 11

advertisement Columbia-Snake River Irrigators Association Request for Formal U.S. Inspector General Investigation June 26, 2017, OPEN LETTER Engineer Inspector General Kevin Elliott Office of the Engineer Inspector General U.S. Army Corps of Engineers (USACE) Inspector General Peggy E. Gustafson Office of the Inspector General U.S. Department of Commerce (NOAA Fisheries) SUBJECT: Request for Formal Investigation – What Happened to the Fish? The Columbia-Snake River Irrigators Association (“CSRIA”) requests that you formally investigate the Columbia River Fish Managers’ decision in 2015, to allow Endangered Species Act (ESA)-listed salmon and steelhead migrations to remain in the Lower Snake River, during extremely poor in-river conditions, rather than rely on the Corps’ juvenile fish transportation program. The fish were exposed to adverse river conditions that almost certainly proved fatal, and have contributed to the low adult fish returns now occurring in 2017. Records show that the Fish Managers deviated from the legally required, ESA BiOp “spread the risk” policy, in the spring 2015, when they transported only 13% of juvenile salmon and steelhead during low flow and high temperature conditions—when young fish are the most vulnerable to the adverse effects of remaining in the river. This was the lowest percent transported since records were first kept in 1993. The action defied sound judgement. In addition to failing to meet their legal, ESA obligation to optimize fish survival, the Fish Managers overlooked their obligation to create a transparent administrative record showing why they made this unusual decision. The available records show that NOAA Fisheries’ scientists attempted to obtain agreement for an early start date to transportation--to get the juvenile fish out of the river during poor survival conditions--but other state agency Fish Managers did not support this crucial action. For reasons not reflected in the record, the Corps apparently felt helpless to act on NOAA Fisheries’ repeated requests. In the long run, CSRIA believes the only practical alternative is to invoke a hydro project exemption, allowed under the ESA statute, commonly called the “God Squad” review. We have requested the U.S. Dept. of Interior to take the first step toward this process. In the short run, however, we will need to live with the ESA litigation process and attempt to make intelligent management decisions regarding ESA-listed fish. There is no more critical decision to make than when to transport juvenile salmon and steelhead, and when to leave them in the river. Although it is too early to calculate the precise effect of the 2015 decisions, initial indicators reveal that the Fish Managers’ judgement likely killed significant quantities of ESA-listed fish. 3030 W. Clearwater, Suite 205-A, Kennewick, WA 99336 509-783-1623, E-Mail: [email protected] 1 | Page