Dear U.S. Army Corps of Engineers, Bureau of Reclamation, and Bonneville Power Administration,
Thank you for the opportunity to comment on the Columbia River System Operations (CRSO) Draft Environmental Impact Statement (DEIS). I am writing specifically out of concern for the endangered Southern Resident orca population, a unique community of fish-eating orcas that lives off the west coasts of the U.S. and Canada. The DEIS fails to adequately address the connection between Columbia and Snake River salmon and Southern Resident orcas, and the impact that declining salmon abundance has on their survival.
As salmon specialists, the main component of the Southern Resident orcas’ diet is Chinook salmon, and they have depended on the region’s historically abundant Chinook runs for millennia.  The Columbia Basin is still a significant source of food for Southern Resident orcas, particularly in the winter and early spring when the orcas are foraging in coastal waters. They are highly likely to be off the mouth of the Columbia River, recognized as a “high use foraging area,” when early spring Chinook are returning. Analysis of prey and fecal samples collected from the Southern Residents orcas in coastal waters indicate that over half of the Chinook consumed are from the Columbia River Basin. 
As Chinook salmon abundance has declined throughout the Pacific Northwest and California, the orcas have suffered. Scientists have found a strong correlation between coastwide Chinook abundance and Southern Resident health indicators: declining Chinook abundance leads to reductions in growth rates, adult length, social cohesion, fecundity, and survival, as well as impaired body condition in Southern Resident orcas.  It is clear that the orcas do not have enough to eat, that nutritional stress has severe impacts on the population, and that recovery of Columbia Basin salmon is essential to ensure their survival.
Independent salmon scientists, the National Oceanic and Atmospheric Administration, and this DEIS itself have all determined that breaching the Lower Snake River dams is the best way to recover sustainable wild runs of Snake River spring/summer Chinook salmon.  However, the Preferred Alternative offers only a minor adjustment to the status quo, which will not be enough to recover endangered salmon or orcas. Therefore, to support the recovery of the endangered Chinook salmon stocks that Southern Resident orcas rely on, the action agencies should implement measures that maximize salmon survival – a combination of Alternative 3, breaching the Lower Snake River dams, and Alternative 4, implementing flexible spill levels up to 125% Total Dissolved Gas throughout the migration period for juvenile salmon. These measures are predicted to result in the greatest improvements in salmon survival and have the highest likelihood of meeting recovery goals for endangered salmon, resulting in increased abundance available to Southern Resident orcas.
This action must be accompanied by continued support and investment in salmon recovery and habitat protection and restoration throughout the range of the orcas. Efforts by state and federal leadership are needed to develop and implement a transition plan to support communities that currently rely on the Snake River dams, and to replace them with carbon-free energy alternatives.
The Southern Resident orcas face a multitude of threats, but a lack of Chinook salmon is the primary limiting factor for their survival and recovery. They need abundant and available food – high-fat and nutritious Chinook salmon – year-round. Breaching the Lower Snake River dams is a vital step for restoring abundant salmon in the Pacific Northwest to support Southern Resident orcas, and rebuilding a healthy watershed to support regional ecosystems and communities.
Thank you for the opportunity to comment.
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