Columbia Salmon: Letter to Gary Locke and Jane Lubchenko

April 6, 2010

The Honorable Gary Locke
Secretary of Commerce
Department of Commerce
1401 Constitution Avenue, NW
Washington, DC  20230

Dr. Jane Lubchenco
Under Secretary of Commerce for Oceans and Atmosphere, and
NOAA Administrator
Department of Commerce
1401 Constitution Avenue, NW, Room 5810
Washington, DC  20230

Re:      Southern Resident Killer Whales

Dear Secretary Locke and Dr. Lubchenco:

NOAA’s Brad Hanson earned media attention and praise for a paper published last month on endangered Southern Resident orcas and their reliance on Chinook salmon.[1] Dr. Hanson’s co-authors included a number of prominent experts on Southern Residents: the principal investigator of the Center for Whale Research, the director of the University of Washington’s Center for Conservation Biology, and scientists from Cascadia Research, to name a few.  The impressive experience of his co-authors adds credibility to Dr. Hanson’s work.

Many of these same scientists expressed deep concern in a letter to you during NOAA’s review of the FCRPS Biological Opinion in the summer of 2009.  Those scientists not only voiced concerns about the quality of the BiOp’s science, but also noted untenable conflicts between the FCRPS biological opinion and an opinion for dam and irrigation projects on the Sacramento River, which was released while the FCRPS BiOp review was under way.  Anyone reading their letter would wonder how one scientific agency could credibly conclude simultaneously (a) endangered orcas can be sustained with no adverse effects by hatchery-produced chinook, and (b) no amount of hatchery-produced chinook can mitigate for the effects on endangered orcas of wild salmon mortality.  That is, one NOAA biological opinion states conclusively, “There is no evidence that a population produced predominantly in hatcheries fish can persist over the long term”[2]; the other relies entirely on hatchery production to compensate for the effects to Southern Residents of dam-related chinook mortality.[3]

NOAA received letters from others knowledgeable about Puget Sound’s keystone predator, which echoed these concerns about the quality of the BiOp and the potential consequences for Southern Resident survival.[4]

Despite these letters, NOAA completely disregarded the concerns these scientists during its review of the FCRPS Biological Opinion. NOAA did not consider, analyze, or refute the concerns raised by these prominent scientists in their letter to you; rather, as far as one can tell from the few documents that have been released, NOAA’s review team did not at any point even broach the topic of Southern Resident orcas when it reviewed the FCRPS Biological Opinion.   As a consequence, the agency’s Adaptive Management Plan  (AMIP) did not include any measures that would ensure that Puget Sound’s orcas have access to adequate levels of chinook salmon.  Indeed, Snake River dam removal – the single most effective action to ensure the recovery of several Columbia Basin salmon stocks and Puget Sound’s killer whales – has been relegated to a decade-long study process, a study that itself would not even begin until salmon populations crash.  An insurance policy that would not pay out until 10-15 years after chinook salmon reach levels that approach extinction is as meaningless to the fish as it is harmful to the killer whales that depend upon them.

A federal court has now given NOAA one last chance to review the scientific underpinnings of the BiOp.  The court has directed NOAA to look at the best available science. People For Puget Sound, representing over 20,000 concerned citizens, urges you not to overlook the Southern Resident orcas during this review, and to take seriously the real possibility of their extinction if wild salmon are not restored to the Columbia River basin

Secretary Locke and Undersecretary Lubchenco, we all know far too well that Puget Sound’s orcas face threats from several directions. While NOAA cannot do everything, when you are given the chance to make a huge positive difference, you should seize it.  The opportunity to dramatically improve the FCRPS BiOp is such an opportunity.

Please let me know how People For Puget Sound can help.

Sincerely,
Kathy Fletcher
Executive Director

cc:  Members of Congress for Washington and Oregon
Governors of Washington and Oregon

[1] B. Hanson et al., Species and stock identification of prey consumed by endangered southern resident killer whales in their summer range, Endangered Species Research (March 2010: 11: 69-82).

[2] Biological and conference opinion on the long-term operations of the Central Valley Project and State Water Project (NOAA: June 2009), pp. 573-74.

[3] Federal Columbia River Power System Biological Opinion (NOAA: May 2008), p.9-16.

[4] Attached for your convenience are last summer’s letters from Southern Resident scientists, Orca Network, Jean Michel Cousteau, and People for Puget Sound