CFM,

I thought my post might frost your pumpkin. It seems like you believe it’s Tacoma’s responsibility to do those things you deem right for the fish or the fishermen. And if I believe differently than you, I must be in Tacoma’s hip pocket. Frankly, I don’t give a rat’s a** about Tacoma, one way or the other. My job doesn’t require that I defend Tacoma nor any state nor federal agency. I need only defend the work that I do. I don’t mind speaking at fishing related or other events in Lewis County or anywhere because I speak to inform, not to make people feel good, same as with posting here.

Tacoma’s responsibilities are spelled out in the Federal Power Act (FPA) and other applicable laws. If you believe Tacoma’s responsibilities are something different, you set yourself up for disappointment.

Yes, I know that Tacoma was asked to change the Cowlitz River flow regime. I also know that change would only come about if persuasive biological and or legal arguments were made. I think the reason changes were not made is because the arguments were not biologically or legally persuasive. The fact that you argued doesn’t make you right. And if you were right, that often still isn’t enough. You have to be right and biologically and legally persuasive under the conditions of the FPA and other applicable laws. I could not require a change in Tacoma’s flow regime unless I could produce evidence meeting the “best available science” standard that Tacoma’s flow proposal does or would harm fish (not fishing). None of the fish and wildlife agencies have any authority to require stream flows that are beneficial to winter steelhead fishing. Resource agencies can only recommend flows that protect spawning, incubation, rearing, and migration. Flow recommendations for good fishing opportunity carry very little currency, by comparison.

Sheesh, NMFS doesn’t consider the decision to rear fewer early winter steelhead a scheme. Also, please be real. NMFS and other agencies don’t maintain that there are any pure steelhead stocks in the Cowlitz. NMFS concern is that Tacoma fully mitigate project effects on the steelhead run. That is, NMFS wants there to be at least as many steelhead returning to the Cowlitz as there would be if Tacoma’s project didn’t exist. NMFS wants that because that is what can be legally had under the FPA and subsequent case law. NMFS doesn’t care, nor do I, how many early steelhead Tacoma rears. NMFS wanted an increase in late winter steelhead for recovery purposes because WDFW says they are dirivitive of the native Cowlitz stock. No one can prove that’s not correct, which isn’t the same as saying it is correct. Again, the best available science, which may not be much, indicates that the late winter steelhead at the Cowlitz trout hatchery are the closest relative to native Cowlitz steelhead. State and federal policies pretty much dictate that the late winters be the “recovery” stock for the Cowlitz. Don’t like it? Bring me a scientifically persuasive counter proposal. If it’s your opinion that the locally adapted early winter steelhead or Skamania fish are just as native as the late winters, I can tell you that won’t cut it. And you already know that I’m partial to Skamania fish, but that’s for purely selfish reasons, not biological ones.

Just because Tacoma is running the river differently today than historically doesn’t mean they are doing something wrong. I really don’t care. What I care about is whether Tacoma’s flow manipulation harms fish. If I cannot produce evidence that Tacoma is harming fish, then I’m stuck, and you’re stuck. Thinking it should be different doesn’t carry any weight with the decision makers. So how is Tacoma’s flow screwing you? What should they do differently, and why? If you cannot show that they are harming fish, you’re out of luck.

The 2,000 cfs Tacoma provides during the summer is greater than the unregulated, natural river flow. All parties to the proceeding favored the higher summer flow as beneficial to fish, and in my experience that has always been the case, so I agreed with it. I didn’t note any opposition. Now you’re saying they should instead drop the river to lower, natural, flow levels? This is the first I’ve heard about low flows being the way to fight C-shasta. The consultants told me that higher winter flood flows would be the natural, effective way to reduce C-shasta problems.

Low-temp, or cold water, disease isn’t likely caused by the deep turbine intakes at Riffe. River water would be colder during the winter in an unregulated, no-dam, situation. Winter water temps are warmer on average due to reservoir storage, so causing cold water disease seems like a stretch to me. If there’s new information, I haven’t seen it.

Yes, I too marvel at the divergence of opinion regarding the number of fish that would be present in the Cowlitz absent the power-dams. The Cowlitz is no different than most western Washington rivers, with or without dams. The watershed is extensively degraded by the effects of urbanization, dikes, levees, sub-urban and rural development, agriculture, roads, and forestry. These developmental effects drastically reduce the fishery productivity and capacity of rivers, completely independent of the additional adverse effects of dams. The Cowlitz basin in degraded, not pristine. It doesn’t even come close to the class of habitat represented by the coastal Olympic peninsula rivers. It’s far more like Puget Sound rivers in the extent of development and habitat degradation. What makes you think it would produce more wild salmon and steelhead than the hatcheries presently do?

Here’s what makes me think it wouldn’t be such a hot river:
No westside river has a wild spring chinook run exceeding 3,000 (ave.). What makes the Cowlitz so special that it would - in this century, not the last?
No lower Columbia River tributary even has a viable wild coho run due to commercial fishery management. Why would the Cowlitz?
No lower Columbia River tributary has a healthy wild steelhead run (they’re all ESA listed!). Why would the Cowlitz?
Only the NF Lewis has a healthy wild fall chinook run. Cowlitz falls have tule timing. Commercial fishing management and sport fishing regulations dooms them to a low level. Why would Cowlitz be an exception?

What are the compelling reasons to believe that if there were no dams on the Cowlitz River that it would host large healthy runs of wild salmon and steelhead? I find none. No undammed lower Columbia River tributary is rated as having healthy, abundant, runs of salmon or steelhead. To think that if there were no dams on the Cowlitz, that the Cowlitz would be an exception, strikes me as complete fantasy.

I think there is a big difference when people base their expectations on opinions rather than facts and law. I don’t think we are so different about wanting fish and fishing opportunity. I think the difference is that my expectation is based on what is available to us under the law. It seems to me that your expectation is based on your opinion of how it should be, rather than how it is under the law. As I indicated at the outset, that sets you up for disappointment.

Sincerely,

Salmo g.