^q,P\<^/\0','^M^AOH''^^/ S. Hrg. 104-291 SALMON SPILL POUCY ON THE COLUMBIA AND SNAKE RIVERS ft^* HEARING ....-r^f^'^ BEFORE THE SUBCOMMITTEE ON DRINKING WATER, FISHERIES, AND WILDLIFE OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED STATES SENATE ONE HUNDRED FOURTH CONGRESS FIRST SESSION JUNE 22, 1995 Printed for the use of the Committee on Environment and Public Works RECEIVED JUL 3 1 2003 BOSTOll PUBLIC LIBRARY GOVERNMENT DOCUMENTS DEPARTMEI U.S. GOVERNMENT PRINTING OFFICE 92-631 cc WASHINGTON : 1995 For sale by the U.S. Government Printing Office Superintendent of Documents. Congressional Sales Office, Washington, DC 20402 ISBN 0-16-052174-2 '^q.nyc-.'^Mi^AOH'j'^/ S. Hro. 104-291 SALMON SPILL POUCT ON THE COLUMBIA AND SNAKE RIVERS '^f^ HEARING ..^i^€^^ BEFORE THE SUBCOMMITTEE ON DRINKING WATER, FISHERIES, AND WILDLIFE OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED STATES SENATE ONE HUNDRED FOURTH CONGRESS FIRST SESSION JUNE 22, 1995 Printed for the use of the Committee on Environment and Public Works RECEIVED JUL 3 1 2003 BOSTON PUBLIC LIBRARY GOVERNMENT DOCUMENTS DEPARTME; U.S. GOVER>fMENT PRINTING OFFICE 92-531 CC WASHINGTON : 1995 For sale by the U.S. Government Printing Office Superintendent of DcKumenLs. Congressional Sales Office, Washington, DC 20402 ISBN 0-16-052174-2 fOi^^,C COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS JOHN H. CHAFEE, Rhode Island, Chairman JOHN W. WARNER, Virginia MAX BAUCUS, Montana ROBERT SMITH, New Hampshire DANIEL PATRICK MOYNIHAN, New York LAUGH FAIRCLOTH, North CaroUna FRANK R. LAUTENBERG, New Jersey DIRK KEMPTHORNE, Idaho HARRY REID, Nevada JAMES M. INHOFE, Oklahoma BOB GRAHAM, Florida CRAIG THOMAS, Wyoming JOSEPH I. LIEBERMAN, Connecticut MITCH McCONNELL, Kentucky BARBARA BOXER, CaUfornia CHRISTOPHER S. BOND, Missouri Steven J. Shimbero, Staff Director J. Thomas Sliter, Minority Staff Director Subcommittee on Drinking Water, Fisheries, and Wildlife DIRK KEMPTHORNE, Idaho, Chairman LAUCH FAIRCLOTH, North CaroUna HARRY REID, Nevada CRAIG THOMAS, Wyoming FRANK R. LAUTENBERG, New Jersey CHRISTOPHER S. BOND, Missouri JOSEPH I. LIEBERMAN, Connecticut JOHN H. WARNER, Virginia BARBARA BOXER, CaUfornia :oos (II) CONTENTS Page OPENING STATEMENT Kempthome, Hon. Dirk, U.S. Senator from the State of Idaho 1 Letters and comments relative to NMFS salmon recovery plans 60-81 WITNESSES Anderson, James Jay, University of Washington, Seattle, WA 11 I*repared statement 146 Bohn, Colonel Bartholomew, Deputy Division Engineer, North Pacific Divi- sion, U.S. Army Corps of Engineers 23 Prepared statement 120 Bouck, Gerald, Biologist, Portland, OR 6 Prepared statement 151 Bowles, Ed, Anadromous Fish Manager, Idaho Department of Fish and Game 26 Prepared statement 110 Ebel, Wesley. Biologist, Seattle, WA 4 Prepared statement 122 Fidler, Larry, Aspen Sciences Limited, Cranbuck, BC 3 Prepared statement 87 Filardo, Margaret, Fish Passage Center, Portland, OR 7 Prepared statement 114 Mundy, Phillip, Fisheries and Aquatic Services, Lake Oswego, OR 9 Prepared statement 106 Responses to questions by Senator Kempthome 141 Stelle, Will, Director, Northwest Region, National Marine Fisheries Service .... 21 Prepared statement 99 Report, "Summary and Comparison of Regional Conservation Strategies for Colvunbia River Salmon," July 1995 35 Review of the NMFS 1994 Supplemental Spring Spill Program 53 Responses to questions by Senator Kempthome 103 (HI) SALMON SPILL POLICY ON THE COLUMBIA AND SNAKE RIVERS THURSDAY, JUNE 22, 1995 U.S. Senate, Committee on Environment and Public Works, Subcommittee on Drinking Water, Fisheries and Wildlife, Washington, DC. The subcommittee met, pursuant to recess, at 10:02 a.m. in room 406, Senate Dirksen Building, Hon. Dirk Kempthome [chairman of the subcommittee] presiding. Present: Senator Kempthome. OPENING STATEMENT OF HON. DHIK KEMPTHORNE, U.S. SENATOR FROM THE STATE OF ffiAHO Senator Kempthorne. Ladies and gentlemen, I'll call this meet- ing to order. A little more than 2 weeks ago, this subcommittee held our first field hearings in Roseburg, OR and Lewiston, ID. At those hear- ings, we had a combined attendance of about 2,000 people; in fact, it exceeded 2,000 people. We wanted to hear from people whose lives had actually been affected by the Endangered Species Act, both positive and negative. We had a good, balanced hearing which centered on the efforts of the National Marine Fisheries Service and the Corps of Engineers to restore chinook and sockeye salmon runs in the Columbia Basin. One method used by NMFS to pass young salmon, called smolts, over the dams is to spill the smolts over the dams rather than ei- ther pass them through the turbines for generating electricity, or physically to collect the smolts and transfer them through a bypass system. When water is spilled over a dam, gases in the air become dissolved in the water. Depending on the percentage of the satura- tion of those gases in the water, fish can get a diseases called the Gas Bubble Trauma, or GBT, which is similar to the bends which scuba divers can get if they surface too quickly after a dive. This morning's hearing will focus on how the National Marine Fisheries Service and the Corps of Engineers chose this particular scientific policy under the Endangered Species Act. NMFS chose this scientific policy in order to increase survival of young, endan- gered chinook and sockeye salmon, but I believe that this policy was hastily conceived without sufficient safeguards provided in the scientific method; and that as a result, we may be continuing to en- danger the very species that we want to protect. (1) Last year, in a subcommittee hearing on the Endangered Species Act, Dr. Nancy Foster, who is the Deputy Assistant Administrator for Fisheries at NMFS, said, if we weren't experimenting with spill- ing water over the dams causing damage to the species we were trying to protect as well as other species, and that, "If it were a perfect world. . . ," NMFS would have studied effects of spill ahead of time. I think it is a reasonable question how, in the ab- sence of science, this type of experimentation with endangered spe- cies could take place. There are many, very complex issues involved in restoring the Columbia and Snake River salmon to healthy populations. Let me state here for the record that I am committed to tne full restoration of salmon in Idaho and the Columbia River Basin, but it seems to me that we have to get on with practical solutions to enhance and restore these salmon runs. Without practical solutions, the only thing we will end up enhancing is the salmon recovery industry. The effort to recover the salmon in the Columbia Basin can act as a guide as we move forward to reform the Endangered Species Act. This subcommittee today is interested many aspects of this hearing: 1. How can we get the best scientific information; 2. How can we be sure that scientific information is put through meaningful peer review; 3. Will good science be communicated to the policymakers in the proper agencies; 4. As new information is made available, can we be sure that those policies can be modified; and 5. How can we judge the results of recovery plans based on that scientific information? In the interest of finding out how the policy is influenced by the science, I'm going to reverse the usual process today. I'm going to ask the panel of scientists to describe the current state of knowl- edge on the issue of spills and its effects. Then I'll turn to the Fed- eral and State agency panel to hear how they have formulated and/ or revised public policy. I'll ask each of our members of the panel to keep your comments to 5 minutes in your opening comments. Your entire statement will be entered into the record. After each panel has finished its opening comments, I will allow time for ques- tions and answers before moving to the next panel. With that, if our scientific panel would please come forward. Let me identify the members of that first panel: Larry Fidler with the Aspen Sciences Limited, Cranbuck, British Columbia; Wesley Ebel, biologist, Seattle, WA; Gerald Bouck, biologist, Portland, OR; Mar- garet Filardo, with the Fish Passage Center, Portland, OR; Phillip Mundy, with the Fisheries and Aquatic Services, Lake Oswego, OR; and James Jay Anderson, University of Washington, Seattle, WA. With that, if we are ready, Mr. Fidler, if you would like to begin. I might mention, we will use these lights just as an indicator to help us stay on course. The green light is proceed and you'll see the yellow light come on saying you are down to about 30 or 45 sec- onds and then the red light. At that point, I would ask that you conclude, but again, we're going to have an opportunity for the questions and answers to really go into greater detail than what you may feel you're covering in your opening comments and your formal opening statements will be made a part of the record. With that, let me call on Mr. Fidler. STATEMENT OF LARRY FIDLER, ASPEN SCIENCES LIMITED, CRANBUCK, BRITISH COLUMBIA Mr. Fidler. Thank you, Senator. This morning, I would like to review two of the main topics I dis- cussed in my written testimony. The first item is the question of are benefits of spill as a fish passage mechanism established, espe- cially in relationship to other fish passage mechanisms? My re- sponse to that is I do not believe that is the case for the following reasons. In the NMFS' biological opinion, NMFS failed to present a quan- titative, comparative analysis of the various fish passage mecha- nisms. This is especially true in the case of spill and the effects of dissolved gas supersaturation and gas bubble trauma in fish. With- out such a comparative analysis, it is impossible to establish which is the best mechanism or combination of mechanisms for survival. Second, in the spill in 1995 risk assessment document, the State and tribal agencies present data to demonstrate that spill is the best fish passage mechanism. However, as I pointed out in my written testimony, much of that data is highly inconsistent and fails to support that hypothesis. Furthermore, the so-called risk as- sessment analysis performed in that spill in the 1995 risk manage- ment document, the analyses were severely criticized by NMFS sci- entists, by scientists with the Oregon Department of Environ- mental Quality and by independent scientists. The methods used in the analysis of gas bubble trauma were flawed to the extent that the results were invalid. I would suggest that if the National Marine Fisheries Service had used their 1994 expert panel on dissolved gas supersaturation to review both the biological opinion and the spill and 1995 risk management document, a more scientifically defensible spill pro- gram could have been developed. The second area I would like to discuss is the 1995 Biological Monitoring Program. You have no doubt read and you will probably hear today that this is a fine program. I would suggest this is not the case. Before describing my reasons for this, I am reminded of something I heard earlier this year. On April 14, 1995, the Oregon Department of Environmental Quality held hearings to review the application by NMFS for a variance to the Oregon State standard for dissolved gas supersaturation. At that hearing, one of the commissioners made the observation that in his view, the 1995 Biological Monitoring Program had been designed specifically to avoid find signs of gas bubble trauma in fish. Senator Kempthorne. Would you repeat that? Mr. Fidler. Yes. One of the commissioners — I'm paraphrasing here — indicated that it appeared to him that the 1995 Biological Monitoring Program was specifically designed to avoid finding signs of gas bubble trauma in fish. After the program proceeded, I believe that observation is verified for these reasons. In 1994, fish were examined for the presence of bubbles in gill lamella and lateral lines. In June 1994, on certain days, up to 80 percent of the fish sampled had bubbles in gill lamella and up to 50 percent of the fish sampled had bubbles in the lateral line. Yet, in 1995, no signs of gas bubble trauma are being reported. Yet, the dissolved gas levels in 1995 are substantially higher than they were in 1994. In the NMFS net pen studies below Ice Harbor, in 1995 the levels of mortality are much higher than they were in 1994. So the question is, why do we see this discrepancy in data. I believe there are a number of reasons. One is that in 1994 in examining the fish for signs of gas bubble trauma, they used 90- to 100-power microscopes; in 1995, they are using 10-power mag- nification to look for these signs. Until only recently, no examina- tion for bubbles in gill lamella were being conducted. As early as July 1994, the problem of high hydrostatic pressures in the bypass system causing the collapse of bubbles before fish are collected for exsmiination was identified. This problem was later validated through experiments at Battelle Pacific Northwest Lab- oratories. Yet, even to this day, the smolt bypass systems continue to be used as the primary source of fish for assessing the impact of gas bubble trauma. I think there is a serious credibility problem with the Smolt Monitoring Program, but I also think there is a more fundamental problem and that is in 1995, the program has been designed with- out an understanding of how fish are distributed in the Columbia and Snake Rivers in relation to dissolved gas levels, the periods of exposure and potential for mortality. As a result, the present pro- gram is an unfocused collection of attempts by various agencies to sample fish without an understanding of the appropriate locations and conditions under which to assess the impacts of dissolved gas supersaturation on Columbia and Snake River salmon runs. Finally, I believe if the NMFS expert panel on Dissolved Gas Supersaturation had been directly involved in the design of the monitoring program, we would have had a much more viable pro- gram than we presently have. Thank you. Senator Kempthorne. Thank you very much. I appreciate your testimony. I'd like to now call on Mr. Wesley Ebel. Welcome. STATEMENT OF WESLEY EBEL, BIOLOGIST, SEATTLE, WA Mr. Ebel. Thank you. I'd like to address my comments again to question No. 1 and a little bit on question No. 5. The benefits of using controlled levels of spill as a fish passage mechanism are established if there is no other alternative than passage through turbines. Available research indicates that juve- nile salmon will survive at a significantly higher rate passing over a spillway than through turbines at the Columbia River Dam. Thus, spilling water at dams where fish are not collected and transported or where juvenile bypasses are inadequate does have some scientific validity as long as spill volumes are held at levels that do not cause excessive mortality from gas bubble trauma. The benefits of spill are not established in relation to smolt transportation. To tne contrary, the best available data indicates that survival of fish collected and transported is greater than in- river survival of migrants even during periods of high flow and spill. Since 1968, over 29 tests were conducted to evaluate the ef- fects of transporting juvenile spring, summer, fall chinook and steelhead. In these tests, marked groups of fish released in the river as controls and transported by barge or truck were enumer- ated when they returned as adults to the fishery and to the dam and sometimes to the spawning grounds when sufficient numbers were marked. All but two of these tests showed a benefit from transportation. In other words, transported fish returned at a significantly higher rate than fish released in the river. Two tests that didn't show a benefit indicated no significant difference. In other words, it didn't matter whether you transported them or left them in the river; the survival was the same. Unfortunately, since 1983, there have been only 2 years, 1986 and 1989 when both transport and control leases were marked for proper evaluation of the transport operation. During the remainder of the years, no fish were marked or only transport groups were marked, making comparisons with in-river migrants impossible most years. However, the research results available today nevertheless dem- onstrates unequivocally that transport of chinook and steelhead from the Snake River Dams benefits salmon and steelhead more than it does river migration. I have seen no convincing scientific studies that indicate spilling at Lower Granite and Little Goose Dams or McNary Dam is better than collecting and transporting fish from these up-river dams. State and tribal fishery agencies have attacked transportation research but I believe their criticisms lack merit. In regard to how we can improve the decisionmaking process, I believe the decisionmaking process can be improved by continuing to properly evaluate actions taken to increase adult returns of salmon and steelhead on the Columbia River. Key studies are those designed to evaluate transportation and in-river survival of juve- nile migrants under various flow and spill scenarios. If the proper studies had been continued through the 1980's and 1990's, as the National Marine Fisheries Service prc^osed, we wouldn't be here today testifying before this committee. I think we'd have enough in- formation to make decisions that people couldn't argue with. NMFS proposed continued evaluation of transportation and in- river survival of juvenile migrants during the 1980's and 1990's but these proposals were rejected by the various committees that must approve research proposals on the Columbia River. Those commit- tees are dominated by State fishery agencies and tribes, and some of the same people who are severely criticizing the transportation operation now are the same ones that rejected the research propos- als in the 1980's and 1990's to evaluate transportation and to con- duct in-river survival estimates. I believe if we're going to spend millions on various activities to increase survival of the fish in the river, we ought to spend a few bucks on properly evaluating what we're doing. 6 Senator Kempthorne. Thank you very much. I appreciate your testimony. I'd like to now call on Mr. Gerald Bouck. Welcome. STATEMENT OF GERALD BOUCK, BIOLOGIST, PORTLAND, OR Mr. BouCK. Thank you, sir. First, I'd like to mention that my comments are critical of some processes, but I don't direct those at any of the people. Senator Kempthorne. I understand that and I appreciate that. We're just trying to figure out the best process and the science that is there. Mr. Bouck. I guess the bottom line question here is: is spill help- ing the salmon? For me, this is deja vu all over again. We went through this in the 1960's and 1970's and I thought the gas supersaturation problem was over; now we're back at it again with the spill and the gas supersaturation problems still on the Colum- bia River. Is the spill helping the salmon? I don't think so. I agree with the Snake River Salmon Recovery Team that the spill is probably hurt- ing more than it helps. It's critical to appreciate that the basic ben- efit of spill is really quite small, so it's very easy to negate it. This benefit critically assumes that there is reailv no problem from gas bubble disease. A lot of that assumption is based on the idea that fish will dive and thus avoid the supersaturation problem. In fact, it has been shown that avoidance by fish does occur sometimes in the laboratory but there's no evidence that it actually works in the wild. Conversely, there are numerous reports in the literature that show supersaturation fish after fish kill in lakes, rivers, streams and estuaries where the fish had plenty of depth that thev could dive to safety but for one reason or another, did not. So I have to say at the least, avoidance behavior is very unreliable and probably unsafe. You might ask why don't we see dying fish in the river if we real- ly have a gas problem? Well, we have a lot of predators there. If you're going to see dying fish in the river, first you have to fill up all those predators and they have a lot of consumptive capacity. If you want to see dead fish, you've got to keep the predators out of the picture by putting the test fish in a cage, and when you do that, you find dead fish in supersaturated river water. At any rate, the next thing I would address is how are NMFS and the National Biological Service performing in this issue? Larry has already pointed out that the reported incidence of gas bubble disease is down this year but I'm very concerned that this reflects a change in investigative procedures, besides, they are only looking at the survivors and once a fish is eaten and digested, it is no longer in the population anymore. I think that a problem exists with the way NMFS and NBS are doing things. I gave NMFS some constructive recommendations and not long thereafter was told I wasn't welcome on the National Marine Fisheries Service boats. The National Biological Service ba- sically followed suit and thereafter declined to collaborate or co- operate with us. At present, NMFS and NBS have kind of an iron curtain around them. Their refusal to cooperate or collaborate with the private sector, I think, is extremely unfortunate because it is depriving the public of additional data that could be obtained at no cost to the Government just by working together. So what will help the salmon? I think good science has nothing to fear from peer review. It prevents mistakes before they happen in most cases. I'm sure you're aware that the Northwest is spend- ing something in the neighborhood of $400 million a year on salm- on, depending on how you calculate it and that we spent in the neighborhood of over a billion dollars in the last 10 years. And yet, we have almost no progress to show for that expenditure. I was as- sociated with the Columbia River Basin Fish and Wildlife Program, I funded an awful lot of those projects, and as I said, it's just awful hard to see any progress out there. Something needs to change and it needs to change drastically. I think the most important thing is to open up this currently "closed shop" and let some sunshine in. I'd let the universities and the pri- vate sector participate, particularly by providing peer review which can help make lemonade out of the fishery agencies' lemons. Finally, we need a new spirit of cooperation and collaboration without which we'll just simply have more polarization and less progress. Thank you. Senator Kempthorne. Thank you very much. Now we have Ms. Margaret Filardo. Welcome. STATEMENT OF MARGARET FILARDO, FISH PASSAGE CENTER, PORTLAND, OR Ms. Filardo. Thank you, Senator, for inviting me today to speak to this committee. I have worked for the past 8 years as a biologist for the Fish Pas- sage Center in Portland, Oregon. The Fish Passage Center was es- tablished in 1984 by the Northwest Power Planning Council. The Fish Passage Center staff consists of individuals with expertise in biology, biostatistics, hydrology and data management. We are re- sponsible, in part, for the annual implementation of the Smolt Monitoring Program as well as collecting and distributing data to all interested individuals. The Smolt Monitoring Program monitors juvenile salmon in the Snake and Columbia River systems of seven dams and five tributary traps. Information is collected relative to the overall species abundance and health and timing of the migra- tion for in-season management of flow, spill and hydrosystem oper- ations. Since 1994, the Smolt Monitoring Program has been an in- tegral part of the overall biological monitoring program developed by the National Marine Fisheries Service for spill implementation under the biological opinion. Our responses to the questions posed to me by the subcommittee are contained in my written testimony. In the next few minutes, I would like to take this opportunity to make three specific points. First, spill as a mitigation measure is not a new concept. Second, the risk associated with the spill program have been analvzed and incorporated into the development of the present controlled spill program. I'd like to make that distinction between the controlled fish spill program and other spill that is occurring in the system. I am confident that the present monitoring program is accurately assessing the occurrence of total dissolved gas and will provide 8 early indication of developing signs of gas bubble trauma. I'd like to elaborate on these points. Spill for fish passage is not a new concept; it has been the long- standing goal of the natural resource agencies and Indian tribes to provide a safe passage route for fish passing a hydroelectric project. The goal of the agencies and tribes has been to achieve nonturbine passage routes for 80 percent of the fish passing a dam. Spill has long been considered a viable method of project passage; numerous studies have consistently shown that it is the safest route of pas- sage past a dam. In the early to mid-1980's, the provision of spill was compatible with the operation of the hydro systems since there was an energy surplus and power operators had excess water. As the region shift- ed from the energy surplus, the issue of spill became more prob- lematic. Spill is presently being implemented according to the Na- tional Marine Fisheries Service Biological Opinion for 1995 with specific restrictions on spill levels imposed by the State limits for total dissolved gas. I'd like to point out that the volume of spill called for through the biological opinion is actually substantially less and has occurred in some past years. The National Marine Fisheries Service has made every effort to obtain and consider input from diverse organizations in develop- ment of the 1995 biological opinion. The steps taken in the develop- ment of the spill program represent technical and scientific proc- esses that occurred over several years. The risks associated with spill were analyzed and incorporated into the development of the present spill program. In the fall of 1994, the agency and tribal resource management team reviewed all of the available literature and studies to develop an assessment of the risks associated with spill. The risk was measured in terms of trading oft" the benefits to fish by avoiding turbine passage versus the detriments associated with mortality due to increased levels of total dissolved gases. The agencies and tribes concluded that spill is beneficial at levels of total dissolved gas greater than the levels adopted by the National Marine Fish- eries Service in the Biological Opinion. The National Marine Fish- eries Service chose a more conservative level of total dissolved gas based on their concerns regarding the sublethal effects of gas expo- sure. I conclude therefore that the NMFS spill policy is both sci- entifically valid and conservative. The 1995 Spill Implementation Program includes both physical and biological monitoring programs. The monitoring program cur- rently being implemented is based on the recommendations of the Expert Panel on Dissolved Gas convened by the National Marine Fisheries Services and on recent research results on signs of gas bubble trauma. Research and monitoring recommended by the State, tribal, Fed- eral and private special interest groups and consultants has been incorporated into the monitoring and research programs for 1995. Individual aspects of the present program are being conducted by State, tribal, Federal scientists and independent consultants. Addi- tional research is being conducted in 1995 which will be reviewed and incorporated into future monitoring programs. In conclusion, I'd like to leave vou with the following points. Spill has been shown to be consistently the safest route of passage past a dam. The controlled spill for fish passage program was developed on the basis of past research and monitoring. It was developed with broad regional input by public and private entities. The spill for fish program was developed using a conservative analysis of the risk and benefits associated with spill and dissolved gas. An exten- sive research and monitoring program has been implemented to verify the program; a broad range of research and monitoring data is being collected to evaluate the impacts and benefits of the spill program; and all of the information collected will be incorporated into analyses to evaluate the effects of recovery measures on Snake River salmon. Thank you for this opportunity. Senator Kempthorne. Thank you very much, Ms. Filardo. Now we have Mr. Phillip Mundy. STATEMENT OF PHILLIP MUNDY, FISHERIES AND AQUATIC SERVICES, LAKE OSWEGO, OR Mr. Mundy. Good morning. Senator Kempthorne. I appreciate the opportunity to be here tooay. To put the spill issue currently before you into perspective, I'd like to point out that nitrogen supersaturation is a phenomenon that occurs extensively in the kinds of waters that salmon occupy. In over 20 years of experience as a salmon biologist working with healthy salmon populations in Alaska, I have never seen or even heard of a fish kill of juvenile salmon that was caused by nitrogen supersaturation. In Alaska, we have monitoring programs that at- tempt to estimate the number of smolts leaving the major rivers, so I believe if there had been such, we would have seen it. The nat- ural falls and cataracts of the Columbia River system prior to im- poundment produced nitrogen supersaturated environments that must have been quite extensive. In moving into my commentary here, I would like you to bear in mind that you're dealing here and talking about the recovery of a species that has evolved over a period of at least 10 million years to deal with situations in the natural environment and to overcome those. So nitrogen supersaturation is definitely a phenomenon in natural waters. Mr. Chairman, I believe that the National Marine Fisheries Service has acted prudently in selecting spill as a recovery tool for endangered salmon in the Snake River. As a matter of best profes- sional iudgment, spill is the safest way to move juvenile salmon past a hydroelectric project. Spill has been tested in a wide variety of situations and has been found to kill smaller numbers than the turbines and the mechanical bypass systems. Then why is there so much controversy over the use of spill as a recovery measure for Snake River salmon? It appears that the cost of spill combines with lack of knowledge about what happens to the fish in the reservoirs to create the opportunity for yet an- other distraction from the central issue of salmon recovery. The central issue of salmon recovery is how to measure survival of juve- nile and adult salmon through the hydroelectric system. If spill were not so expensive, I do not believe we'd be here today. 10 On the other hand, I see no alternative to spill in the near term. In the long term, the most promising alternatives to spill involve an end to electric power generation and transportation of commod- ities on the lower Snake River, so I think it behooves us to see whether or not we can make spill work. The benefits of using spill as a juvenile fish passage mechanism are established for a broad variety of localities. However, each hy- droelectric dam is different, so the actual benefits achieved will de- pend on the design of the hydroelectric facility, the species, the life history type, and ambient physical conditions, among other factors. The benefits of spill are established in relation to the passage mechanisms of turbines and bypass in some localities for some spe- cies and life history types. However, the same limitations of time and place apply to these comparisons as described above for the overall benefits of spill as a passage mechanism. • Nitrogen supersaturation definitely poses a risk to migrating salmon and the resident species since prolonged exposure to nitro- gen saturation levels above approximately 115 percent at the sur- face has been demonstrated in the laboratory and in net pens to be lethal to fish. The risk may be negligible or serious depending on the degree to which the distribution of the fish coincicfes with the distribution of the nitrogen supersaturated waters. To put nitrogen supersaturation into perspective, I do not regard the risk of mortality for salmon, which are actively migrating through nitrogen supersaturated waters to be as serious as the risk posed by migrating through turbines or bypasses for a number of reasons. First, supersaturation drops off sharply with depth. For example, the potential lethal total dissolved gas level of 140 per- cent at the surface is reduced to the still potentially lethal but lower level of about 126 percent just below the surface. Second, migrating adult chinook are known to travel closer to the bottom than to the surface of the reservoirs when they have the op- portunity. Third, although juveniles have been observed at all depths in the water column, the majority of juvenile salmon are likely to travel in an average depth of aoout 10 feet according to one study. Fourth, if gas bubble trauma is affecting large numbers of juve- niles, I would expect to see much higher rates of symptomatic juve- niles than the negligible rates observed in 1995. Fiftih, althougn the depths occupied by resident fish depend on factors such as feeding and reproductive behavior, monitoring studies have found few resi- dent fish with gas bubble trauma symptoms. Sixth, the effects of nitrogen supersaturation on juvenile salmon appear to be reversible since juvenile salmon are frequently re- ported to recover from the effects of exposure to nitrogen supersaturated water. In closing, I would like to point out that it is really a stunning indictment of the research system that we've spent so much money and we don't have estimates of survival of juveniles in the hydro- electric system. I would echo the comments of other people who have called for an independent peer review process to guide re- search. I think we do this in all other areas where we spend very large quantities of public money on research. Thank you. 11 Senator Kempthorne. Mr. Mundy, thank you for your comments. Now we have Mr. James J. Anderson. STATEMENT OF JAMES JAY ANDERSON, UNIVERSITY OF WASHINGTON, SEATTLE, WA Mr. Anderson. Thank you, Senator Kempthorne, for inviting me to offer this testimony. I'd like to describe to you some of the results from a project that I have been working on for 7 years, the Columbia River Salmon Passage Project. We have developed some models to describe the movements and survival of fish through the hydro system and through their life cycle. This project has been rather extensive. About 20 people are working on it, including undergraduates and graduates. Several Ph.D. theses have come out of this work. We are actively engaged in trying to understand in terms of the mathe- matics and the underlying data how fish move through the river, and the consequences of the actions we take on the fish. I want to emphasize today that these are a synthesis of the types of information we have developed over quite a long time. A number of people have been working on this. One of the things we found is that spill at low levels produces low levels of gas. When you reach a certain level, the system changes and the gas becomes lethal. I believe that fish have adapt- ed to situations in nature where they can handle the levels of gas below this critical level. In the Columbia River, we have the capac- ity to produce very large levels of gas. I believe our primary con- cern is to keep the levels lower. In a sense, it's like walking up a hill; you get a small benefit from spill for low levels of gas. You reach some cliff and if you go beyond that, then you have a real problem. There is a chance that we have gone beyond that this year. There are several observations that came out of this year's pro- gram. One is that we had high gas levels below Ice Harbor, up 130 percent of supersaturation. Another element is we had very high mortalities in pens and fish in pens below the dam up to 100 per- cent in some cases. In deep cages, they had 50 percent mortality. Another observation was we saw very few effects of the gas on the fish downstream. How can we explain the high cage studies with the few effects downstream. The model we have allows us to balance these things and interpret both of these in terms of a con- sistent story. With the model, I could represent the cage studies and show the movements of fish through the river system. With the model, we are able to get the same levels of cage mortality or pen mortality, and then we project downstream. What we find is a very small but negative impact of the spill which means that ac- cording to our work, we're probably not affecting fish very much with the current levels of spill. One reason is that the fish are deeper in the water. We assume they are at average depth at 30 feet in which case, you maybe lose in total survival through the system, 1 percent of the fish with the spill in the Snake River. What concerns me is if the fish are shallower in the water, such as 10 feet, as Mr. Mundy suggests they might be, then the amount of loss you get would go upwards of about 4 percent. The higher 12 the fish are in the water column, the more dangerous it becomes because the more they are being exposed to it. These model results tell us that we can explain both the cage studies and the impact on the fish. The fact that we are not seeing many results in the river, we're not seeing a lot of impact on the fish. Of course as Dr. Ebel points out, I believe one of the reasons we're also not seeing a large impact on the fish is because you don't see dead fish. Other things consume them. The net result of all this analysis is that we probably are not having much of an impact through the spill program. This is the conclusion that the Snake River Recovery Team has also come to. The important result from my concern is that I believe that our analysis to date might be underrepresenting the impacts of spill and we might actually have a much larger impact than we realize. That concludes my results. Senator Kempthorne. Dr. Anderson, thank you. Let me begin with some questions now. Mr. Fidler and Mr. Ebel, I appreciated your comments that you made at the opening. Let me ask you this. In many cases, under the Endangered Species Act we ask scientists like yourselves to provide the policymakers with the options. We also then ask the policymakers to make the best pos- sible decisions based upon what they've been provided by the sci- entists. My question is, how has this process worked for you? Has your science been considered fully, in your opinion, by the policy- makers; have you ever been asked to make any policy decisions? How is the process working and do you feel the science you've rec- ommended is being considered? Mr. Fidler. Both Wes and I were members of the NMFS expert panel on dissolved gas supersaturation. The panel came up with a variety of recommendations to assist NMFS in their decisionmak- ing. Unfortunately, many of the recommendations were not in- cluded in the Biological Monitoring Program. The final design of the 1995 Biological Monitoring Program was never submitted to the NMFS expert panel for review. As I said earlier, I believe if that had happened, many of the flaws in that program would have been identified and some corrections could have been made so that it would be a much more viable program. So there seems to be a disconnection between what scientists like myself suggest in such panels and the actual policy that is developed. Senator Kempthorne. ^y insight, Mr. Fidler, as to where that disconnect took place or what caused that? Mr. Fidler. I m not sure. It's verv apparent that has happened. I don't know that the problem really lies within organization like NMFS, or why they chose not to take advantage of the broad base of knowledge that is represented by those panels. I think if they had, we would have much better programs. Senator Kempthorne. I appreciate that. Mr. Ebel, your comment. Mr. Ebel. I think they have considered the research. I think the problem is the degree of emphasis that one bit has in relation to another bit of research and whether or not, for example, it's a good idea to spill x amount at Lower Granite or not to spill anvthing, and whether it is a good idea not to transport fish at all from McNary, for example. I think the agencies and NMFS have consid- 13 ered the information and they came up with conclusions that not all of the scientists agree with. I can't say that they haven't looked at the science. Senator Kempthorne. Mr. Bouck, I understand that you served on the NMFS Dissolve Gas Panel. Mr. BouCK. I did, but I'm not sure if I still do. Senator Kempthorne. What has been your experience on that panel? Mr. BouCK. I would have preferred that NMFS let us get orga- nized, and attack the problem as we see fit rather than give us parts of the problem to look at. I didn't attend the second meeting. NMFS kept putting it off and they finally just asked me when couldn't I attend and I said during elk season and I'll be darned if they didn't hold the meeting during elk season. I don't know if they were trying to tell me something or not but that's what hap- pened. So I can't say anything about the second one. Senator Kempthorne. So that goes back to your comment that you had made a series of recommendations and you felt that you were "not welcome" on the NMFS panel? Mr. BouCK. Yes. I offered to delay my elk hunting trip and you, coming from Idaho, know what a sacrifice that means. Senator Kempthorne. A lot of elk would have been happy with that. [Laughter.] Mr. BouCK. I have argued that these kinds of committee func- tions have to be open, they have to deal with the merits of the issue, that no scientist who is well-qualified and has peer-recog- nized expertise in the gas bubble disease issue should be excluded as NMFS has done. My opinion was apparently not too well taken but I think that we can do a lot better than we have done. Senator Kempthorne. You had referenced, Mr. Bouck, the idea of opening up the closed shop and providing for peer review, and Mr. Munay, you brought up peer review. I'd like to ask all mem- bers of this panel about peer review. As we think about the reau- thorization of the Endangered Species Act, changes that we may wish to incorporate, how can we get pragmatic so that the scientific community that is willing to serve and provide us science will feel that it is worth their time and effort and that there is meaningful peer review? Can you help us with the nuts and bolts? Mr. Mundy, let's start with you but again, I'd like to hear from all of you on this. Mr. Mundy. Senator, I serve on the peer review panel for the Exxon Valdez Oil Spill Trustee Council, which administers fish- eries research funding from a trust fund established as a result of the settlement in the Exxon Valdez oil spill. We have 10 years of funding and we get to spend about $100 million a year on salmon recovery in the Prince William Sound and Kodiak areas that were impacted by the Exxon Valdez oil spill. The peer review process has been around for some time now. In this past year, it's come together quite effectively. An analogous sit- uation occurs in the Columbia Basin, and this is what you re look- ing for in terms of nuts and bolts, because we have a pot of money that is established that comes out every year; we have Federal and State agencies who are primarily implementing the research with 14 some private entities involved. But unlike the Columbia Basin, we have a group of independent, privately-contracted peer reviewers and State and Federal agency studies cannot go forward unless they are certified by the peer review body. This doesn't mean that we tell State and Federal agencies what to do, not at all. We simply ensure that the science is the best that we can find; we ensure that the objectives of the research projects contribute to the established program measures for salmon recov- ery in the Exxon Valdez oil spill area. So this process, I think, has been very effective. It doesn't keep State and Federal agencies from functioning; we're not a drag or a bottleneck. We simply bring on more people if a bottleneck appears to get the job done. So I think that a peer review independent of the process that is now going on could very well benefit and give some direction be- cause there are some critical quantities that we should have had by now. We've been spending lots of money. I don't accept $400 mil- lion a year for research, I think that's a figment of somebody's imagination. We probably spend maybe $25 million in what I would call hardcore research projects out of all of that. Those are the ones that I relate to measuring the impact of the hydroelectric system on the juvenile salmon. I think we could focus that research program much better than we have and I think we could get a lot more for our money than we have with an independent peer review process. Senator Kempthorne. All right. Thank you very much. Mr. Anderson, your comments. Mr. Anderson. I think the peer review is essential. I also think it is very limited. The reason is because of the volume of informa- tion that we have to sift through. There was a peer review of the models a couple of years ago and it did not attain, in my opinion, all that it should have. Someone will come in, an outside scientist, and spend a week or 2 weeks reviewing information. They might end up understanding the basic elements of the system but to real- ly get into peer review, they would have to understand the data and all the intricacies of the data, which means the people who are actually doing the work. To do that, I thought of the idea of a jury panel where scientists doing the work would present their results in a more formal set- ting, and then have a jury of peers evaluate that. We, as individ- uals can point out the strengths and flaws in each other's work and then get those strengths and flaws evaluated by an outside group. It's a way to direct the peers to the essential parts. Right now, we don't have that ability. Senator Kempthorne. I may come back to you on that. Ms. Filardo, if you could give us your comments on this meaning- ful peer review? How do you make it work? Ms. Filardo. I would welcome change in the present process whereby programs are developed and implemented and funded. I think the overall region needs a change in what is presently going on, something of the magnitude that Phil is speaking to, the Exxon Vaidez peer review committee, elements that he referred to in that overall game plan and elements that Jim Anderson referred to in his game plan as well. 15 There is difficulty in finding an independent peer review group. Many people are established in the region and have some kind of gain in the region itself. If you take an independent peer review that has no resource management responsibilities, they look at something maybe completely different than a resource management agency with responsibilities would look at it. There may be a way to meld those two processes so you can have the best of both worlds, an independent peer review oversight team and then get- ting the input possibly from those people that are in the region who have something at stake in terms of resource management. Senator Kempthorne. We've heard from some of your colleagues that they were serving in a peer review capacity, they were on a panel, but that perhaps their science was not in keeping with per- haps where the policy was going and therefore, we had a dis- connect. Ms. FiLARDO. I'd like the opportunity to address that. I'm a tech- nical individual; I come at this from the perspective of monitoring programs and my role in the overall management. I have been in- volved in a committee that is presently co-chaired by the Environ- mental Protection Agency and by the National Marine Fisheries Service that has been set up to address the biological monitoring program. In developing our portion of the biological monitoring pro- gram, we took into consideration all the implementable information that had been given to us by the oversight team that NMFS con- vened last year. The biological monitoring group is co-chaired by EPA and Na- tional Marine Fisheries Service. The first couple of meetings were spent just looking at each of the individual elements that had been recommended for near-term implementation and for long-term studies. All of those were addressed to the best of our ability in the program for 1995. I think that the work of the panel has taken into consideration the overall development of the program. Senator Kempthorne. Thank you. Mr. Bouck, your views, please. How can we construct peer review so that it works? Mr. BouCK. That's a very interesting question. I've been involved in that for a very long time and I think there are plenty of models of how and how not to do peer review and project selection. My in- volvement in that sort of thing goes back to the old National Insti- tutes of Health and their research review system. In 1983, when I went to work in the Fish and Wildlife Division of the Bonneville Power Administration, I tried to implement a peer review system there, but it wasn't accepted by the fishery agencies. So I would say that one of the very first problems is to get acceptance by the peo- ple who are going to be judged. If they won't accept it, and if you're not operating in a context in which those peer judgments have to be addressed somehow or other, then you're wasting your time. Before I forget it, I'm talking about getting peer review and open- ing up this relatively closed fishery shop to the private sector and all, but I should point out that I don't have a conflict of interest. I'm not here trying to get money for myself because when I retired, I took the voluntary separation incentive and I can't contract with or work for the Government for another 5 years. So when I say I 16 really believe thev should open things up and get peer review, it's because that has been my experience for a very long time. I should mention a couple of other problems that I had over the years setting up peer review. First of all, you have to demand real qualifications to get real peers with real expertise; otherwise, re- view panels get loaded up with policymakers and other people who don't really have adequate qualifications. A second problem is that you can't operate this very long on vol- unteers. I can barely imagine how busy you are. We probably aren't as busy as you are, but let's suppose we sent you a proposal and said we'd like you to review it and get comments back to us by next Friday. You just can't operate a peer review system on a volunteer basis like that, unless there is some kind of compensation there. Third, and this addresses the second problem too, there has to be an air of open competition for at least part of the projects in order to stimulate interest in serving as peers, particularly by the university sector. The worse problem I had was trying to keep the university people interested and involved in a program in which they recognized that they didn't stand a chance of getting any of the money or projects. Senator Kempthorne. I'm going to continue this but this is all very helpful and I would invite any of you who, after this meeting on further reflection, just steps one through five, what have you, if you'd send those to me, it would be helpful because I appreciate this and it is helpful. Mr. Ebel. Mr. Ebel. I agree with just about everything that my colleagues said on the left here. I think one of the main difficulties is to find a peer group that is knowledgeable enough and unbiased without some kind of ax to grind to review these studies. Senator Kempthorne. Does that happen in the scientific commu- nity too? Mr. Ebel. You bet. The other thing that Margaret mentioned is that something different needs to be done in the way the North- west research proposals are handled. I agree with that but if some- thing new is done, let's, for Grod's sake, eliminate some of the stuff that is being done now; otherwise, you're never going to get a project off the ground. If you're going to have peer review, that should be it ana the proposal goes forward after that; let's not run it through nine more committees and State agencies. Senator Kempthorne. Good point. Mr. Fidler. Mr. FiDLER. I agree completely that there is a need for a review process. One of the difficulties I see is who establishes the people who make up the peer review panel, if you will. Is it the State and tribal agencies or NMFS? To me, this is like letting drug companies do their own clinical review and conduct their own clinical trials on new drugs. I think there needs to be some mechanism to allow truly independent input to the review process, independent review and participation. I think another problem is there needs to be some mechanism to force people to participate in the peer review. For example, on the second NMFS Dissolved Gas Expert Panel meeting, the State, trib- al agencies, along with the Fish Passage Center were invited to 17 participate in that. They all declined to participate. So there needs to be, as I say, some mechanism to force everyone to participate in this. I've often said to colleagues, if we all were faced with jail sen- tences for professional incompetence, we wouldn't be here today, we'd be all hunkered over a table working very closely together to come up with a solution. Senator Kempthorne. So you would like us to hold that out as an alternative? Mr. FiDLER. You may have to, given the situation as it is. [Laughter.] Senator Kempthorne. Mr. Fidler, you stated in your opening comments that the monitoring program seemed as though it were specifically designed to avoid finding gas bubble trauma. Could you please expand on that? Mr. Fidler. Sure. One of the central recommendations of the NMFS Dissolved Gas Expert Panel was that gill lamellae are the most sensitive indicators of pending signs of gas bubble trauma and that they should be the primary site that should be examined for signs of gas bubble trauma. In the 1995 Monitoring Program, gill lamellae were excluded from the exams. Senator KEMPTHORNE. Would you please define that? Mr. Fidler. The gill lamellae? Senator Kempthorne. Yes. Mr. Fidler. OK. Gill lamellae in fish are analogous to our lungs; that is, this is the way fish transport oxygen from the water into their vascular system and this is how they excrete things like CO2 and ammonia. This is, in fact, how they transport the supersaturated dissolved gases from the water into the vascular system where they can then form bubbles. The gill lamellae have always, based on information in the literature, been very sensitive. That is one of the first locations you will see bubbles formed in the fish above certain levels of total gas pressure. There are thresholds involved for all of these arrays of signs of gas bubble trauma. I mean thresholds in total gas pressure. They don't all occur at the same total gas pressure, so total gas pressure has to rise to certain levels before you see specific signs of gas bubble trauma. As I said, the 1994 Monitoring Program included the examina- tion of gill lamellae as a central component of that. As I mentioned in my testimony, a large number of bubbles were found in 1994. In fact, it was these bubbles that led to the termination of the spill program in 1994. Again, as I mentioned before, 90 to 100 power mi- croscopes were used in that examination in 1994. Now, the Na- tional Biological Service protocol for looking at bubbles in gill lamellae calls for 10 power magnification and not even the use of a microscope. So it baffies me why when you had a process in 1994 that worked very well, why you would then back off to something that cannot resolve as well as the 90 to 100 power magnification. Really, the use of 90 to 100 power microscopes, most high school biology classes utilize that kind of work in laboratories, so it's not some new technology or anything like that; it's a very common thing to do and very effective. 18 Senator Kempthorne. So let me see if I'm tracking with you. In the examination for the existence of bubbles, they would use 100 power magnification? Mr. FiDLER. Right. Senator Kempthorne. And in 1994? Mr. FiDLER. That was 1994. Senator Kempthorne. Yes. And in 1994, by utilizing that meth- od, you were able to come up with some meaningful data and yet in 1995, they went to a 10 power magnification which apparently does not allow you to see the existence of the bubbles? Mr. FiDLER. As I pointed out earlier, there's a very sharp con- trast between all of the data from 1994 compared to 1995. In 1995, we've got much higher dissolved gas levels than we had in 1994 where we saw signs of gas bubble trauma. Yet, in 1995, the pro- gram is reporting very few signs. The net pen studies below Ice Harbor in 1995 have shown dramatically higher levels of mortality than occurred in similar studies in 1994. As I said earlier, there just seems to be such a contrast in these results that one has to question the validity of the monitoring program. Senator Kempthorne. All right. I appreciate that very much. Ms. Filardo, I understand that it's common practice to have a test population — we just referenced that — and a controlled popu- lation when conducting an experiment or observing a particular phenomenon. What control did you use to compare the effects of spill on wild fish? Ms. Filardo. I'm unsure of the question. In the monitoring pro- gram, what you're looking at is fish that are run-of-the-river fish, including both hatchery and wild fish. In terms of experimentation that's done, I'd say the preponderance of the information that has been collected has been conducted on hatchery fish themselves. The monitoring itself is not a research program; it is to monitor the ex- tent of the signs of gas bubble trauma in the population. There isn't any specific test and control group in that. There are specific test and control groups that National Biological Service is conduct- ing under experiments they are subcontracting under the monitor- ing program. Senator Kempthorne. Thank you. Mr. Bouck, I'd like you've referenced the term, if I jotted this down right, referring to the National Marine Fisheries Service that there was an "iron curtain of isolation." Would you tell me what you mean by that? Again, we're not being personal; this is just be- tween you and me. [Laughter.] Mr. BouCK. Admittedly, it's kind of hard to accept not being one of the boys I guess, having watched some of these young folks like Mike Schiewe come up through the line, and now he has replaced Wes Ebel. But when this issue came up, I was called and asked by Cramer Associates to go out on the river and have a look at how things were going and report back to them. I thought that had some merit and of course I was very interested. I think gas bubble disease is a tremendously interesting biological phenomena and it also just happens to have some important ecological and environ- mental implications. 19 So I went out with and I helped the NMFS, who had two people to do the work of four people. I saw some serious shortcomings in their techniques and I told them so. Then my colleague did the same upriver at Ice Harbor Dam and the next thing we knew, NMFS was offended by this and a news release that a third party put out. Thereafter, we were not permitted to go back out with the NMFS crew, look at their fish, or help them. I asked if I could at least look at the fish when NMFS got through with them, because NMFS kills them all, and I said if you're going to throw them in the garbage, can I have them when you get through and NMFS said no. I asked, can I buy your garbage and NMFS said no. The NMFS employees said if I wanted to talk to them, I had to call a PR person in Seattle and make formal arrangements. You can't get anything done that way. Senator Kempthorne. What would you have done with those specimens? Mr. BoucK. I would like to have looked at them to see if I could see bubbles or other lesions that the NMFS's staff of non-biologists couldn't see. I was primarily interested in the wild resident fish. We have quite a trophy fishery for walleye and small-mouthed bass in the Lower Columbia River. I was able to get the cooperation of the Oregon Department of Fish and Wildlife crew who let me look at their fish. We were not able to get an ESA permit to collect nonsalmonid fish or look at fish. We had to have the cooperation of somebody who had a permit; the NMFS people had a permit, the National Biological Service people had a permit, and we wanted to look at their nonsalmonid fish to see if we could expand the infor- mation base on gas bubble disease and so forth. NMFS and NBS came up with a lot of reasons why we couldn't look at their fish but it all boiled down to the fact that they didn't want to cooperate. So that was the end of that. Senator Kempthorne. Were you invited by the National Marine Fisheries Service to participate in this? Mr. BouCK. No. I asked for permission and it was granted, then rescinded. I'm on their panel of gas experts, so I think that had something to do with it. I asked, "can I go out and have a look at the fish?" and NMFS said yes, but then they withdrew it and said no. Senator Kempthorne. So they would not allow you to look at these dead fish? Mr. BoucK. Not after the first time I went out there, no. This attitude immediately went to the National Biological Service and before we had a chance to go out with NBS, they let us know that they would not cooperate or allow us to look at any fish that they had looked at. Senator KEMPTHORNE. All right. I appreciate that. Mr. Anderson, your overall conclusions on the modeling and I guess the final point I'd like you to address is, is spill beneficial? Mr. Anderson. Our work suggests that spill is not beneficial. It's not beneficial to fish passing through the river and it's not bene- ficiad when you consiaer fish being transported, particularly when fish are being transported. Anytime you do not transport fish, you're losing some of the benefits of the transportation. 20 I'd also like to just follow up on this idea of bringing other infor- mation into the development of the ideas. The spill risk analysis that was performed, which is primarily the foundation for the spill, in that process they never considered or contacted us to do some runs, do some analysis with our model. We spent 7 years develop- ing the system which is designed to analyze the risk for different actions. It was a tremendous amount of work and it was not uti- lized in this process. Senator Kempthorne. So in other words, it took you 7 years to develop a model. Then did National Marine Fisheries Services uti- lize that model in their draft plan? Mr. Anderson. For the spill, they did not. Senator Kempthorne. Did they give any reason why they did not? Mr. Anderson. My feeling is there are alternative models, the models give different results, and they concluded to back off from model results because they have uncertainties and I think there is a difference between scientific uncertainty and ignorance. We need to really separate the two. Senator Kempthorne. Is this something too when we ask about a meaningful peer review process, all of us must feel that if we're contributing something, that it will be considered but here is a model that was done that took 7 years and not utilized. Is that one of the things that is perhaps a demoralizing factor to then step for- ward again as a scientist to offer your services? Mr. Anderson. It might be. In my case, it isn't. It just makes me want to bring this information out even more and try to get people to use our work and to understand it and criticize it so that we can improve it. Senator Kempthorne. All right. I want to thank all of you. I appreciate greatly the input that you've provided us. This is the sort of discussion that I wish we could just continue for some time. I would suggest that our commu- nication channels are open and as you have further thoughts on this issue, as well as the Endangered Species Act, I would welcome your input because I respect all of you that are here. With that, I would ask the next panel if it would come forward. We will take a brief 2-minute recess as we do that. [Recess.] Senator Kempthorne. Ladies and gentlemen, we will continue this hearing. I've been advised that at approximately 11:30 a.m., there will be a vote so what I'd like to do is we have three members of this panel that will be making opening comments and again, I would ask that you try to keep it to close to 5 minutes. Assuming we could get through the opening statements and they would then call for the vote, I would recess. 111 quickly run over and vote and be right back, and then we'll do our question part of this. With that, let me first introduce Mr. Will Stelle who is the Direc- tor of the Northwest Region, National Marine Fisheries Service, ac- companied by Michael Schiewe, Division Director, Coastal Zones. Mr. Stelle, if you'd like to proceed, please? 21 STATEMENT OF WILL STELLE, DIRECTOR, NORTHWEST RE- GION, NATIONAL MARINE FISHERIES SERVICE, ACCOM- PANIED BY MICHAEL SCHIEWE, DIVISION DIRECTOR, COAST- AL ZONE AND ESTUARINE STUDIES Mr, Stelle. Thank you, Mr, Chairman, and I appreciate the op- portunity to appear here today. I have a written statement which Fd like to submit to the sub- committee for its record. Senator Kempthorne. It will be made a part of the record. Mr. Stelle. I'd like to concentrate on several summary com- ments. First of all, the goal of the National Marine Fisheries Service in this effort is to develop a scientifically-sound and legally-defensible recovery effort for salmon. That is our touchstone, that will remain our touchstone, and we will adhere to it as we proceed. It's veir important for us to use that as our reference point throughout all of these proceedings. To the issue of spill, the issue of this morning's hearing, first, to echo an earlier witness, spill is not new. Spill has been occurring voluntarily and involuntarily in the basin for decades. To give you a brief summary of that history, the fish and wildlife program of the Northwest Power Planning Council, the 1982 program, em- braced voluntary spill at the Federal hydropower projects; there was a 1989 MOA between Bonneville and the State and tribal fish- ery agencies which again embraced and called for a spill program; the Federal Energy Regulatory Commission, in a set of proceedings both in the 1980's and as late as last year, ordered the mid-Colum- bia PUD projects, four of them, to institute a spill at their projects in order to pass fish safely around them. The States of Oregon, Washington, and Idaho, and the lower river tribes have rec- ommended to us the institution of a spill program and spill was called for at all downstream collector and noncollector projects by the 1994 amendments in the Salmon Strategy of the Northwest Power Planning Council. So the first point would be, spill is not a new thing by any means. The second point is that to understand the function of the spill program, one needs to reference the larger recovery effort that is directed at improving mainstem survivals. It's only in that larger effort that one can understand spill. As you well know, our objective is to identify the best method to improve survivals in the mainstem, period. As you know, Senator, there is a sharp disagreement within the region on how to do that. There are those who believe that the best technique for improving survivals is the transportation system where you collect juvenile smolts and you move tnem around the projects. The reason for that is fairly simple, it boils down to arithmetic in my view. It is that you've got eight mainstem dams through which these juveniles nave to pass on their way to the sea and those dams are not fish friendly. So the transportation system is based on the idea of let's pick them up and move them around them, not through them one by one. On the other hand, there are also those who feel very strongly that transportation is a failed policy and that the best way to pro- 22 ceed now is simply to put the fish back in the river and improve in-river conditions. This is the heart of the debate in the region. Our objective is to identify the best mix of mainstem passage measures to improve survivals, be it transportation or in-river mi- gration. Our method to achieve that objective is fairly simple. First, improve the transportation system through aggressive implementa- tion of quality control measures. What does that mean? It means simple things like don't put too many fish in the barges, take care of your water quality and temperatures, don't hold the young fish in the raceways too long. Simple things that we understand. Second, improve the in-river conditions for in-river migrants and then evaluate the results over time to see what provides the most benefit. It's in this context that the National Marine Fisheries Service has embraced a spill program at the downstream projects, both collector and noncollector, because it's part of the effort to im- prove in-river migration systems so that we can settle the larger debate on good science, the larger debate about whether or not we should continue reliance on a transportation system or junk the transportation system and move to complete reliance on in-river migration. If we don't do our best in testing out both alternatives, we will not be able to answer that question well and on a solid scientific basis and in a couple of years, we will be left with the flip of a coin as to which major option we choose to follow, including some major system reconfigurations and major drawdowns. So the function of the spill program is part of the larger, scientific evaluation of what works best. If we don't institute the spill program, we will not give fair credence to an effort to improve in-river migration. The third point is that the National Marine Fisheries Services, in consultation with the Corps of Engineers, the Bureau, Bonne- ville, Fish and Wildlife, NBS, and the State and tribal agencies in the region, has, in my view, designed and implemented a scientif- ically sound and biologically safe voluntary spill program. Dr. Schiewe is a principal architect of the biological monitoring component of that and if you have questions on how that was de- veloped, then I would encourage those questions. I think we have good answers. The next point, we are committed to continuing progress on im- proving this system through what is called an adaptive manage- ment approach. What that really means. Senator, is that we are committed to continuing to learn as we go and that we are conimit- ted to changing what we do as we learn. At the end of this migra- tion season, the National Marine Fisheries Service, together with her sister agencies and the States and tribes of the region, \vill sit down together and review the operations of this season— did the technical management team that ran the river do a good job; did it have adequate guidelines; can we improve that system; and if so, let's go ahead and improve it, preparing for next year. Let us also take a look at the spill parameters, the parameters governing the spill program. Do we have them right; are there ways we can improve them; and if there are, let's get on with it. We are absolutely open to continuing to make those improvements and we intend to do so. 23 Finally, I'd like to close by recognizing that this is not simply a Federal river and it is not simply a Federal issue. The States of the region and the tribes of the region have a substantial and di- rect interest in the way this system is operated and in the way we pursue our recovery effort for the listed salmon, the other anad- romous runs and the resident fish and wildlife of the basin. There- fore, it is our practice and our policy to bring people into our effort and to open it up with doors and windows so that all of the govern- ments of the region have a complete and full opportunity to partici- pate with us. To the issue of peer review, I would encourage additional ques- tions because I agree with much of what is being said and we are now negotiating with the Northwest Power Planning Council to de- velop a science board that can help us institute that much more co- herent, scientific approach to the larger basin issues. With that, I'd like to conclude, and again, I want to thank you for the opportunity to be here this morning. Senator Kempthorne. Mr. Stelle, thank you very much. Next, we have Colonel Bartholomew Bohn, Deputy Division Engi- neer, North Pacific Division, U.S. Army Corps of Engineers who is accompanied today by Doug Amdt, Senior Fish Program Planner, Department of Army. Colonel, if you would go ahead with your comments. STATEMENT OF COLONEL BARTHOLOMEW BOHN, DEPUTY DI- VISION ENGINEER, NORTH PACIFIC DIVISION, U.S. ARMY CORPS OF ENGINEERS, ACCOMPANIED BY DOUG ARNDT, SENIOR FISH PROGRAM PLANNER, DEPARTMENT OF THE ARMY Colonel Bohn. Mr. Chairman, I am Colonel Bart Bohn, the Dep- uty Commander, North Pacific Division, Corps of Engineers, and Doug Amdt is here joining me today from our Pacific Salmon Co- ordination Office. I represent our division commander, Major Gen- eral Ernest J. Harrell who is busily involved right now in prepar- ing for his upcoming retirement. Thank you for the opportunity to testify before the subcommittee today on an issue of great regional interest and of increasing na- tional interest. Mr. Chairman, I'd request I be allowed to summa- rize my testimony and provide a more complete version for the record. Northwest salmon stocks are in serious trouble. As you know, three species of Snake River salmon are now listed under the En- dangered Species Act. The Corps' eight hydroelectric dams in the lower Columbia and Snake Rivers are widely believed to be a ma^or factor in the decline in numbers of wild Snake River salmon stocks. We have sought and continue to seek solutions to the impacts of Federal dams. Originaliv, we built fish ladders into all of those Federal dams and those nsh ladders were designed to aid the adults in their re- turning to spawning grounds. Those fish ladders have worked very well. Now the issue is juvenile fish passage. Many improvements have been made to juvenile fish passage routes at the dams. There are a number of ways that juvenile fish pass through the dams — through the turbines, over the spillways. 24 through juvenile bypass facilities, and specially designed tanks for transport by barge or truck. Based upon juvenile passage studies, projects are operated to provide optimum passage conditions. Sur- vival numbers depend upon how many of the juvenile fish use each passage route and upon conditions they encounter. Turbine passage may disorient fish and allow predators to catch the fish. High lev- els of spill result in gas supersaturation levels that can cause gas bubble disease in fish. Under the Endangered Species Act, the Corps prepared a biologi- cal assessment of the effects on listed species of the planned oper- ation of Federal dams prior to the spring migration. Following con- sultations between the National Marine Fisheries Service and the Corps, NMFS issued a biological opinion. In its March 2 biological opinion for 1995 and future years, NMFS found that the Corps' planned operation of the Federal dams would jeopardize the contin- ued existence of the listed salmon. Accordingly, the biological opin- ion provided reasonable and prudent alternative measures to avoid jeopardy. On March 10, General Harrell, Division Engineer, signed a record of decision documenting the Corps' intent to fulfill the rec- ommended actions in the biological opinion. In its decision, the Corps has relied upon NMFS professional, scientific determination that the reasonable and prudent alternatives and measures will provide the necessary actions to halt and reverse the decline of the listed Snake River stocks. The biological opinion has called for a variety of actions and studies for salmon; flow augmentation, spills, juvenile transport, lowered reservoir levels, improvements to existing passage systems, and other actions are being implemented in the 1995 operating year. Future improvements and alternative configurations of the physical projects are being evaluated for the long term. One of these is the surface bypass system for juvenile fish. This is a new technology whereby the juvenile salmon are collected in the top 20 feet or so of the reservoirs where they usually migrate and are passed through or over the dams. In 1994, NMFS requested and the Corps implemented an emer- gency program of spilling at all eight lower Columbia and Snake River dams. This request went beyond the spill measures in the 1994 biological opinion. In 1995, the biological opinion again called for spill at eight dams, including the juvenile collector dams where a majority of juvenile fish would normally have been collected and transported. In its 1995 biological assessment, the Corps expressed concern about exceeding current State water quality standards. In a prior letter to Federal agencies, the States and other regional interests, General Harrell had indicated the Corps would attempt to adhere to the State water quality standards in operating its projects. For 1995, we asked NMFS to request those waivers and they did and we have received waivers from the States of Washington, Oregon, and Idaho. In consultation with NMFS, the agencies agreed to a well-mon- itored spill program, managed in near real time. The monitoring plan includes two components — physical monitoring which is being 25 conducted by the Corps of Engineers and biological monitoring being conducted by NMFS. Regarding research efforts, the Corps assures that evaluations which it funds on salmon passage at its projects are fully coordi- nated with regional entities and programs. It accomplishes this through an interagency technical review and oversight process called Anadromous Fish Evaluation Program. The Corps is working with NMFS to bring this research program into processes estab- lished under the Pacific Salmon Coordinating Committee, or the forum currently proposed by NMFS for implementing the recovery plan. A coordination team will continue to consult with Indian tribes. Federal and State fish agencies, the Power Planning Coun- cil, and other interested parties to assure that they have adequate opportunity to review and to provide recommendations throughout the development and implementation of Corps-funded studies. We will continue the annual study review meetings to provide prelimi- nary and final study reports to all interested parties. In conclusion, we have underway in the region a comprehensive and ambitious plan of measures and evaluations to improve sur- vival of the salmon at the Federal hydro projects. Because of the complex life cycle of the salmon and the many factors that influ- ence their survival, there is much uncertainty whether all of these actions will result in benefits to the fish. We must continue to learn from our actions and modify them as necessary. The NMFS Biologi- cal Opinion, proposed recovery plan, and our research process are intended to assure just that. Results from turbine efficiency studies, gas abatement studies, surface collection evaluations, among others, will be considered as we make future decisions. Spilling for juvenile fish is to provide interim protection for the juvenile fish until long-term protection measures can be imple- mented. Spill is considered to be a safe method of passing the fish as long as it is carefully monitored to control gas supersaturation. Mr. Chairman, that concludes my oral statement. I d be happy to answer any questions you might have. Senator Kempthorne. Colonel, thank you very much. I want to make a note on what you just said before we move on here. Now, let me turn to Mr. Ed Bowles, the Anadromous Fish Man- ager, Idaho Department of Fish and Game. STATEMENT OF ED BOWLES, ANADROMOUS FISH MANAGER, IDAHO DEPARTMENT OF FISH AND GAME Mr. Bowles. Gk)od morning, Senator Kempthorne. Thank you for the opportunity to testify on NMFS' spill policy which is an important plank in Northwest salmon and steelhead recovery efforts. Idaho Department of Fish and Game supports spillway passage of juvenile salmon smolts as they migrate over dams in the lower Snake and Columbia Rivers. Managed spill is a valuable and sci- entifically valid recovery tool. NMFS' spill policy reflects this fact. There are few on the scientific panel who were really in support of spill but I'd like to emphasize that this is not really representa- tive of the issue. All of the State and tribal salmon management 26 agencies in the Columbia Basin are in consensus on the use of spill as a valid tool. As you're well aware, it's hard to get that diverse group to agree on anything, and yet on this issue, there is consen- sus. This group has really only one common agenda that ties them together and that's to bring adult salmon back to their regions. Mr. Chairman, you have the pleasure of knowing firsthand that salmon and steelhead represent a tremendous heritage for the citi- zens of the Northwest. Snake River salmon once thrived by spawn- ing far inland in Idaho's mountainous headwaters and sending their progeny to the ocean on the wave of natural snowmelt each spring. This journey has been altered dramatically by dams and reservoirs located between Idaho and the ocean. This broken link in the salmon's ecosystem must be repaired for recovery to occur. Managed spill at mainstem dams on the lower Snake and Colum- bia Rivers is one of the best, most practical tools to repair this bro- ken link, A carefully managed spill program is essential, first, because it is the best way available to get smolts past the dams and second, it is the best way to spread the risk between smolts transported in barges and those allowed to migrate in the river. A good ques- tion might be why not just transport all the smolts and not worry about the river? Quite frankly, we've been trying to do that for 15 years and the decline to extinction continues. If the bottom line is to try to turn the comer, doesn't it make sense to not put all our eggs in the transportation basket and allow for some in-river mi- gration? I'd also like to point out that even under full transportation as it currently exists, it is impossible to transport all the fish. So, for that component that is in the river, we must do everything we can to make that river environment as friendly as possible to them. As you mentioned. Senator, there are three ways for these in- river, migrating smolts to pass the concrete. There is little dispute that managed spill provides the safest route for them to get past the dams and that going through the turbines is the worse route. Spill at mainstem dams is our best tool available to minimize this turbine route. I'd like to stress also that managing spill to reduce the turbine passage of these smolts requires no flow augmentation from upstream storage reservoirs. It simply reapportions existing water flowing past the dam. Spill at mainstem dams is a management tool with known bene- fits, risks and applications. These benefits and risks are not fraught with uncertainty requiring extensive research prior to im- plementation. Spill is not driven by bad science. In fact, the sci- entific basis for spill was recognized recently by a Federal Energy Regulatory Commission judge who rejected smolt transportation in favor of spill and in-river migration associated with two mid-Co- lumbia River dams. Just because spill has a scientific basis does not preclude the need for rigorous monitoring and evaluation. Adaptive manage- ment requires continued critical analysis of the spill program in order to maximize benefits, minimize risks and test our assump- tions. The NMFS spill policy embraces this need effectively. Gas bubble trauma in fish associated with spill is a risk taken very seriously. Fortunately, this risk can be effectively managed. 27 I'm not aware of any salmon management agency and tribe in the Columbia Basin that does not believe the benefits associated with a carefully controlled and carefully monitored spill program don't far outweigh potential risks from gas bubble trauma. NMFS' spill policy includes adequate provisions to adeptly man- age spill and minimize risk of gas bubble trauma. This does not mean we shouldn't take rigorous action to better control gas. Ice Harbor Dam is a pertinent example where risk of gas trauma could be substantially reduced if the Corps could install gas abatement devices and get their turbines back on line. Regarding the development of NMFS' spill policy, I think they did a good job this past year soliciting scientific information. From my perspective, this information helped formulate their spill policy, just as new information will help adjust that policy. After extensive input and debate, NMFS concluded that continued use of spillway passage is scientifically justified. State and tribal salmon manage- ment agencies concur. Although NMFS has allowed ample opportunities for public com- ment on the general merits of spill, it has not done all it should to include State and tribal fishery professionals in the day-to-day decisions that implement that program. As a result, I believe that the region missed some opportunities to improve salmon survival in 1995. Correcting this flaw is important. In conclusion, I believe existing knowledge supports spill as an important recoverv tool. It is currently the best way to spread the risk more equitably between transportation and in-river migration. It's the best way to minimize the number of in-river migrants pass- ing through turbines and it is the best way to get in-river migrants past the dams. I think one of the key questions today is not whether there are people who disagree with the continued use of spill, but rather, did N^flFS take into account all relevant evidence and make a decision to use spill that is supported by this information? In this case, it is clear that NMFS met this fundamental obligation. Can the NMFS spill program be improved? Absolutely, but that is the na- ture of adaptive management and something we should not be afraid of as we move forward in salmon recovery. Thanks once again. Chairman Kempthome, for this opportunity to testify. I hope my comments have been constructive. I have writ- ten comments that expand on this oral testimony. Senator Kempthorne. Thank you very much. Let me start with you since you just completed your testimony. You stated just a moment ago that all State agencies share consen- sus that spill is a valid program. Does vour testimony reflect the position of the Governor of the State of Idaho? Mr. Bowles. Essentially, my testimony represents the State and tribal salmon management agencies. These are the fisheries profes- sionals that are obligated and responsible for salmon recovery with- in the States and tribes. Senator KEMPTHORNE. Does the Gk)vemor concur with that? Mr. Bowles. In my opinion, yes. The Grovemor right now doesn't have his own personal salmon recovery plan that he has put forth but our department is working very closely with him, his staff and the Idaho representation on the Northwest Power Planning Council 28 with respect to this issue. As you're aware, the Grovemor just as- sumed office, kind of right in the hot seat of this winter's spill is- sues and is still, I think, coming to terms with the issue and all its complexity. One of the key planks that there seems to be strong support in is utilizing spill at the mainstem dams below Idaho's borders to help get the fish across those dams and to spread the risk more eq- uitably between transportation and in-river migration. Senator I'd also like to mention that the comments that I pre- pared for this testimony were reviewed by the Governor and his staff and his input was taken very much to heart. Senator Kempthorne. All right. Mr. Bowles, you state in your written testimony that, "A carefully managed spill program is es- sential to interim salmon recovery efforts." Based on the testimony from the first panel, do you consider this a "carefully managed pro- gram"? Mr. Bowles. I think that it is a very good face put forward, a very good step and one that is put forward in very good faith. I do think it can be improved on several fronts, but the primary concept and basis of the spill program and the policy that drives it is sound. As I mentioned, I think all of us, in dealing with issues day to day, have to deal with managing when we have uncertainty; we have to make decisions anyway and move forward. The salmon issue accentuates this management under uncertainty. I'd like to stress that this isn't just an experiment that we're doing to try to see what might work. The bottom line is we have fish that define the very nature of the Northwest that are about to go away. Steps have to be taken to stop that. Transportation can be an important, interim part of that, but it has not stopped the decline. Something else that also needs to be allowed is in-river passage, and spill to help those in-river migrating smolts is a part of that. Improving the program? Yes, I think we can do that. I think we have involvement to do that. It can be improved and I have written comments on some specifics, but the basis is there for a good program to continue. Senator KEMPTHORNE. Mr. Bowles, let me also ask you, were you troubled by the testimony that we heard today that this year's monitoring program is substandard and that last year's monitoring program wasn't initiated until after the spill program had begun? Mr. Bowles. I was troubled by that testimony perhaps from a different perspective than what you're asking. I personally have not been directly involved in the monitoring program in my position, but we have scientists within the department who are tracking it very closely and have participated in developing that monitoring program. The States and tribes were represented in developing that program. The monitoring program this year, I think, has done a very good job of responding adaptively to the issues and concerns that have been brought up, and there have been many. Some of them are is- sues that, over the course of the past year, tne scientific community that has been reviewing the spill policy and implementation have come to a conclusion, for example, on internal versus external sam- pling protocols for gas symptoms. They came to the conclusion that 29 external was more reliable than the internal and implemented that as their measure. When the issue came to a head in the Ice Harbor incident, I was very pleased with the responsiveness of NMFS and the monitoring program through the States and tribes to say, let's take a look at this and they implemented internal monitoring. Another issue came up where spill opponents said we're not finding the gas bub- bles in the fish through the monitoring program because we sam- pled them after they go through the bypass system. They said, if you sample them before they go through the bypass system, then you'll find the gas bubbles. The program adapted to that issue and that concern, which was a legitimate concern. Intertribal Fishery Commission biologists and the National Biological Service went out and addressed that concern and found that, for both internal and external examinations, there were no gas bubble problems with the fish before they went through the bypass. So I think the monitoring program has adequately assessed the risk to migrating smolts this year. Let me stress, migrating smolts, not necessarily smolts that are held in a cage for 4 days. The mi- grating smolts, I think, have done well this year. Senator Kempthorne. Thank you very much. I appreciate that. Mr. Stelle, did you hold your current position in the National Marine Fisheries Service during the spills that were mentioned in the testimony of the preceding panel? Mr. Stelle. Last year's spills, sir? Senator Kempthorne. Yes, 1994-95. Mr. Stelle. No, I didn't. I was appointed to my current position effective September 7, 1994. Senator Kempthorne. Were you the individual who made the de- cision to pursue a spill rate regime at the lower Snake and mainstem Columbia Dams this year? Mr. Stelle. Yes, sir, I was. Senator Kempthorne. As I understand it, last year, 1994, was the first time that the Federal Government decided to run an in- tentional spill program at the major dams on the Columbia and the lower Snake Rivers. That program was terminated within weeks after it began. Was that because monitoring results at different times showed gas bubble trauma in almost 100 percent of the fish that were tested? Mr. Stelle. Yes. A couple of clarifications on that. Senator. First of all, I believe it was the first time that we instituted a voluntary spill program at the collector projects but prior to that, we had been for quite a while spilling intentionally at noncollector projects. The program was pursued at the request of the States of Idaho, Or- egon and Washington and the lower river tribes. It was instituted, I believe, at the end of May and after a couple of weeks, because of repeated readings of elevated gas problems with the fish, we backed it down. Senator Kempthorne. Last year, the National Marine Fisheries Service testified before this subcommittee on the 1994 spill pro- gram. In that testimony. Dr. Nancy Foster with NMFS said that nitrogen levels were such that they were causing dsonage to both the species that you were trying to protect as well as to other spe- cies. Was Dr. Foster correct in that statement? 92-531 0-96-2 30 Mr. Stelle. I would guess so. Dr. Schiewe. Dr. Schiewe. Yes, those were the results we obtained last year. Senator Kempthorne. If her testimony then was correct, you must have some new data that justified initiating and expanding the spill program this year. In light of the testimony that we've just heard from the preceding panel, perhaps you would tell us what information you had that justified this year's spill? Mr. Stelle. That's a good question, Senator. A couple of major pieces of information. First of all, on the issue of whether or not spill per se is a preferable way to move young fish around individ- ual projects, I think there is a large body of information which an- swers that question in the affirmative. The question then turns on the issue of gas levels and what is an acceptable level of gas supersaturation to protect these young fish against gas problems. On that, we discussed the matter with the parties to the IDFG Marsh litigation; we also discussed it with the States and tribes extensively in the development of our biologi- cal opinion; and our Science Center, after reviewing all of the infor- mation, made a recommendation to me on what it believed was a safe level for purposes of gas supersaturation. It was that rec- ommendation which NMFS then sought to implement through ap- plications for gas waivers to the States of Washington, Oregon, Idaho and the Nez Perce Tribe. Those waivers were granted. Senator Kempthorne. How do you respond to some of the com- ments by some of the scientists who had been on your panel that they felt that their recommendations were not well received, per- haps not even received at all, the idea that it was isolation, that the monitoring program was designed so that it would not identify the gas bubble trauma? Mr. Stelle. If I may. Senator, may I turn it over to Dr. Schiewe as its chief architect? Senator Kempthorne. Sure, but then I'd like your input as well. Mr. Stelle. Of course. Dr. Schiewe. I would like to begin. Senator, with just a brief comment on the events of 1994. As Mr. Stelle has indicated, the spill program began in mid-May in a rather hasty, hurried fashion and the monitoring program had to be developed somewhat after the fact. We learned quite a bit from that and I believe we've incor- porated much of what we learned last year into what we've done this year. Senator Kempthorne. Dr. Schiewe, let me ask you this question, and I appreciate that. As you stated and this is consistent with what members of the National Marine Fisheries Service stated last year, it was after the fact, it was an experiment. How do we justify that when we're dealing with an endangered species? What was the science that drove you to do this when you had not had good re- sults on the spill in 1994? Dr. Schiewe. For this year, in the framework of developing the necessary information to operate and manage the hydropower sys- tem in future years in the best way and for the benefit of fish, we consider a spill to be an integral component of improving in-river conditions and allowing us to make a scientifically sound evalua- 31 tion of how we want to balance transportation with in-river move- ment of fish for the years to come. Senator Kempthorne. Mr. Stelle, would you like to comment? Mr. Stelle. Yes. I think, Senator, if I understand the thrust of your questions, it goes to the gas levels. Senator Kempthorne. Well, no, it goes to what the previous panel had stated, the number of scientists who said they lust felt that their scientific recommendations were ignored and that if it was contrary to the policy direction the National Marine Fisheries Service was going to take, there was a disconnect. Mr. Stelle. Senator, I think that is wrong, I think it's com- pletely wrong. Again, I'd defer to Dr. Schiewe in part because he ran those panels. I believe those panels were conducted in a credi- ble and scientifically sound manner and I believe that we listened and learned from it. There are a couple of specific issues that were raised this morn- ing and without getting into too much detail, there is a question of access to the monitoring program. Six weeks ago or so when the incident in Ice Harbor occurred, there was all sorts of what I would call a media frenzy on that subject and that frenzy ran the risk of substantially undercutting the quality of the monitoring effort. We couldn't have people and cameras crawling all over our monitoring boats looking over the people doing the monitoring and the re- search. Therefore, in order to avoid that and in order to protect the integrity of the monitoring program and to protect the safety of the people conducting the monitoring effort, we stipulated that any- body, any member of the public who wanted access to the monitor- ing effort need only call us and we would make arrangements for that access, but it had to be done in an orderly way both to protect the integrity of the monitoring program and the people doing it. There were some specific issues as well. Clearly not every rec- ommendation of every member of that panel was necessarily adopt- ed either by the overall panel or by the National Marine Fishenes Service. I think what we heard this morning was some of that. Senator KEMPTHORNE. Mr. Stelle, last year's testimony also talked about the National Marine Fisheries Service Spill Panel that was convened in the last few days of the 1994 spills. They rec- ommended that the river be managed to confine total dissolved gas levels to the existing 110 percent standard if we intend to protect fish from harm. Can you tell me if the National Marine Fisheries Service accepted that recommendation from the panel? Dr. Schiewe. Dr. Schiewe. We considered that as the basic cornerstone from where we would go with that entire adaptive management ap- proach to spill. The existing standards which were built upon the National Academy of Sciences' recommendations of 110 percent of saturation in the early 1970's have been adopted by all the States as well as the Federal Government. The panel's statement was very specifically that it was probably a good standard; going below that might afford greater protection; going above that would move in the direction of harm. We also evaluated the current literature that has been developed in the scientific arena since those early reports of the National Academy of Science and we looked very hard at the issue of depth 32 compensation which was raised by several of the members of the scientific panel and that is, as a fish moves deeper in the water col- umn, it, in essence, compensates hydrostatically for supersaturated gas levels. The equation is roughly 3 percent a foot. Therefore, if a fish is 10 feet below the surface, rather than being at 120 per- cent, they are effectively at 110 percent saturation, which is a safe level. Knowing that fish do not migrate solely in the top one foot of the water column, we were very comfortable in moving to a rec- ommendation for 115 percent. Senator Kempthorne. Let me ask you, Mr. Stelle, what peer re- view or public review and comment process did you go through be- fore making the policy decision to go ahead with the 1994 spill? Mr. Stelle. With last year's spill program, Senator? Senator Kempthorne. 1995, excuse me. Mr. Stelle. There were several processes. First, at the direction of the court, we engaged in a lengthy discussion with the parties to the Marsh litigation as it is so called, to discuss how the earlier plan of operations could be adjusted to better improve fish survival. During those discussions, the States of Oregon, Washington, and Idaho, and some of the environmental parties recommended spill as one of the recovery measures. At the same time, we developed a written draft biological opinion which we circulated to all of the parties and sought comments from them, both written comments and we had a number of meetings with them, and it was based on those meetings and those com- ments that we made a final decision that was reflected on the spill program per se. It was reflected in the March 2 Biological Opinion. At the same time but separately, our Science Center was review- ing the data from the 1994 spill program and had convened twice an expert gas panel to look at that spill program and to develop recommendations both on how to design a spill program and to de- sign an effective, reliable monitoring program. That as a peer-re- viewed— it wasn't a peer-reviewed exercise but it was basically a special panel of gas experts that helped us assemble that. So there was both the scientific side of it and then the policy side of it, and there was substantial participation from both. Senator KEMPTHORNE. In light of the previous panel's testimony, did you plan from the outset of this year's spill program to look for internal signs of gas bubble trauma in fish by looking for bubbles forming within the gills or did the National Marine Fisheries Serv- ice do so only after independent review of your proposal forced the National Marine Fisheries Service to do so? Mr. Stelle. I believe the answer is the latter but again, let me defer to Dr. Schiewe if I may. Senator Kempthorne. Dr. Schiewe. Dr. Schiewe. The examination of gill filaments or gill lamellae was indeed one of the components of the monitoring program rec- ommended by the peer panel. After the two peer panels, the Na- tional Msirine Fisheries Service, in conjunction with the Environ- mental Protection Agency, convened a panel of regional scientists that have dealt with this issue for many years and they basicallv scrubbed the growing monitoring program that had been drafted. There was great discussion over whether to include this internal 33 examination specifically because it required sacrificing fish, and in- deed, our goal is to save fish. It never quite became resolved in that particular forum and with- in 2 weeks or so of the beginning of the spill program, we asked the National Biological Service to go ahead and begin examining gill lamellae, gill filaments, in steelhead at three of the six loca- tions to get some idea of how important the monitoring of this site was to the program. Senator Kempthorne. Dr. Schiewe, what is the best way to find evidence of the gas bubble trauma and would you reference the 100 magnification versus the 10 power magnification, and in fact, was that a decision made and can you find the gas in the gills with a 10 power magnification? Dr. Schiewe. You can find it under both magnifications. It, of course, depends on the size of the emboli in the filament. This is another area which we are actively researching as we speak and attempt to develop more information, it's not quite as crisp as it was presented earlier. Last year, it was being done at 90X and we saw things and this year, we're doing it at lOX and we don't see things. An in-season inspection team last year, which included some out- side consultants as well as some National Marine Fisheries Service scientists, looked at the methods used last year and there was question whether the removal, excision of the gill and the examina- tion at the higher power was, in fact, introducing bubbles as an ar- tifact. This is what we're attempting to sort out now. If indeed the analysis validates that this is a concern, we will implement that in the monitoring program, the higher power magnification. Senator Kempthorne. So did I hear you correctly when you said that at 90X, you did see things; at lOX, you do not see things? Dr. Schiewe. No, I did not say that. Last vear, at 90X, they saw a higher prevalence of bubbles in the gill filaments than they are seeing this year at roughly lOX, but they are two different years. Senator I^mpthorne. But you saw more of it last year when you did use the 90X than you have this year using the lOX? Dr. Schiewe. Exactly. Senator Kempthorne. I understand that almost 100 percent of the fish sampled in last year's spill program had signs of gas bub- ble trauma; yet, this year, the National Marine Fisheries Service has failed to report signs of the trauma. Is it possible that NMFS has designed a program so that it is ignoring this gas bubble trau- ma situation? Dr. Schiewe. I would say that's not the case at all. Again, the prevalence of science last year was confounded by the possibility of the technique producing the bubbles as an artifact to tne examina- tion and I know of no instance last year. Certainly you cannot characterize the entire program last year as showing 100 percent prevalence of any sign. In select groups of fish at selected times at Bonneville Dam in hatchery-reared steelhead, I believe thev showed prevalences as high as 60 percent, but this is a very small part of the overall program. Senator Kempthorne. Mr. Stelle, after the fish kill was reported below Ice Harbor raising doubtp about the safety of the migrating fish, I cosigned a letter to Assistant Secretary of Commerce, Doug 34 Hall, with seven other Senators from the Northwest States that asked very clear questions about the spill program. To my knowl- edge, we've not yet received a response. Can you give me any in- sight on that? Mr. Stelle. Yes, Senator, I can. I think to coin a phrase, "the check is in the mail." I'm not quite sure where in the mail system it is. I know that the response has been prepared and it is quite detailed, sir. My apologies for the delay, that's my fault. Senator Kempthorne. On that note, National Marine Fisheries Service Director, Rollie Schmitten, promised the Senate Appropria- tions Committee a side-by-side comparison of the salmon recovery team recommendations with the National Marine Fisheries Service draft recovery plan. Do you know if that document has been com- pleted? Mr. Stelle. No, I don't. Senator, but I'm happy to check and if not, I will provide it to you. Senator Kempthorne. Again, we do not have a copy of that. [The document requested by Senator Kempthorne follows:] 35 Summary and Comparison of Regional Conservation Strategies For Columbia River Salmon July 1995 36 INTRODUCTION The following matrix summarizes and compares provisions of major regional conservation strategies for Columbia and Snake River salmon. The matrix includes specific recovery objectives for Sruike River salmon, and is organized into biological categories and major management activities. The references for this summary are as follows: NMFS Proposed Recovery Plan: The NMFS Plan as required under the Endangered Species Act. identifies specific recovery criteria and tasks to achieve these criteria. Recovery Team Recommendations: Snake River Salmon Recovery Team recommendations presented to NMFS (May 1994). 37 SUMMARY OF RECOVERY OBJECTIVES j NMFS Proposed Recovery Plan Recovery Team Recommendations Areas Necessary for Recovery Spring/Summer Chinook Fall Chinook Sockeyc Produaion above Hells Canyon not required for delisting. Salmon, Imnaha, Grande Ronde, Tucannon, Lochsa and Selway R. basins. Mainstem Snake River and Lower reaches of major tributaries below Hells Canyon Dam. At least 3 Stanley Basin Lakes and investigate feasibility of one lake outside Stanley Basin). Same as NMFS Plan pending further information concerning reestablishment of fall Chinook above Hells Canyon. Same as NMFS Plan Same as NMFS Plan Same as NMFS Plan Sockeye Abundance 8 year geometric mean of 1,000 naturally- produced sockeye in Redflsh Lake and 500 natural spawners in each of two other Stanley Basin Lakes. 1,000 naturally produced sockeye in Redfish Lake, and 500 natural spawners to a second Stanley Basin Lake over 8 years. Sockeye Productivity Natiu^ fish "cohort replacement rate". Must exceed 1 .0 for at least two generations. Same as NMFS Plan Spring/Summer Chinook Abundance 8 year geometric mean of 3 1 ,400 natural adults at LGR and 8 year geometric mean of at least 60% o f pre- 1971 brood year average redd counts for 80% of available index areas. Eight year geometric mean of 26,200 natural spring/summer chinook adults above Ice Harbor Dam. Spring/Summer Chinook Productivity Natural fish "cohort replacement rate". Must be greater than 1 .0 for eight years. Natural fish cohort replacement rate must exceed 2.0 for at least two generations. Fall Chinook Abundance 8 year geometric mean of at least 2,500 natural spawners in the mainstem Snake River annually. Annual escapement of at least 1000 natural spawners above Lower Granite Dam. Fall Chinook Productivity Natural fish cohort replacement rale must exceed 1 .0 for at least two generations. Natural fish cohort replacement rate must exceed 2.0 for at least two generations. Sockeye Slocks Redfish Lake Sockeye gene pool. However, in assessing demographics, each lake population should be considered relatively isolated Same as NMFS Plan Spring/Summer Chinook Stocks 39 separate populations; evaluate subset of these for delisting. (See spring/summer chinook abundance) Same as NMFS Plan Fall Chinook Stocks Single distinct population. Same as NMFS Plan 38 SUM^URY OF MAINSTEM AND ESTUARINE ECOSYSTEM PROVISIONS | NMFS Proposed Recovery Plan Recovery Team Recommendations Inriver Passage Approach for Yearling Migrants in the Snake River Actions for Yearling Migrants Year-round management by a Technical Management Team (TMT emphasized. TMT will call for required flows (see below), spill, and transportation based on juvenile and adult migration status, river conditions, and run-off expectations. Ensure most effeaive use of resources for spring and summer migrants and ensure sufficient reservoir refill probability. Evaluate the potential for flood control operations that provide additional storage volumes. Operate the hydrosystem year- round to meet flow objectives for anadromous fish. 4/10-6/20: 85-100 kefs When April-July runoff forecast for Lower Granite Dam is >16 MAF and <20 MAP. When the forecast is >20 MAF, average flow will be at least 100 kefs. Continue research to evaluate flow/survival relationship. Same as NMFS except calls for designated volumes (see below) Calls for managing the following volumes instead of a minimum river condition objective in low flow years (see NMFS Plan and NPPC Amendments). Total volume: 1.2 MAF w/outFC shift; 1.44 MAP w/FC shift. Seek access to additional volumes for augmentation. Inriver Passage Approach for Subyearling Migrants in the Snake River Actions for Subyearling Migrants Year-round management by TMT. The TMT will call for flows (see below), spill and transportation based on juvenile and adult migration status, inriver conditions, and run-off expectations. Ensure most effective use of resources for summer migrants and ensure sufficient reservoir refill probability. 50-55 kefs; when April-July runoff forecast for Lower Granite Dam is > 16 MAF and < 28 MAF. Average flow should be at least 55 kefs, when the forecast is >28 MAF. Implement temperature control measures when possible by releasing cool water from Dworshak in coordination with releases from Hells Canyon complex. Continue research to evaluate flow/survival relationship. Same as NMFS except will call for designated volumes (see below) Calls for managing the following volumes instead of a minimum river condition in low flows years (see NMFS Plan and NPPC Amendments). Total volume: .89 MAF. Plus a variable additional volume from operating Dworshak to lower elevations. 39 SUMMARY OF MAINSTEM AND ESTUARINE ECOSYSTEM PROVISIONS | NMFS Proposed Recovery Plan Recovery Team Recommendations Inriver Passage Year-round management by TMT. TMT Same as NMFS except will call for Approach for Yearling calls for flows (see below), spill, and designated volumes (see below). and Subyearling transportation based on juvenile and adult Migrants in the migration status, iruiver conditions, and Columbia River run-off expectations. Ensure most effective use of resources for spring and summer migrants, and sufficient reservoir refill probability (75-90%). Operate the hydrosystem year-round to Actions for Yearling meet flows for anadromous fish. Calls for managing the following Migrants volumes only instead of including a 4/20 - 6/30: 220-260 kefs when January- minimum river condition in low flow July forecast at the Dalles is >85 MAF and years (see >fMFS Plan and NPPC Amendments). 105 MAF average flow at McNary Dam should be al least 260 kefs. BPA and COE should obtain an additional 3.5 MAF of storage in Canadian reservoirs for augmenting flows. Continue to evaluate flow/survival relationship. T(?tal vplump: I.) 6.45 MAF to meet flow objectives, 2.) 7/1 -8/3 1:200 kefs a variable volume from operating Grand Coulee to lower elevations (up to 380 kaf), and 3.) obtain over five years an Actions for additional 1 MAF available annually. Subyearling Migrants Calls for managing the following volumes only instead of including a minimum river condition in low flow years (see NMFS Plan and NPPC Amendments). Total volume: Volumes to meet flow objeaives included under spring measures. Snake River Operate Snake River pools now within Not proposed. Drawdowns one foot of MOP. Complete necessary feasibility studies. By mid- 1996 decide on either spillway crest drawdown, natural river drawdown, or surface collection technology. By December 1998 complete engineering and design and implement by 2000. 40 SUMMARY OF MAINSTEM AND ESTUARINE ECOSYSTEM PROVISIONS NMFS Proposed Recovery Plan Recovery Team Recommendations John Day Drawdowns Operate within 3 feet of MOP from March-October. Operate at MOP permanently by 1996. Not recommended. Little or no short- term benefit since listed stocks are transported and anticipated benefits are too small to be measurable against environmental "noise." Additional Water Available Above Brownlee Dam BOR should secure an additional 427 kaf from the Upper Snake River in 1995-97. Draft Brownlee Reservoir to 2,069 feet in May, pass inflow, draft to 2,067 feet in July, pass inflow, and draft to 2,059 feet in August/September. Same as NMFS Plan Spill During April 10-June 20 in the Snake River, and April 20-June 30 in the Columbia River, spill at all projects, including collection projects, to achieve 80% FPE. Do not spill at Lower Granite Dam when unregulated weekly average flows < 100 kefs. When unregulated weekly average flows <85 kefs, do not spill at Lower Granite, Little Goose, or Lower Monumental dams. From June 21- August 3 1 in the Snake River and July 1- August 3 1 in the Columbia River spill at all noncollector projects to achieve 80% FPE. Reduce spill when 12 hour TDG >1 15% in dam forebays and > 120% in dam tailraces. Reduce spill when instantaneous TDG>I25% anywhere for 2 hours. 1. Evaluate spill as an alternative passage route. 2. Do not exceed 120% TDG. 3. Do not spill at collector projects (Lower Granite, Little Goose and Lower Monumental). Predator Control Contmue squawfish removal and evaluate means to more effectively remove them. Evaluate avian predation and, if necessary, expand avian control measures. More effeaively remove squawfish and liberalize bag limits on non indigenous fish to reduce predator abundance. Achieve 50% reduction in predation within 5 years and 75% in 10 years. Develop method to directly measure salmon survival improvement Juvenile Fish Transportation Transport all fish collected at Snake River collector projects. Do not transport spring migrants collected at McNary Dam. This operation is expected to result in between 56% and 74% of spring migrants being transported. Improve transportation efficiency through increased number of barges, changing release sites, improved collection and bypass facilities, etc. Similar to NMFS Plan. Transport majority of juvenile migrants, with particular care to facilitate inriver passage and transportation studies. Reduce transportation only if river conditions are clearly favorable for inriver passage. Upstream Collector at Lewiston Not proposed. Conduct design competition and construct if feasible and if transportation is determined to be a long term recovery action. Structural Improvements Modify stilling basins and spillways at Ice Harbor and John Day Dams based on gas abatement evaluations in 1995 and 1996 to reduce TDG. Immediately begin modification of the Wanapum Dam stilling basin to reduce TDG. Same as NMFS Plan 41 SUM.NURY OF NUINSTEM AND ESTUARINE ECOSYSTEM PROVISIONS Surface Collectors Diversion Screens Marine Mammal Management NMFS Proposed Recovery Plan Evaluate feasibility. Design and test prototype beginning in 1995. Require that diversions be screened to meet or exceed NMFS criteria by December 1996. Diversions that do not meet this requirement should be closed when juvenile salmonids are present Determine how pirmiped abundances/distribution correlates with migration; implement non-lethal removal measures dependent on study. Recovery Team Recommendations Same as NMFS Plan Same as NMFS Plan Develop protocol of rationale and procedures for reducing marine mammal predation on salmon; implementation pending demonstrable urgency and legal basis. 42 SUM^URY OF HARVEST PROVISIONS NMFS Proposed Recovery Plan Recovery Team Recommendations Non Treaty Leaseback/Buyback of Fishing Capacity Reduce harvest capacity of ocean troll fishery by 50% by 2002. Same as NMFS. Alaskan Fall Chinook Harvest Rate Canadian fall Chinook Fisheries Provide harvest rate schedule for terminal fisheries tied to specific biological criteria and management of ocean fisheries (see below). Implement abundance based approach for management of PSC fisheries to rebuild coastwide natural stocks and achieve escapement goals established by PSC in 1984. Total harvest rate (ocean and river) less than 50%. Establish harvest rates for all fisheries to minimize incidental take. Not specified. Included in 50% rate. PFMC Fall Chinook Fisheries Not specified. Included in 50% rate. Inriver Non Treaty Fall Chinook Fisheries Inriver Treaty Fall Chinook Fishery The incidental take of listed fall chinook should be limited using a harvest rate schedule tied to Snake River Fall chinook escapement and R/S rate and, secondarily, upriver fail chinook abundance. The minimum harvest rate represents a 61% reduction inriver harvest relative to the previous ten years. Not specified. Included in 50% rate. All live release capable gear by 2002. Included in 50% rate. All live release capable gear by 2002. Inriver Treaty and Non Treaty Commercial and Recreational Sockeye Harvest No commercial fishery below confluence of Snake and Columbia. Ceremonial and Subsistence Sockeye Fishery No commercial fisheries below confluence of Snake and Columbia rivers. Non-treaty limited to 1% incidental take. Treaty limited to 5% total, C&S and incidental rate, until substantial recovery occurs. Request the release of marked Snake river sockeye and request reduced take of all sockeye from current levels. Non Treaty Columbia River Commercial Gillnetting Phase out use of gillnets in the lower Columbia River by 2002. Only approved live capture gear allowed. Same as NMFS Alternative Fishing Methods Evaluate potential for size selective gear. Support development and implementation of selective fishery options and terminal fisheries opportimities. Same as NMFS Columbia River Fisheries Management Plan (CRFMP) Modify CRFMP to explicitly provide for the conservationof Snake River salmon. (See species specific recommendations.) Same as NMFS 1% harvest rale (HR) limit for nontreaty incidental impacts and 5% HR limit for treaty C&S and incidental impacts. Inriver Spring Chinook Harvest Hold to current levels (10-12%). 43 SUMMARY OF HARVEST PROVISIONS | NMFS Proposed Recovery Plan Recovery Team Recommendations Inriver Summer Chinook Harvest 1% HR limit for nontreaty incidental impacts and 3% HR limit for treaty C&S and incidental impacts. None Specified 44 SUMMARY OF ARTIFICIAL PROPAGATION PROVISIONS | NMFS Proposed Recovery Plan Recovery Team Recommendations Hatchery Management Develop specific hatchery management plans to address productioa, harvest, genetic, disease, and research/monitoring/evaluation issues for salmon subject to supplementation, captive broodstock or mitigation production. Same as NMFS Plan Natural Production Natural populations are first priority. Only natural component of listed populations used in delisting thresholds. Preserving stock structure to maximize probability of sustained recovery is the primary objective. Same as NMFS Plan Improved Hatchery Practices Modify Columbia River salmonid hatchery operations to improve fish quality and monitor those results. Same as NMFS Plan Use of Supplementation Further research is needed to determine role of supplementation. In interim, support existing efforts and new programs necessary to preserve remnant populations until measures focused on impediments to recovery take effect. Use indigenous stock. Avoid supplementation where significant risks of genetic/ecological degradation affecting indigenous stocks. Same as NMFS Plan Use of Captive Broodstock Continue for sockeye. Initiate for spring/summer Chinook salmon populations at greatest risk of extinction. Use to preserve stock structure. Conduct further research to improve techniques and determine potential. Same as NMFS except initiate fall Chinook captive broodstock program also. Increased Production or New Facilities Columbia Basin hatchery production limited to 1994 levels. Only propagation to support recovery may be expanded. Find/Retrofit, etc. hatchery facilities for extended captive broodstock efforts. Same as NMFS Plan Transplants from other Watersheds Preclude unless to recolonize vacant habitats to recover natural populations. Use stocks most similar to indigenous stock. Same as NMFS Plan 10 45 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS NMFS ProposecJ Recovery Plan Recovery Team Recommendations Habitat Management Authority Habitat subcommittee to advise the Salmon Recovery steering committee which advises, NMFS on the most scientifically based policies, actions and decisions. Membership solicited from states, tnbes, academics, private sector, etc. based on technical qualifications. Same as NMFS Plan Goals and Performance Standards Basin-wide ecological goals established. Federal Lands; Ripanan management objectives (RMOs) modified from PACFISH (see below); may be modified following watershed analysis and section 7 consultation. Until long-term ecosystem management plan developed, 1) designate, and protect riparian habitat conservation areas (RHCAs) from degradation; 2) provide for a network of Priority Watersheds containing best remaining and readily restorable habitat; and 3) minimize risk to Priority Watersheds. Similar to NMFS Plan except calls for a moratorium on resource exploitation which imposes risks of measurable habitat degradation. Habitat Status Assessment NMFS should Identify Priority Watersheds. Compile a comprehensive inventory and summary of historic and present habitat quality and quantity. Assessments will provide baseline information for delisting decisions, identify areas needing immediate protection and improvement, and determine production potential to assess progress towards recovery. Determine instream flow needs and inventory hydropower facilities, push-up berms, water intakes, and water diversion screening. Similar to NMFS Plan Subbasin Management (1) Develop long-term ecosystem management plan through the two proposed EISs for upper Columbia River Basin, Eastern WA & OR; (2) develop Snake River subbasin/watershed conservation and management plans, based on regional/local planning processes involving public and private sectors. Similar to NMFS Plan Water Diversion Screening Accelerate screening of all diversions in critical habitat to meet or exceed NMFS criteria. Complete screening in Washington by 1995, in Oregon by 1996, and in Idaho by 2002 (prioritize diversions by ttveat to salmon). Screen ail pump diversions in critical habitat by October 1998. NMFS and NPPC should develop a plan to involve state and Federal agencies in funding screens by October 1995. Through the FSOC, identify innovative alternatives to traditional screening. Screen diversions in tnbutary stream with up-to-date equipment as soon as possible. Screen water intakes in the Lower Columbia River and its estuary (e.g. paper mills in Longview, WA) as needed to ensure harm to salmon is minimized. Resident Trout Program Work with state managers to release trout in areas where interactions with listed salmon can be avoided, and terminate introductions into pnmary chinook spawning and nursery areas. Similar to NMFS Plan Steelhead Program Construct acclimation facilities to minimize interactions with natural salmon. Steelhead smolts should be l70-220mm total length at release. Similar to NMFS Plan 11 46 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS || NMFS Proposed Recovery Plan Recovery Team Recommendations Water Quality The EPA should: (1) Strongly encourage states to develop and enforce non-point source pollution control mechanisms; (2) determine the extent of the effects resulting from the mixing/dilution zones allowed in current water quality regulations for municipal/corporate discharges; (3) in conjunction with state agencies, review water quality standards, compliance, and adequacy of enforcement for Idaho, Washington, and Oregon; and, (4) if necessary, make recommendations for changes to the appropriate state. Similar to NMFS Plan Water Quantity State/Federal/tribes: Determine instream flow needs for all salmon life stages. Use available authorities to obtain any necessary increases in stream flows during low flow periods. Identify other needed authorities and seek legislative approval. Work to continue the Conservation Reserve Program. State/Federal/tribes/local: Inventory water withdrawals and assess effects on fish passage/entrainment, and achievement of minimum flows by October 1996. Develop plans for combining withdrawal sites, removing withdrawal structures from rivers, enforcing withdrawal amounts, and maintaining minimum stream flows and passage routes. Federal/state: Develop incentives to encourage irrigators to modify techniques and repair/update water delivery systems. Develop outreach and education programs. States: Extend moraloria on issuing water rights and implementing unperfected rights. Ensure headgates installed and flows measured. Similar to NMFS Plan Lake Fertilization for Sockeye Fertilize Stanley Basin Lakes to improve sockeye productivity beginning in 1995. Same as NMFS Plan Watershefi Restoration USPS and BLM should pnoritize watershed restoration funding as soon as possible. Restoration activities should initially focus on Priority Watersheds with high restoration potential. Where possible. Priority Watershed restoration plans should be developed within the context of broader area plans (subbasin. Forest, etc.). Give special emphasis to multi-agency restoration plans. Restoration in RHCAs and stream channels (such as adding large woody debris) should be only be undertaken if the cause of habitat degradation (e.g., riparian logging) is changed. Similar to NMFS Plan 12 47 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS || NMFS Proposed Recovery Plan Recovery Team Recomtnendations Riparian Areas Ripanan Habitai Conservation Areas (RHCAs) Fish-bearine streams: two site-ootential tree heights, or 300 f^ slope distance, or edge of 100- yr floodplain, or outer edge of riparian vegetation, or top of inner gorge, whichever is greater. Perennial, non-fish bearine streams: one site- potential tree height, or 1 50 ft slope distance, or edge of 100-yr floodplain, or outer edge of riparian vegetation, or top of inner gorge, whichever is greater. Intermittent streams: one site-ootential tree height, or 100 ft slope distance, or outer edge or riparian vegetation, whichever is greater (NMFS' plan extends into Clearwater Basin except N. Fork above Dworshak Dam). Ponds/lakes/reservoirs and wetlands> 1 acre: one site-potential tree height, or 150 ft slope distance, or extent of moderately and highly unstable areas, whichever is greater. Ripanan Reserves as in FEMAT - Similar to NMFS Plan in size, but fewer activities permitted. Restrictions in riparian areas In Priority Watersheds, actions that exceed a de minimis risk of adverse effects to listed salmon and critical habitat (De minimis is defined as very small, or of little significance.) Examples are given for silvicultural activities and mining. No specific restrictions, although FEMATs recommendation to only allow timber thiiming and salvage where needed to attain riparian management objectives is implied by accepting FEMAT Riparian Reserves. Roads In Prionty Watersheds: Where road density is greater than 2 miles/square mile, the USPS and BLM should reduce road mileage and emphasize road closure, obliteration, and revegetation. After watershed analysis, new road building and road widening should only proceed in RHCAs if there is no more thanade minimis risk of adversely affening salmon or not attaining Ecological Goals and RMOs. The fimctions roadless areas fulfill in meeting the Ecological Goals and RMOs in Priori*y Watersheds should be careftilly descnbed by the USPS and BLM and evaluated by NMFS prior to proposing new actions in these areas. Road Management Plans and Transportation Management Plans required by PACFISH should be completed and implemented as soon as possible. The status of these plans, schedules for their completion, and the effects of not completing these plans should be analyzed and described in the ecosystem management EISs. Notes problems with riparian roads. Recommends decommissioning of roads not needed for fire control. 13 48 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS NMFS Proposed Recovery Plan Recovery Tearti Recommendations | Riparian Grazing All watersheds: To prevent harassment of spawning salmon and damage to spawning substrate and redds, the USPS and BLM should eliminate or adequately restrict stream access (by livestock, off-road vehicles, anglers, etc.) during spawning and incubation periods. Expand outreach and education programs, in cooperation with state agencies, that promote awareness of the need to protect spawning fish and redds. Similar to NMPS Plan Timber Harvest In Priority Watersheds, the USPS and BLM should not propose any salvage or silvicultural activities within RHCAs that pose more than a de minimis risk of adversely affecting listed salmon or their critical habitat, unless both watershed and site-specific analyses show the action will avoid adverse effects and will not retard or prevent attainment of ecological goals and RMOs. Similar to NMFS Plan Irrigated Agriculture (See Water Diversion Screening) Similar to NMPS Plan Mining In Priority Watersheds, the USPS and BLM should use the full extent of their authorities to ensure that new mines are located outside of the RHCAs. There may be some exceptions for activities with ade minimis risk of adverse effects. Outside RHCAs in Priority Watersheds, the USPS and BLM should complete watershed analysis prior to deciding whether to approve plans of operation for mining activities that are likely to adversely affect listed salmon, designated critical habitat, or the ecological processes and functions. Based on results of the watershed analysis, the USPS and BLM should adjust proposed plans of operation or, if necessary, prohibit mining operations. Watershed analysis may not be necessary for mineral activities with de minimis risk of adverse effects. Outside Priority Watersheds, the USPS and BLM should work with the EPA, COE, and state water quality agencies to ensure that draft plans of operation for new mines that have the potential to produce acid rock drainage are conditioned so that the mines will not adversely affect groundwater or surface water quality. Similar to NMPS Plan Toxic Chemical Transport All watersheds: the USPS and BLM should minimize risk of toxic fuel spills during transport through RHCAs by using alternate routes where feasible, and taking all other possible precautions. Similar to NMFS Plan Recreation Management See riparian grazing. Similar to NMFS Plan Water Conveyance USPS and BLM should ensure that water conveyance intakes with the potential to trap or impinge listed salmon meet NMPS' established intake screening criteria before use is approved and that permits would be authorized or re- authorized only If streamflows are adequate to prevent adverse effects on listed salmon. None 14 49 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS NMFS Proposed Recovery Plan Recovery Team Recommendations Sediment Delivery Objective None None Fine Sediment Objective Limit to <20% in spawning habitat of Priority Watersheds. None Cobble Embeddedness Objective Optional alternative to fine sediment: Limit to <30% in rearing habitat of Priority Watersheds. None Pool Objective Adopts PACFISH standard (varies with channel width) Protect pools by protecting streambanks and riparian areas. Sircambank Stability In Priority Watersheds, 90% (non-forested systems only) Protect from breakdown. Width/Depth Ratio <10; stratify by channel type None Water Temperature Adopts PACFISH standard (<60F in spawning habitat, <64F in reanng habitat). Temperatures should benefit salmon (no numeric standard) Large Woody Debris Adopts PACFISH standard (20 pieces/mile) None Stream Morphology None None Fire Suppression In Priority Watersheds: By June I , each year before each fire season, the USPS and BLM should submit to NMFS an outline that they will use to brief Fire Overhead Teams regarding ESA-based responsibilities for protecting salmon habitat Following a fire that affects RHCAs in watersheds with designated critical habitat, the USPS and BLM should review suppression and rehabilitation efforts and determine if revegetation and rehabilitation of the burned area were effective. Reports on these reviews should be submitted to NMFS for review within 15 months following fire containment None 15 50 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS NMFS Proposed Recovery Plan Recovery Team Recommendations Long-term Determine of levels of resource use which have Same as short-term plan approaches for a high probability of maintaining high quality ecosystem habitat, restoring degraded habitat, and restoring management Federal connectivity between high quality habitats. lands Consider and refine criteria for prioritizing restoration actions among watersheds. The following steps may be necessary: a. Describe the range of historic conditions and disturbance regimes; b. Describe desired future conditions; c. Refme the delineation of important areas of biological diversity within watersheds; d. Adjust land allocations and outputs of goods and services from Federal lands to reflect the ecological requirements of listed salmon; e. Develop a monitoring program that will: document subbasin-scale trends in habitat quality and quantity, and fish populations; monitor and evaluate reference watersheds and other, more actively monitored watersheds to determine if watershed restoration and management programs are meeting habitat objectives; f. Coordinate with Federal/state/tribal/local governments and private landowners to develop long-term subbasin habitat management plans; g. Establish as one of the purposes of the EISs that all LRMPs and LUPs should promote the survival and recovery of listed salmon. 16 51 SUMMARY OF TRIBUTARY ECOSYSTEM PROVISIONS NMFS Proposed Recovery Plan Recovery Team Recommendations Monitoring and Evaluation The PAC FISH monitoring commillee should oversee experimental design, data collection, quality control, analysis methodologies, and reporting. Include: Implementation monitoring and reporting for all actions that may affect listed salmon or their designated critical habitat: effectiveness monitoring and reporting annually for groups of actions (by activity type, time, and subwatershed or watershed) that may affect listed salmon: permanent photo- monitoring plots: and plan and begin validation monitoring to determine whether the assumptions used informing the aquatic ecosystem strategy described in this Recovery Plan are valid. NMFS, the USFS. and the BLM should establish a monitoring quality control team to conduct and oversee random spot checks of the implementation of P AC FISH and guidelines from the USFS Land and Resource Management Plans (LRMPs), NMFS' March I, 1995 Biological Opinion on the LRMPs, and BLM Land Use Plans. The USFS and BLM, in coordination with the Habitat Committee and the ICBEMP. should identify and protect enough pristine or relatively pristine, well-studied watersheds as 'reference areas" against which the effects of restoration and land management projects can be measured (may require 10-15 watersheds). Similar to NMFS Plan 17 ,)\ 52 Senator Kempthorne. At a hearing I attended last year, Septem- ber 9, 1994, the National Marine Fisheries committed to providing a foUowup report on the results of last year's spill program. Do you know if tnat document has been completed? Mr. Stelle. No, sir, I don't. Senator Kempthorne. Again, I do not have a copy of that. [The document requested by Senator Kempthorne follows:] 53 RQviev of the National Marina Fisheries service 1994 supplemental Spring Spill Program Background Prior to May 10, 1994, the standard spill scenario for the Lower Snake and Columbia River dams was according to the National Marine Fisheries Service's (NMFS) 1994-98 Federal Columbia River Power System Biological Opinion which was issued on March 16, 1994 as a result of Endangered Species Act, Section 7 consultation on hydropower system operation. Briefly, the Biological Opinion states that spring spill shall occur at three dams at the following rates: Ice Harbor - 25 kefs for 12 hours. The Dalles - 10% of project flow for 24 hours, and Bonneville - 50% of project flow for 24 hours. On May 9, 1994 the National Marine Fisheries Service requested that the U.S. Army Corps of Engineers (COE) emd Bonneville Power Administration (BPA) , at the esurliest opportunity, implement an emergency spill program at all Federally-operated dams on the lower Snake and lower Columbia rivers. • This action was deemed necessary to improve survival of spring outmigrating juvenile salmonids and was developed by the technical staff of the U.S. Fish and Wildlife Service and National Marine Fisheries Service and with technical input from regional State and Tribal fishery agencies. This operation began at 24 00 hours on May 10 emd consisted of an increase or initiation of spill at all eight Federally operated dams on the lower Snake and Columbia rivers to a level necessary to pass 80 percent of the juvenile outmigrants through non-turbine routes (80% FPE) but not to exceed 120% total dissolved gas saturation. Water Quality Standards Discussions began January 13, 1994, between NMFS the Environmental Protection Agency (EPA) , Oregon Department of Environmental Quality (ODEQ) , and Washington Department of Ecology (WDOE) regarding the 110% total dissolved gas (TDG) standard. On May 10, a letter was sent by NMFS to WDOE requesting a short-term modification of the standard. Since the ODEQ had no provision for a modification, a letter was sent by NMFS to the Governor of Oregon recpaesting assistance in obtaining a variance from the ODEQ Commission to manage gas levels above the state standard (letters were also sent to the Governors of Washington and Idaho asking assistance with their water quality standards) . The ODEQ Commission held a public meeting on May 16 to hear justification for exceeding the water quality standards and, on May 17 , ' issued a Temporary Rule allowing exceedance through June 20, 1994. The WDOE issued an executive order to allow a one week exceedance of the 110% standard on May 10 and a short-term 54 modification to NMFS on May 18, 1994, which extended the exceedance period through June 20, 1994. Both agencies stipulated that TDG levels should not exceed 120% on a 12 hour average at any location in the rivers. Spill Management Spill' was managed by NMFS through weekly meetings with all the affected agencies. Every Thursday, technical meetings were held to review the biological and physical monitoring data and every Friday in-season management meetings were held to request necessary changes in spill levels. On May 27, as a precautionary measure due to uncertainty about risks associated with the high prevalence of interior signs of gas bubble disease (GBD) , NMFS requested that the spill levels be reduced by one third. Subsequently, the director of the ODEQ issued an order for a reduction of the allowable gas level in the Columbia River to 110% TDG, with instantaneous values not to exceed 115* TDG. No other reductions in spill or TDG were made until June 15 when NMFS made the determination that continued spill was unveirranted in the lower Snake River because 95% of' the spring migration of juvenile threatened and endangered salmon had passed these dams. At this time, voluntary spill was ended at Lower Granite, Little Goose, and Lower Monumental dams and cut in half (from 24 hours per day to 12 hours per day) at Ice Heirbor Dam. On June 17, NMFS . terminated voluntary spill at McNary Dam in response to migration status and concern for fish survival under projected low flow conditions in the lower Colximbia River. The Monitoring Effort A biological and dissolved gas monitoring program was developed by the NMFS amd forwarded to the state water quality agencies on May 20, 1994. An updated version was sent to the ODEQ and WDOE on June 21 which included all revisions made during the spring spill season. In summary, the monitoring plan included: (l) daily external assessment of juvenile in-river migrant condition at five smolt monitoring facilities, four fish guidance efficiency research projects, and two river reach locations; (2) every other day internal assessment of 30 juvenile hatchery steelhead at each of the five smolt monitoring locations; (3) juvenile net pen studies in two das tailraces; (4) periodic monitoring of adult migrant condition at three lower Snake and lover Columbia river dams; and (5) gas supersaturation monitoring at 23 lower Snake and lower Columbia River sites. The results of the monitoring effort were reported daily to a vide distribution list and posted on two electronic bulletin boards by the Fish Passage Center. NMFS also issued a daily monitoring report, primarily to Federal fishery and hydropower management agency personnel. On each Thursday, the NMFS report included a memo containing interpretation of the biological data 55 for that week. Monitoring Results Between May 10 and June 17, a total of 188,526 juvenile salmonids were examined externally for signs of GBD. A total of 138 fish or 0.07% exhibited external signs. Table 1 provides a siiamiary of external sign data by sample method. Table 1. External sings of GBD in juvenile salmonids by sample method. Affected fish exhibited at least one cutaneous gas bubble. Sample Mode Snake R. SMP^ Col. R. SMP SMP Separator FGE^ River Reach Total 188,526 138 • 0.07 ^ SMP refers to the Smolt Monitoring Program. ^ Fish Guidance Efficiency (FGE) testing. Of the 30 fish affected, 77% were coho observed at The Dalles Dam on May 15. Internal signs were observed in 973 (40.8%) of 2,387 hatchery steelhead examined between May 13 and June 21. See Table 2 for a breakdown of signs observed by location. These internal signs were predominately of low severity and of questionable relevance. A working group of experts on gas bubble disease met in Seattle on June 21, 1994. Several members of this group (who had earlier inspected the gas monitoring program and data) expressed the concern that the internal lateral line and the internal signs (gas bladder, kidney) data were not very useful for determining the prevalence or severity of GBD. They also indicated that the gill filament data, while important for determining impacts of elevated TDG on juvenile salmonids, were useful only if the examination technique was improved aind made consistent among mpnitoring sites. Total Percent Total Affected Affected 61,905 54 0.09 91,524 25 0.03 11,549 26 0.23 21,772 30 0.14 1,776 3 0.17 56 Table 2. Internal signs of GBD in juvenile salmonids by sample location. A total of 2,387 fish were sampled, 446 at LGS, 417 at LMN, 585 at MCN, 483 at JDA, and 442 at BON. Data aure in percent. External Internal Gill Internal Total Site Lateral Line Lateral Line Filaments Signs Affected LGS 0 0 18.6 3.6 20.8 LMN 0 0.2 20.1 18.9 32.4 MCN 0 0 0.2 0.5 0.7 JDA^ 4.5 46.1 28.1 8.8 62.9 BON^ 30.1 96.8 41.2 24.4 98.2 ^ Data are incomplete for JDA and BON. A total of 860 adult salmonids (459 in the Snake and 401 in the Columbia) were examined between Hay 10 and June 20, with no external signs observed. Eighty-one percent of the adults were spring/ Slimmer chinook salmon. Invertebrates and non-salmonid fish were also sampled in the river below Ice Harbor and Bonneville dams. Between May 10 and June 16, 1,321 non-salmonids were sampled below Bonneville Dan with no observed signs of GBD. Between these same dates, 3,467 non-salmonids were sampled below Ice Harbor Dam with 72 or 2.1% exhibiting GBD signs. Over half of the organisms demonstrating GBD signs below Ice Harbor Dam were observed diiring a period (May 11 through 18} when hourly dissolved gas levels, resulting from involuntary spill, exceeded 130%. Physical monitoring data were calculated from data available from the COE CROHMS reports. Table 3 presents period average TDG for the monitoring sites most used in in-season management. Twelve hour averages would be more meaningful since spill normally occurred on a 12 hour per day basis. However, at this time those data are availeQ>le only for the forebay monitors and monitors below Bonneville Dam (see table 4) . Table 3. Total dissolved gas monitoring results from COS monitoring locations. Data are in percent TDG and are averages of hourly TDG readings between the dates noted. Season Average Location Mav 10-27 Mav 28-June 19 Hay 10-June 19 LGR Forebay 104 102 103 LGR Tailwater 111 108 110 LGS Forebay 108 106 107 LGS Tailwater 115 108 112 LMN Forebay 113 107 110 LMN Tailwater 114 111 112 IHR Forebay 112 108. 110 IHR 3.6 mi.^ 122 121 121 IHR 7.6 mi.^ 113 MCN OR Forebay 113 MCN WA Forebay 114 MCN Tailwater 115 JDA Forebay 110 TDA Forebay 109 BONN Forebay 112 Warrendala 114 Skamania 116 57 112 113 110 - 112 110 112 112 113 103 106 105 107 107 109 112 113 113 115 ^ Ice Harbor monitoring sites located 3.6 miles downstream on the north bank and 7.6 miles downstream on the south bank. Table 4 . Dissolved gas data presented as the average of the highest 12 hourly readings per day measured at forebay monitor sites and at Warrendale and Skamania. Data are in percent TDG. Season Average Location May 10-27 Mav 2 8- June 19 Mav 10- June 19 LGR Forebay 104 103 104 LGS Forebay 109 107 " ■ 108 LMN Forebay 113 • 108 110 IHR Forebay 113 109 111 MCN OR Forebay 115 112 . 113 MCN WA Forebay 115 111 113 TDA Forebay 111 106 109 BONN Forebay 113 108 110 Warrendale 115 113 ■ 114 Skamania 118 114 116 58 Senator Kempthorne. Both in the private and the public sectors, and in fact, in the public sector it's from Federal agencies, it's been stated, for example, on the Section 7 consultation process, that the National Marine Fisheries Service is extremely behind in meeting deadlines on the consultation process. It has been suggested that the National Marine Fisheries Service may not have the resources to carry out all of the duties and re- quirements that have been placed upon it. I look at the track record of documentation or responses we've asked for that have not been forthcoming. Would you comment on your assessment of Na- tional Marine Fisheries Service and the resources that you have and the aspect of deadlines that are missed? Mr. Stelle. Senator, I think that is a fair point. I know that the people that I oversee and manage in the Northwest region work in- credibly long hours; they work weekends and they are carrying an extraordinary load. The volume of work is enormous. Have we been able to make all the deadlines? No, Senator, we have not. As the program requirements continue, our resources get cut back. It's a huge problem and I would fully admit that. I think it's frankly a problem for most of the Federal agencies that are struggling to im- plement some of these complicated programs while our resource base is dwindling. Senator Kempthorne. Would you comment on this? I had a con- versation with representatives of the National Marine Fisheries Service expressing my concern about the delays, my concern about the fact that consultations do not take place, the fact that in some instances it's caused a Federal court to impose an injunction. When I pressed this point with representatives of the National Marine Fisheries Service, they have stated, well, if you would please be pa- tient with us because we are traditionally an oceanographic agency and the inland waterways is a relatively new assignment for us. Taking that into consideration, then when I asked what is happen- ing then to the salmon in the ocean, then I'm told, we don't know because it's a black box, would you comment on that because on the one hand, we look to the National Marine Fisheries Service be- cause of this charge that you're to do it in the inland waterways, but we're reminded that you're an oceanographic agency primarily but you can't tell us what is happening in the ocean? Mr. Stelle. The issue of what is happening in the ocean is in- deed, I think, largely not adequately researched and if there is one area of the salmon life cycle that we collectively have not done a good enough job on, it is in researching and developing the infor- mation on what is going on in the ocean habitat and how that may affect the life cycle. Has the Service or any other entity developed that kind of body of knowledge and information? No, Senator, we have not as of yet. Most of the focus of the Service from an ocean standpoint has been the more traditional bread and butter management of fisheries in Federal jurisdiction. Senator Kempthorne. Would you also give me your insight on why is the National Marine Fisheries Service in the Department of Commerce? 59 Mr. Stelle. Senator, I don't know. I think it's quite comfortable there. I don't know what the historical origins of that circumstance are though. Senator Kempthorne. Is it also accurate though that one of the primary charges of the National Marine Fisheries Service is to as- sure the harvest of the fish in the ocean, which is a large business program for the United States? Mr. Stelle. I would not state it that way, sir. I think one of the primary responsibilities for the Service is the proper husbandry of our fishery resources, a component of which is harvest, but only a small component. I think if you talk to some in the fishing indus- try, they might say that our job is not harvesting. Senator Kempthorne. That's interesting because that is a little different than what a previous spokesman for National Marine Fisheries Service said at a prior hearing that really, one of the pri- mary purposes is to support that business of this country, which is the fish that are harvested. This is a large economic benefit to the United States. Mr. Stelle. Yes. I was speaking from a fisheries management perspective, sir. I didn't want to leave the impression that our pri- mary job from a fisheries management perspective was to catch fish; it was to manage fisheries for long-term sustainability. Senator Kempthorne. I have a copy of a letter dated May 26, 1995 from Langden March, the Oregon Department of Environ- mental Quality, detailing 30 violations of the spill standard from April 26th to May 16th. Are you familiar with this letter? Mr. Stelle. Yes, Senator, I am. Senator Kempthorne. Again, based on this when I consider whether or not this was a well-controlled spill, should I ignore this letter or is there basis for this letter? Mr. Stelle. No, vou shouldn't ignore it and yes, there is a basis for it. The source of those violations, sir, is to my knowledge largely a large volume of fresh water coming off in big flows this spring that well exceeded the capacity of a couple of the projects to man- age that water. It had nothing to do with NMFS voluntary spill program. Particularly at one of the projects at Ice Harbor, the river nas been running at 120, 130, 140 thousand cubic feet per second and yet the hvdraulic capacity or the ability of the project to pass water safely through the turbines is limited to about 66 kefs. That means that about naif your river is going over your spillway and generating very high levels of gas. Those, I believe, sir, are either the exclusive or most of the violations which the Oregon letter cites and they are correct, it's a problem. It's a significant problem. It is not part of the Service's voluntary spill program though. Senator Kempthorne. I will make that letter a part of this record. [The letter and supporting documents follow:] 60 From: Frick Johnson To: Pat Reiten U5 31 95 17:23 O503 238 5514 : 6/1/95 Time: 11:03:24 DIRECT SERV. May 26, 1995 \ir. Ernest J. Harrell Iv ajor General, US Army - DixTsion Engineer C 3rps of Engineers, North Pacific Division O Box 2870 P jrtland Oregon 97208-2870 Dr. William Stelle Regional Director National Marine Fisheries Service N orthwest Region 7 SOO Sand Point Way NE BinCl5700Bldg I S52ttie.WA 98115 ear Major General Harrell and Dr. Stelle: DEPARTMENT OF ENVIRONMENTAL QUALITY NOTICE OF NONCOMPLIANCE Cin Apnl 14, 1995 the Oregon Environmenial Quali^ Commission issued an order that provided for a variance to the state's water quality standard for total dissolved gas. The variance w/as granted to enable spill over Columbia River dams to assist outmigraiing ( olumbia and Snake river salmon smolts. T he dissolved gas le\'e!s permitted in tlie order are. a daily (12 highest hours) average of II 5 percent as measured at established monitors at the forebay of the next dam downstream from the spilling dam; a daily (12 highest hours) average of 120 percent as measured at established tailrace monitors below the spilling dams; a cap on total dissolved gas for the Columbia River during the spill program of 125 percent, based on tJte highest two hours during the 12 highest hourly measurements per calendar day; 811 SW Swfh Avenue Portland, OR 972(»-l .'iJC (503) 229-5696 TDD (503) 229-6993 DEQ-l «^ 61 From: ErtcK Johnson Tc i.S 51 95 1 Pal Reite 7: 23 OSn.-) 238 5514 ; e/ves Time: 11:03:55 DIRECT SERV I NT) Page 3 of 4 (21002 003 'his variance to the standard was granted for the period from niidnight on April 19, 1595 13 midnight on August 31, 1995. "he followng violations have been recorded since that lime; ! :)atc Dnni Forebflv/Tailrace TDG Level April 26. 1995 John Day Tailrace 123 percent April 27, 1995 Bonneville Forebay 1 16 percent April ?.R. 1995 John Day Tailrace 121 percent April 28, 1995 Bonneville Forebay 1 1 6 percent April 29. 1995 John Day Tailrace 121 percent April 29, 1995 Bonneville Forebay 1 1 7 percent April 30, 1995 Bonneville Forebay 1 1 8 percent \.pri; 30, 1995 McNary Forebay 1 1 7 percent 4ay 1, 1995 Bonneville Forebay 1 1 9 percent vlay 1, 1995 McNary Forebay 1 1 7 percent w1ay2, 1995 Bonneville Forebay 1 1 7 percent ►■lay 3, 1995 Bonneville Forebay 1 1 6 percent ^?-y 3, 1995 iVlcNaiy Forebay 120 percent 4ay4, 1995 Bonneville Forebay 117 percent ^ay 5, i 995 McNary Forebay '■ 116 percent 4ay5, 1995 John Day Tailrace 1 23 percent 'Azy6, 1995 McNary Forebay 1 1 8 percent vla'y 7, 1995 McNary Foretdy 1 1 7 percent vlay 8, 1995 McNary Forebay 1 1 7 percent vfay9, 1995 McNary Forebay 1 1 7 percent vlay 10, 1995 John Day Tailrace 122 percent vlay 10, 1995 McNary Forebay 120 percent Vfay 11, 1995 John Day Tailrace 121 percent v4ay 11, 1995 McNary Forebay 121 percent Sday 12, 1995 John Day Tailrace 122 percent vfay 12, 1995 McNary Forebay 120 percent vlay 13, 1995 McNaiy Forebay - , 1 1 7 percent vlay M, 1995 McNary Forebay 1 . 1 1 7 percent vlay 15, 1995 McNary Forebay 120 percent vfay 16. 1995 McNary Forebay 1 1 8 percent 92-531 0-96-3 62 From: Erick Johnsoi 05 31 95 Pal Reiten 7 24 O503 238 55H Date: 6/1/9S Time: 11:04:25 DIRECT SERV Page 4 of 4 [^ 003 003 1 hese are Class One violations under Oregon Administrative Rules (OAR 340- 1 2-055 )(a) and (h)), and should be considered major violations of Oregon environmental law. "V ou are hereby requested to manage the spill prograin to remain within the water quality andard estabUshed by the Environmental Quality Conunissioniin its Order of April 14, lfe95. Failure to do so will result in more serious enforcement aiction up to and including ti irmination of the spill program authorization, if necessary. j \ /e recognize that compliance with the standard niay become dUScult with the in)pending s iring: runoff and snow melt. Nonetheless, webelieve thai thislis a critical water quality andard, and we will seek to discuss compliance with you flirther at tlje appropriate time. Sincerely, '^-'^^^-2^?^'^ Langdon Marsh Director iM:MD:RH:crw J;A\WC13\WC13497 (}c: ■ • ■ Rudy Rosen, ODFW MicheleDeHart,FPC Michael J. Spear, USFWS Roy Hemmingway, Governor's Office Mary Riveland, Washington Department of Ecology EQC Members TOTAL P. EH 63 MERfesiyKi May 30, 1995 Mr, Wiliam SleBe Re9»oal Director hteiional Marine Fts^ertes Servtea 7600 Sand Point Way N.E. $eani«,WA9eti5 DearWiB, The SnaKfl River Salmon Fteccrydfy Teain (the Team) has reviewed th« March version of th« Proposed NMFS Ftecovefy Plan. This lecer is to convey tfw Team's mone ifTtportant conwrents on NNfl=^S' propoeed recovery actions. The Team supports much of the draft Reoavcry Ptar. Your Ptan embraces most d the Recovery Team's firal rocomm»ndatioos thai oal for the use of indepenoant sderrtrfic reviews to g that implies that there is a known ftow-SL»rv« Harvatt: We do not beieve thai giving harvest management rasponsaaaty to the Pactfic Fishery Mareigemefn Councd and the Pacrfic Saimon Comfrtssion wiil nesud in reoovefy. • HabftaL Some specifk; gxaions the Team rscoeoded ("ua-. an immediate moretohum on further rxjn-feh-retetod ctevetopment of crlticai habita! areas), and which were incJuded in eajfer NM=^ Plsoi drafts, became *wetered down' in the final draft to the status of federaJ agency guidelines rather than ESA-martdated spedftc actions. 65 SteUe 5/30/95 Page 3 Proposed Recovery Plan Summov Table and the Dioiatjon Conarsi «t me end of Chapter VI The duration column of tD© taWes should be P9v»w©d and ttte time scales revisea to s^torter more rsaaonabte ones. For exampte. over a year iS suggested for the estabiislimerrt of t^I© Impte mentation Team and the ScicHrtHic Advisory Panel The State of Idaho, r^spongible for insurirtp that water drv»rsioaa.flre scrae,Q9CL-ia-Aitawed 8 years tg_^mptetg tta task. The Conssrvalion Diairicta and the irngaiors are gh/on two years to elminaie iWogai *berms.* The Team is aware that ft takes time to make hjndamerrtal changes in the Status-quo bet the proposed time frarnes are too teisurely oiveo ttie crtas that is occumng in the baan. tt vvill De trvcreaangly <»fftcult to advocate aggnesave imptementation cfi tt^ expensive mainstefn meafiuree whHe simuftaneousJy gomg 5k)wty wrttt other crifecal elements eteewhei* in the basin. institutioncri Structive The irtstitutjon section is the ptece to stress tt>e mrtportanoe of setting poorttjos. Some groups hoid the mistaken view thai we have unfimited resources to recover satmon. We know that hjndlog will be imttod and NMFS wrth tt^ help of the ImptementalJon Team and the Scientific Advisory Panel (SAP) must set pnorrties that will improve survival cTver the interim ¥rhi}e gen^ating adsJtional infennation through monitoring and evakiaticn that will enhance our prospect of making significant improvemertts In system operations or neconfigurations. The new ir^stftuttonai structure Is needed to bring orcier out o^ the present chaos. We canrxxt recover the eaJmor witt^out a single and accountable dedsksn point to imptement recovery. The Team necommenbed ttiat MMFS. because of its reeponsjbiirties under ESA, become tt>e decte^on makar w^ regard to matters ttiat affect the fisted Snake River salmon. In Ofderto devetop th© infrastructure and operating prcx:edures NMFS requires ttte resources for it to proceed. The sectkxi on data oolkection, manei^ng and cS^seminating of d^a is vvei done and needs to be implemented immedtetely. These activities ahoiJd be cerrted out ttvoogh an open pubtc p^^cese. We supped using a dtathbuted 3y«»fn such as the World WWe Web currentiy being developed on Internet The Te»n strongjy reconwnends that NMFS use an open pubfic process to stimulale reseercti and Oetsets on the effecth^^ness of salmon recovery measurea. 66 St8rte 5.^30/95 P£^« 4 W€ <^uesfion tha NMFS' prjposaJ ttiaithe Imptenwntation Team sfiould be an Qc&nmstfative Ktemity that wtfl 'direct researdT and the dsptrte rB«)lraon ciscussion is inoomptete and iaa(J©th«d«taii6 of testing and we suggeet that a more detaied ptan of operations be devetoped. 67 »8lle S/Sa'SS Pag« 5 We are cx)noem0d that the NMFS pfopcsed plan recommefxM: 3prinfl Itows as th* highest priority tor use of avajlaW« reaefvoir storage. TTte NMFS plan rsle^atos wfiat w« be^idve to be the highest pfionty. the use of readfvoir storage tor augmentation in tti© summer, to 'conserving som0 water for flow augmentation tn July and Auguat." The Recovery Team has recomrrwnded trtat first priority be grven to augrr^r^tirtg flows in the summer to axj taS chinook saimon juveniles because: {1 ) there is son^ evidence that flows oi 50 kefs aid fish (lA^ng throogh the reservoirs tn the summer. (2) flows are fikefy to be betow 50 kefs durtr^g mtx:h of Xt>6 summer mtgratlcn season in y«are we bener used to berwftt adults and fail Chinook juvenj tea in the summer. Only in y«rs of extremety tow runoff woukJ s^nifkarrt amounts of augmentation be needed in the spring. We beheve the NMFS Plan for use of stoned water in augment (towe is not ade<^iateiy deecrS^ed. We agree with the genefEd goai of using flew augmertation to attempt to incrBase survivai, but when arid how much to augnr«nt Is tefi to the Techrttcal Managenwnt Team (TMT) with urxdear guidance on priorities, irrterpretatton of inconsietent necommendations and application of flow obfectives. Row augmentation in the spring stVDuJd be rt^intonized and used, if needed, primarily during the teter part of April and May virhen most of the saimcn and steetwad are moving downstream. If targe numbers of Chinook amve at U^vtrer Grar»te Dam in April and flows are bw, It may be r^ecessafy to augment flows untif natural runoff increases. The Te^n racomfrteods thai ttie highest phorrty for tfie use of the water In Oworshak Reservoir shoukj be for tali Chinook in late June, July and August For this reason, the Team reoommerrts that hiMFS nrtaximize the r«fHI probabiity for [Xvorshaic Reservoir so thact the fuU storage cap^Qiuty is available 6 on reech survivajs. When the Team began the devetopment of our Recoveiy Plan Rocommerxlatiorts, over three years ago. it was commonfy thought that smolt survivals were exceptionally iow in the first re«4rvoir arxMuntered as they migrate out of the system. Fof this reason, recovery recommerxlatlons vwera focused on decreasmg water-parbde travel time arxJ presumabiy fish travel time. It was believed tl-^ this would reduce exposure to predators and increase survivals. The first two years of the N^FS/UW s>.rvivaJ stixiy have not oortfamed previous conventionaJ wisdom. In fact, the results were shr^ier in both years and showed reservoir sun/ival in Lower Grarate that appft)ached 1 CM percent over a wide rsnge ot ftows dunr^g the out-mtg ration. This is practseiy the type ot irttonnatior tt^ is absolutely necessary tor anyone to design and imptement a recovery plan. W^ a better understanding of reach survival, recovery measures can be tailored to rBduce mortafty as fish move through the system. The NMFS Reoovefy plan states th«^ NMFSAJW studies were rrande during a "very narrow range of ftow coocfition and so cannot be used to compare survivals at cSfferont Sow leveis.' The sbjties were conducted over the last two years and becBuse the flows vnry signiflcantty durkig each season they were able to coAect survival data over a wide range that va/ted from low to rska^y^ high fkj¥rs. The relationship of flow to sifn,nvai wil come from repealing these stwSes over many yeers. While the limitations of the data leave considefabte uncerrainTy ar^d unknowns, the Teaffl has not seen a reieijonship between suPrtvals of yearling Chinook and flow in the upper tv¥0 reservoirs. 69 Stett« &'30/95 Paga 7 SpiB The Team believes that the role of spill as a component of tt>e inteflm operations of the hydropower system m^its reexamination, and recommeivis to you tfat you undertake sucM a review . in our Fefaojary tetter to you and in ourext«nsiv« eartiereneve mat such a review would be the best example ot applied adaptive management artd wcuW reflect your continuing commrtment to the use of the bea science avatobte in the coodu^ ot the necovafy effort This recommendation is based on the Team's anaiysis of The !ike>y charge in survwais due to the tfMi program. The Team h^s deveSopeO these estimatos using ^jsumptiorw from your staff for mortaitjes through the ttree possible dam passage routes and through the reservoirs. The thrae ways tfiat fish pass a dam are over the spjilwery, througfi the turtiines or via the bypess system. Usaig the survival assumptions that we reoeived from NMFS staff, it appears that for those fish emigrating in the river, less than 40 percent of the fish that r99cf\ Lower (Srajvte as^ on the peroenftaoe of (ls^ that pass each cSam by the thre« alternate pessage routes. During sp«4r>e8 or b& captured in the Dypasa system forcoltectton and transport or in some cases returned to the river. Figure 1 illustratBS the in-river survival conditions with and vwithout spiil al arfl projects. The irvriver survivals without adcStional spill are 37 percent to below Bonnevitte and wfth sp«ll at aJI projects as recommonded by NMFS the in-rivef survivais increase to 40 percent. This is a very srrtafl increase tnat protoaWy cannot be rr»eesured arxl sgain assurrtes nst increase in rrtonaJty caused by increased dissolved sas. Rgurts 1 aiso illustrates the projected survtvaJ of fish to b^ow Bonnevitie taking into account the fish that are colioct«d and transportBd. The currerrt tran^xjrtation system when combired wiih fish omi^rHting In the river wiM result in approx*ma2aiy 78 percent of the fish that approach Lower Granite surviviog to below Bonr>eville. Under the NMFS proposed spill program this survival is reduced to 74 percert because fewer fish am coiJoctod for transport and the*efOfe more fish are exposed to tt^ ojmuiative mortality of emigr38f>g past eight darns and reservoirs. Again, ttie drfference between tftese survfvai estBTiaisi is prnbably too smai) to measure but the generai lev^ of survival under the proposed sptli program is likely to reduce survivais of listed salmon to beiow Bonnevifie dam. The Team believes that spil is not a vi^rie downstrsarn passage soMion. The current spiH program w* result in suc*t a sma^ change in survivals that it will be impossible to measure while at the same tfme presenting substantiai sunrivai risks due to gas bubb^ disease. WVale the Cofps of Engineers (Corps) and fiMFS are doing thstr best to manage diasoived gas levels, it is stppanm th«t technical and manAgemem failures have led to gas supersalLirceJon that exceeds theNMFSetandaidsot 115%torabayand I20%taiirace. The result is that ws do net have the abJBty to corttroi gas concentratioas to prect&ofy set levefa and the impacts of qsb bubble ^se^M could exceed ttie possible Der^efrts of avoKjing turbine mortaity. Our analysis has shown that the ngducttors In mortality in passing dams «(th ss>* are nxafe then offset by the trxyeased risk of super«rtUJ3lion snd 9t9 cumulaave mortaity erf pesaing nxilt^jie ressrwoirg and dams. 71 Stefle 5/^30/95 Page 9 Figtrs 1 - Cakaiiated survivals based on NMFS survivaJ astinnaies The Team cominu« to support tha devBtopnwnt of efforts on atemaiive suifscs collection and bypass systems bocause they offer itw opportunity to move fish past a dam VMthout creating ga« sup«rsa$urKtion problems. Given th« existing cofrftguration of spiUway gatss and sdlng basins^ spifi must be rinrited to reduce me impact of dissolv9d gas on eurvivals. In the futuro, reconSgured spitways may (» abie to satety pa^ greater amounts of sptll than is pfoserttry prudent but there must be substantial amounts of research and «ngineer1ng before this will be a rsality. Surface ooUecdon and vertical slot buA^head gates at sp^Mweye currently hold promise of increasing the portion of the tiah tha avo^d tt)e turbtfM»e v^le incfsasing the numbo? of tish spiled per volume of wcter spilled. The Team has foflowwj devekspment in surface oriented bypassirig and ootection since pubiishmg our Rnai Recomrtioodatiof^ in 1 994. We are now even more optimtstK t\3t preiminary prototype tests mi show tte ab0rty to Increase survivai past dams. We suggest thai efforts and expendturos for testing surface ooHecsion be increased, pertiaps at the cost of de-emphasizii^ other altematives such as instding extended length servers at the mainstem dams. KJMFS should foHow ck»*ty tn« surface ooJ»ectk»i •nork by th« Corp* at Ice haitnr and Lower Granite; and by the PUD's at Hocicy Reach and Wanapum. 72 Steiha 5/30/95 Pag« 10 Hood Control Tho recent indOtsrt of mortaiity in fish p&ns tsoksw ice Hartwr Dam suggests tfiat we should reconsktef spnng flood contro{ ar>d flow augmentaijon strategies. In rrfodsig^t. it se«ms mat bath th« Team and NMFS concentrated on flT« siTuation wfion the years were dry and we r>eed€id to maximize the use oi iiow augmentatioa. Our recant experience wrth involLMTtary spiH ttiat results in ni9h levels of gas supersaturation, shows ttta! NMFS needs ttie abflfty to nsducs rtver flow. The recent fish kjJJ below toe Hartxjr is an exampte whare in-season management decasjocs cooW have reduced ttre ftaw augmentatJor and spiH teveis above loe Hartxx dam sooner wnen the turtJtne pnabtem caused hi^ gas levels tselow the project. As gas saturecion Isvete incroc^s^d Into the lethal range, ftow ftugmectation ahouW have been naduced eocner to decrease the amount of water ttiat rteeded tc be spi^i^ at Ice Hartxx. Also the spilfe that were ordered above ice Hartor contributed to the saiLirafeon tev»J of the waier in ttte forebey. This added to the amount of supersaturation below the project Wrth tt>e present forecast of large invoKjntary spili st the end of May, rt ts a debcale balance to determirva hovr much* nitrogen we take over the short term in antler to redujce the peak total dissoK'ed Qas In ia» May taldng into accotffil of tt>e number of fish In the river. These types of operational decisions are predeeiy what is impHed tjy tt>e term in-season management. The high gas lovels at Ice Harbor empha^zes the importance of turbine rnaintenanca and gas abatement measures 3ssoy ctecomprasston rn the collector system. Technique that win not introtljce bubbles, (i.e. exsmffiation of giS larneSae), wiH Oe used wMh eaimon as well as steei^ead We eUso recommend thai haichery steetnead be sacrlflced for internal samples a^ that similar live samples be h«ld in the rivor to piravide a rr«asure ot nvartatity. WHh the almost certafnty o* high 73 Stelte 5/3CV95 Pag© 1 1 disso>v«d gas in tlTfl r}9X3 few weeks we sJTOold obtain as much irrfermatJon as po&sibte to rgsofv© t)T« uncertainty^ for planning future monitonng. Transport The NMFS decision to reiy primarlty on the cxjUection and transportation systems to get mo« of tfie smote past tt>€ dams and the reservoirs, uotrt irvrivef migration has oeen paiv^n as a better option, is a wis« choics in our view. Harvest Much of the harvest Section of th© draft Racov«/y Plan is very wefl done. The Harvest section shouW poHit out th^ since reductions in Harvest can have immadlaie effect on returning adults It Is impftrative that actiond de initiabod as quickiy as pcssiUe. This wlU irntiate the recovery process unt9 other measurBs tiegtn tc taice effect The draft Plan should specify that phaang out of tfie tower river ^net fle« is required because of intermingling of Snake Rrver fan Chinook with heatthy up-rtvw brigWs and hatchery stocks. The Team is <*«tufbed thai sooie han/est attematives have been removed from the latest NMFS Propose Specificafly the Pacific Fishery Management Council (PPMC) and the Pacific Salmon Commissioo (PSC) are given the responsibility of recovering Snake River Saimon by oorrtroffing harvest. The P^dific Council does not fvofo a ntanagenoent record that demcxistraJes a high oorcem for weak stocte. NMFS saems to propose thai the Pacific Salmon Commission meet their Chinook rebuitdng schec&jle that has not sf>own a trend tovvard rebuilding since rt w«s started in 1 984. THs requires an assumjsion that the Commission wil change their past harvest rules and ssjopt an imnnediate rebuikfr^ scheduie. The Team does not believe that the Corrmissicn wffl adopt the changes necessary to estabiah a netxJldng scheduie. in fact, the Commission has repeatedly ignored its own bilaterai sciorttifkj reports rsoommending that chinook harvest be reduced in order to fne« the rebuacSng schedule. The Team doubts th« the Commlaaion will develop, adopt and implement a rebuikring schedule that wil me«t the needs of coastwtde Chinook popuiatkxis in a timeiy fashion. 74 Stelie S't50/96 Pago 1 2 H would be ctesiraiale to manage harvest erf Snaka Rjver CSiinook w^'n t)^ frame>vork of tfi« cverail PSC cfuoook rebuilding proonam. H tTiat cannot be aooompfished we must have a fai! hack position th* p\sces thd burden on fisJ>eri»8 subi^ct to U.S. jurlscfiction. We agree that the sacrmce required to save a very small number of Srake Rtver fails, most of wt»ct\ will be cmigirt in Cartatda, is net practicafate: henc^ tne greatest reductions must occur in the en^e In-rtver har^st plus the ocean cajcft off Oregon aryj Washington. We are encourapftd by your report ttial the PMFC recogrizes ttiis rwed. The ir>-fiver haiveslBfs must atso be convinceci of its critical importance. H we cann« mantain tight oontroi over the harvest of ttw endarigenad SnaJce River Chlnooic, many ot the gains from other recovery methods will be lost. i isMbit The Team cot tvtw nets the Plan's sarxig st^i^xart tor the our recommendaiiofts on the cooitlHTaffing rote of tne Habrtal Comrrtcee, emphasis on tne effective monitoring of habcy and staketuslder (»rticipalk)n in development of long-term sub-&asin hab^al martagement ptan«. However, the Teem is cSsappointad ttiat the specific actions the Team recommended (e.g., an immedte*e moratorium on furt^ef non-fish-reteled devetopment of crttica) hsiatat areas), and wtiich were irHAxted in earter NUFS Plan drafts, became "waiered down" in the firaJ draft to the status of federal agency guidefines rather than ESA-mandatad specfflc actkrns, Asa resut. innplementation of the propoeed hi^oitat protection and necovery measures wifi depend upon NMFS ataity to persuade cooperaiive euppcrtive action by other federal ageTKies, wtthout the cenainty of ESA-mandatad drectfves. The Team urges NMFS to be strongly proactive in driving towanl that essemiai mtitti-agency cooperatiYe action. 75 Steite 5/30/95 PaQ« 13 I have sent cop«es of this tetter to the tvro rrembers of Congress wfro have asked us to review \h& NMFS Recovery Plan. A3 we have said before, we afioredaie the time and eftort that you hav© made to attempt to bring the NMFS Proposed Recovery Ptan into agreement with the Team's finai recommendations. We continue to ho*d the vtew that we expressed earlier. Time is not on our side cLnd the continufitian of argument or iegal chaUenges, regardless of merit, vrti surefy damage the Snake River socksye and Chinook salmon. ft you need further infbrmalian or explanations of our comments pteaae cal upon us. DoraW E. Sevan, Ph.D. For the Snake f»vor Salmon Recovery Team oc: Senator Mark Hatfietd Congressman Norm Okiks 76 COMMENTS OF THE DIRECT SERVICE INDUSTRIES AND PACIFIC NORTHWEST GENERATING COOPERATFVE ON THE NMFS PROPOSAL TO INCREASE ALLOWABLE TOTAL DISSOLVED GAS IN THE COLUMBLV RFVER Years ago, state and tribal fishery agencies and the United States Environmental Protection Agency conducted a "comprehensive review and syntheses of [gas bubble disease) research" which was also "reviewed by the Water Quality Section of the American Fisheries Society". (Tab 1, at 1; see also Tab 2.) The state and federal governments ultimately adopted a standard of 110% allowable total dissolved gas supersaturation that was specifically engineered to protect migrating fish in the Columbia River Basin (Tab 2, at 1; Tab 3), L.B. Day, then Director of Oregon Department of Environmental Quality, supported a limit of 105%: "'I maintain that the risk of killing fish by setting the level too high is a much more senous one than the nsk of taking a cautious approach so that the fish are protected." (Tab 4) Since then, the effects of supersaturated water on salmon remain the same. Only the politics have changed. For the reasons set forth below, NMFS' eleventh-hour request to set aside a sound water quality standard should be rejected. 1. Enormously signiTicant relaxation or state water quality standards should not be adopted in abbreviated proceedings. Last year, water quality decisionmakers reluctantly approved a spill 'expenment" that state and inbal fishery agencies admit produced no evidence of increased survival from increased spill. (Sec Tab 5, at 3.) Fishery policy spokepersons have long known that water quality waivers would be required this year to support their desire for increased spill. They were advised by DEQ staff and others to present iheir jusufication for their proposals in a fashion that would allow reasoned consideration, and did not do so. A ten-day comment period on changing a water quality 1 77 standard that has protected aquatic life in the Columbia for many years does not promote well-mformed decisionmaking. Our ability to respond to NMFS' proposal has been seriously hampered by the shonness of the time penod allowed for public comment. 2. The spill program will decrease salmoD survival, not increase it. NMFS recognizes that the most accurate computer model of juvenile salmonid survival is the CRiSP model, developed by University of Washington researcher Dr. James Anderson. Applying the model to NMFS' spill program, Dr. Anderson reports that it will decrease the survival of migrating spnng chinook salmon by at least 2.5% (and probably more) (Tab 6, at 3-4), pnmanly because the spill program will decrease the percentage of salmon transpcrtsd around the dams. A staff report by NMFS' own scientists offers an even higher estimate of the decrease in survival than Dr. Anderson: they report a 4% decrease in survival. (Tab 1, at 5 & Table 1 (decrease from 79% to 74% survival).) Dr. Don Chapman confirms that "relaxed restnctions on gas supersaturation, to the extent that they lead to increased voluntary spill, will do smolts no favor. The available data indicate that juveniles are better off if left in barges." (Tab 7, at 4.) 3. The state and tribal "1995 Spill and Risk Assessment" document cannot be relied upon to support any increase in allowable TDG. Two NMF,S scientists who reviewed the Risk Assessment document identified "major deficiencies" in it. (Tab 5, at 1.) This conclusion is shared by former NMFS scientist Dr. Wes Ebel (Tab 8, at 2 & Exhibit A), Dr. Larry Fidler (Tab 9), Dr. Don Chapman (Tab 12), and Dr. James Anderson (Tab 22), all of whom have advised the Oregon DEQ that the Risk Assessment should not be relied upon. DEQ staff appears to share this assessment. (Tabs 18-21. ) Frankly, the state 78 and tnbaJ fishery agencies have ndTdemonstrated the requisite scientific expertise on TDG to render informed judgments on this question. (Tab 13.)' We note that the agencies have been aware of these deficiencies for over two months, and have deferred responding until the very close of the public comment period. 4. A massive spill program is umiecessary to achieve NMFS' goal of passing 80% of salmon around turbines. As Dr. Ebel explains, NMFS and the states and tribes have erroneously assumed that the percentage of fish passed over a spillway is identical to the percentage of water spilled. Several studies deny this assumption, and indicate that almost all salmon can be passed around the turbines with much lower levels of spill that do not require water quality variances. (Tab 8. at 7-8.) The Snake River Salmon Recovery Team, keenly aware of the problems associated with high spill levels, has concluded that "spill is not a suitable long term recovery method". (Tab 15, at 2.)' 5. The proposed monitoring is inadequate. The U.S. Army Corps of Engineers. BPA and the Snake River Salmon Recovery Team all recommend that "any spill program should be biised on TDG level measured in the tailrace of each dam". (Tab 14, at 4; Tab 15, at 2.) NMFS, however, wants TDG measured in the forebays of the dams and at downnver monitonng stations showing consistently lower TDG measurements (Tab 8, at 'NMFS does have scientists with the requisite expertise, but we doubt they will appear in these proceedings. NMFS' scientists offered lukewarm support at best for an instantaneous limit of 120% of saturation (Tab 1, at 3 (such a standard "could be adopted on a temporary basis"). ^This comment is contained in a letter to NMFS endoning the January 25th diafi biological opinion. When the Team learned that NMFS had increased spill and decreased transportauon in the face of threats of litigation and political pressure from the state and tnbal fishery agencies, the Chairman of the Team indicated that the Team's endorsement was no longer valid. (Tab 16.) 79 5). NMFS also proposes to monitor for visible external signs of gas bubble disease in migrating smolts, but this is "unlikely to provide adequate protection for salmon" because "[b]v the lime gas bubble disease is widely apparent in either the juvenile or adult populations, it is likely that substantial losses will have occurred". (Tab 8, at 6.) NMFS' own scientists note that "[m]any researchers experienced in examining fish for external signs of GBD refute the validity of this method of assessment". (Tab 5, at 5 (referring to adults).) To the extent that a determination is made to reljix the standards, Dr. Larry Fidler notes that it IS essential to conduct a "microscopic examination of gill lamella and lateral lines" (Tab 11) -- monitonng apparently omitted from the NMFS monitoring plan. 6. The spili program will cost Northwest electric ratepayers at least $40 million dollars. Federal, Oregon and Washington law all require water quality standards to be set after consideration of all beneficial uses of the water, including hydropower generation, and consideration of economic impacts.' Douglas Faulkner, senior operations engineer for the DSIs, esumates that granting the water quality variance sought by NMFS will result in the loss of 4,500 megawatt-months of power, enough to power the entire City of Seattle for four-and-one-half months. (Tab 17, at 2.) This in turn will impose some $42 million in addiuonal costs on BPA ratepayers. (Tab 17, at 3.) Da«JV RP TA 88 In if}iU and J99S Risk Managemeiii, the agenciss present data for the r«c«pf»ire of juvenile talmonidt at McNary dam which were markeri and rdwEod at Rock Island Dam on the mid-ColumWa and ai IJflle Gooie Dam on ihe Snake River. Tobies ] and 2 arc takeo directly frou) SpUl uikI 1993 Risk Managcmau I have added one addliiuiinl tulumn orinAjmiailon to Uie lablej which jhowj lh« lurbine flows (/.«., Average Flow Ie3$ Daily Averajje Spill) for the years examined in the a«enaei' report The intent of the agencies in presenting those tables waj to demonatrare (hat there wu not a majsive mortality resuiting ftom Hi«olved gm wpertaturation (DOS) during this period. Howcv«r, at indicated in TabU J, most of the DOS levels nro below the US. nnvironmemal Piolwlion Ajjency ' guideline of 1 10%. In ftict, the hlgliesi lolid tjas pressure (TCP) Is 1 13.7 %, which is sianlflcaiUly below the ma.\lmum valuei of 120% . 125% recommended in Spilt aid J99S RiskManagemeni. Similarly, in Table 2, the TOP leveb are also well below the aJiowabie levels recommended in S^HI and 1995 Rixk Management. Conawjiif miy, the dissolved gat ralalioniWpa ihown in Tablea 1 and 2 have no relevance to the dissolved gai levels proposed for the Columbia and Snake RJverj by lliB alate end tribal agenciea and which are preseni in UH»e rivers in 1993. The most Imponatit aspects of these daU are the relationships between spill, turbine flow, and the proportion of recaptured fish The argiimenf advanced by Spill and 1995 Risk Managi/ituinf is that high recapture proportions reflect higher smolt uutvivol In the sections of river examined (I.e., Rocli Island Dain to McNary Dam &11J LiiiJo Oouse Dam to McNiry Dam). In Table 1 , It li clear thtt the highest recapture proportion occurs in 19y3 when the spill is highest {I.e., 417 kefs). However, this is also the year with the hiRJicst flow through the tuibines (/.? , 88.1 kcft). In fkct. the second highest recapture proportion (0 4fifi) of<^irrpd in 1989 when spill (Tow was well boJow the 1993 spill level, but turtjne flow waa the second hiffhen for the period {I.e., 70.0 koft) Clearly, because ofthe contrasting results, ilieae data Oiil lo dciiioiiiiiiiatt thm npill produces the highest sinoh survival in these river reaches. Table 1 also yields Important infcrmstion about siiidt survival, spill, and turbine flows. In the table, 1991 corresponds to the year of highest dnily avcrngc spill (56.6 kefi) with a corresponding recovery piopuiliuii uro.32 fui thinouk aalmoji and 0 3'4J fbr steelhcad trout. Yet, In 1989, when splU levels are about i/2 those of IVVl (/. . 54 4 kefs), thf recovery proportion k ne"'!' src'ter lh«n that of 1991 (/.c, 0.34 for chinook salmon ond 0.381 for Jteolhcod trout) nnd is the highest for stcclhcad trout shovrTi in the tabic. When examined iij leiiiis uf turbine flows, seme yf the hijjhest recovery proportions shown In Table 2 correspond to the nighest turbine flows (120.6 kcli ill 1989 and 130.9kclSin 1991). Again, because ofthe highly variable results, these data fail to dcmoiisirai? that spill is the optimal means offish passage at dnms In the case yf adult sun'ival, Figure 1 shows piois of migrant sup-ival indices fbr two populations of Snake River Chinook salmon tor the period 1980 through 1990. These data are from Table 3 of Spill (uid 1995 Risk Mana^mcnl. which l:een included for reference. In the figure, it is seen that for Mar»h Creek wild spring chinook, jurvivil was high when spill leva's ^vers 54 8 kefs. However, survival was also high when spill levtls were only 8 2 kcfi When spill \c\zU were bctvfoon 27,3 aud 48.1 kcfa, survival was less than that fbr either 54.8 or 8.2 kefs. 89 In the case of the Imnalia wild summer chinook, the Jiighcst surviva) occurred at a spill level of only 117 kcft while the third highest suivival occurred ai a spill le\el of only 8 2 kefs. The second highest survival occurred at a spill levels of 54.8 kefs. Clearly, the data of Figure 1 show little consistency and there is no dofinabie relationship between spill and the survival indices for the two populations of Snake River chinook. A similar efTevl is found in data for the survival of fkll chinook migrants ft-om the Priest Rapids i Hatchery fo; the period 1 980 through 1 987. Figure 2 shows a plot of migrant survival versus spill flow 11 is apparent that some of the highest suivivais occur at spill levels of about 20 kefs and again at spill leve's of about 160 kefs This constitutes a factor of 8 in the difference In spill rates. Based on this large difference, along with the other data of the figuic, it is apparent that there is again no consistency or definable relationship between spill and survival of this population of chinook salmon. In su'.nmary, the available data on the survival of Snake River and mid-Columbia fisli stocks are Wghly variable and fail to validate that spill is the best mechanism for fish passage at dams. A 1 additional coricern regarding the validation cf spill at; an optimum means offish passage is thai the eiVecis of DOS and gas bubble trauma (GET) in fish, which arc the primary deleterious effects of spill, have not been quantified in a manner which will allow a comparative analysis of the various fish passage mechanisms. Without such a comparison, it is impossible to scientifically establish which mecha;iism (or combination of mechanisms) will produce the greatest overall survival of salmonids. Furthermore, the NMFS 1 995 Rinlogical Opinion ignores much of the data from the literature, especially those data which show adverse effects of DGS on fish The Biological Opinion often refers to the risk analysis described in Spill cuxd 199^ RIskMamigemeni, which was prepared by the state and tribal agencies However, the analysis methods contaimd in this latter document have been criticized by NMFS' own staff, the Oregon Department of Er.vironmental Quality, and 8e\"eral independent scientists The fiaws identified in this document a.-e such that the analysis and conclusicns are invalid. The only justification which NMFS uses for seeking a variance to the stale water quality guidelines for DGS (in order to permit high spill levels) is contained in the following statement taken from the 19y1 Biological Opinion "NMFS concluded that it was appropriate to seek an operation that would result in the EPA criteria of I ]0% being exceeded primarily because of 1) the ability offish in a river environment to compensate hydrostatically for the effects of dissolved gas supersaturation. and 2, the daily fiucluaiion in levels of dissolved gas throughout most of the river." The statement with regard to fish having the "ability to compensate hydrostatically" is not consistent with the scientific literature, which shows thai in many cases where fish have adequate depth to compensate for DGS, they do not do so, and die of GBT as a result. NMFS' own 1995 net pen studies (Vom below Ice Harbor Dam illustrate this point directly The high levels of mortality which occurred In early May should have been avoided if the fish had compensated hydrostatically for the effects of DGS Based on the measured TGP levels of 128%, a compensation depth of about 1.0 meter would have prevented bubble formation in the vascular systems of these fish (t^idler and Miller 90 1994), The fish had 4 meters of depth available to them for compensation, yet 85% of them died from OBT (Dawlcy, NMFS - personal communication) In 1994, NMFS convened two panels of experts in the fields of DOS and GBT for the purpose of adwsing NMFS on the effects of DOS on Columbia and Snake River Salmonids. However, the panels were never provided an opportunity to examine and comment on the dissolved gas sections of the 1 995 fiiologiuil Oplntoti or Spill and 1995 Risk Management. Had this occurred, many of the flaws in these documents could have been avoided and a more scientifically defensible spill policy developed As it stands, the NMFS spill policy has very little scientific basis and certainly no comparative quantitative analysis of the various fish passage mechanisms Without validation, the spill policy is, at best, a guess and, at worst, scientifically irresponsible. 2. What independent scientific research is being conducted to monitor the efTecti oriplll And Its Alternatives in the Columbia River system? By independent, I am assuming this implies research conducted by universities or persons not associated with state, tribal, or federal agencies. At present, I know of only the work being conducted at the University of Washington by Dr. Jim Anderson on the development of the CRiSP computer model for salmon survival. Jn addition, research is being conducted by the Chelan County Public Utility District on the suiVival offish through Kaplan turbines at their Rocky Reach hydroelectric facility There has been one investigation by a scini-governmenlal agency on the effects of high hydrostatic pressure associated with the smoli bypass systems on the reduction or elimination of GBT signs in fish collected for biological monitoring. The^o experiments, which were conducted at Battelle Pacific Northwest Laboratories, demonstrated that the signs of GBT can be reduced or eliminated in five minutes or less of exposure to high hydrostatic pressure These results Indicate that the examination offish collected fVom the smolt bypass systeins for sdgns of GBT can under-estimate the extent of GBT in fish in the upstream reservoirs (Montgomery Watson 1995). 1 am not aware of any other independent research which is directly related to the monitoring of spill and its alternatives in the Columbia River System. 3. Are there risks to migrating imolts and returning Adults associated with high levels of dissolved nitrogen resulting from spill? The experience of the I960's and 1970'8 involving both juvenile and adult salmonids clearly show that there are high risks of mortality to fish in the Columbia and Snake Rivers exposed to elevated dissolved gas levels (Weitkamp and Kaiz 1980). Chinook salmon and steelhcad trout gmolts held in cages up to 4 5 meters deep experience 58% mortality in 7 days at TGP levels of 127% (Ebel 1971). Fish held in 4 meter deep cages below Ice Harbor Dam in 1 995 experienced significant levels of mortality in 4 days or less at TGP levels of 128% (Earl Dawley, NMFS - personal communication). Data from laboratory and field studies indicated that exposure to TOP levels of 1 1 5% at water depths of one meter or less can lead to 20% monality in times of 100 hours (Jensen et al. 1986, Fidler 1988) At TGP levels of 120%, time to 20% mortality can be as low as 50 hours (Jensen elal. 1986, Fidler 1988). 91 Smith (1974), using varied mysh gill nets on adjustable frames, has shown that up to 18% of Chinook salmon jmolts and 7 9% of the sieelhend smelts can be found in the upper meter of the water column upstream from Lower Monumental Dam on the Snake River Rondorf (1995), using hvdroacoustic methodi, has shown that the dcptii distribution offish in Lower Granite Reservoir is quite variable. Although the hydrcicoustic methods cannot sample accurately in the upper mctei of the water column, Rondorfs data indicate that m some sections of the reservoir up to appioximatcly 18% of the fish observed are in the 1 - 2 meter depths. Thus, the combination offish distribution depths and time to mortality data from field and laboratoiy experiments indicate there is high risk of direct mortality to fish exposed \o dissolved gas levels above 1 1 S%, l.inle is known about the level of indirect monaiity {i.e., predatijn, disease, failure to adapt to sea water, eic.) associated with the sub-lethal effects of GBT (NMTS 1994 Expert Panels on DGS «nd GBT). L'nforluriafeiy, the 1995 biological monitoring program, as designed, will not yield an accurate assessment of the lethal or sublethal mortalities associated with the high levels of DGS present in the Columbia and Snake Rivers The dlfTiculiy with the 1995 program is that it has not been designed with an understanding of how fish are disliibutod in the Columbia and Snake Rivers in relation to dis-.olved gas levels, periods of exposure, and poteniia! for mortality The NMFS 1994 Expert Panels o:i DGS and GBT made recommendations regarding the design of a biological monitoring program for ■i995. Few of the recommendations were implemented and the panel was never consulted regarding the design of the 1995 monitoring program A team of scientists which reviewed the 1994 biological monitoring program also made recommendation", for improving the design of the 1995 monitoring program (Montgomery Watson 1994) Again, few of these recommendations were implemented in 1995 At present, the 1995 biological monitoring program is an unfocused collection of attempts by various agencies to sample fish without an understanding of the appropriate locations and conditions under which to assess the impacts of DGS on the Columbia and Snake River juvenile and adult salmonids In many cases, the examination methods are inferior to those used in 1994. For example, in 1994, hatchery steelhead smolts were examined for bubbles in gill lamella and lateral lines using 90 - 100 power microscopes. In May of 1994, signs of bubbles in t;ill lamella were present in up to 60% of the fish examined This led to a termination of spill in 1 994 Ii. ] 995, examination was done with 1 0 power microscopes and no signs of GBT are being reported even though TGP levels arc 10% to 1 5% higher than in 1994 Cle-arly, there is a credibilhy problem in ihe results of the 1995 monitoring progtam In 1994, both the NMTS Expert Panels on DGS and GBT and the Montgomery Watson scientific review team pointed out the problem of high hydrostatic pressures i.i the smoll bypass systems reducing or eliminating the signs of GBT in fish before ;hcy are intertepted for monitoring. Even with the experimental results obtained /yom the Battelle Pacific Northwest Lnbo; atones experiments, the smolt bypass system sites coniimio to be the primary locations used in monitoring for signs of GBT. Another problem with the monitoring program is that many of the agencies which have been most vocal in their asserJon that high levels of DGS will not cause significant mortality In Columbia and Snake Rjver salmonids are, in many cases, the people responsible for much of tht biological monitoring. This presents a conflict of interest situation in that the credibility of tl)ese agencies may be 92 dimajied If Jlgnlflcsm levels of montlity or signs of (JBT are found in «moltt of the Columbia end Snake Riven This situation may lead to a compromije of the results of the biolotfical monlioHng program. At present, there i« no inrfp.pendert biologjcal monitoring for jignt of OBT being oonduetod on the Columbia and Snake Rivws. Consequently, the monitoring results reported by llie Fi»li Fusaiie . Center cannot be indepondonlly veiifieU. Perhaps the moit troubling aspect of the 1995 blolouical monitoring program is that hecauM it Is so unfbeused and poorly designed and iinplAmfintrd, an opportunity lo undariland the effect* of DCS on juvenile and adult salmonldi of the Columbia and Snako Riv«rs has bc«n lost. Scicmistt will f^cc ihe 1996 salmonid migrations with Utile itioic iiiA;inut\iun than was available at the beginning of I99S. Thli regrettable sltuadon could have been avoided had NMPS ke«p the DOS and GBT Expert Panel involved In the design of the 199S biological program and in an ongoing review ofthe data. Even af this late date, NMFS appeara relucunt to reconvmie the DOS and OBT Export Panel In order to review the 1995 data, analyze the inistAket of 199S, and develop a eomprchonaive monitoring program for 1996. 4. Have there been invesll)tatlonj ofthe cfTect of supcnalurated water on resident flsh? Have the reiujti of these itadlea hem InrorporatMi into currtnt pulley. The eiTbcti of DOS and GDI on resident flsli spocicii lias been ijuile limited in tumparison to studies of migratory salmonlds. The studies which have been conducted are summerlzed in Fidler and Miller (1994). NMFS is conducting some net pen studies on the elT^tt of DOS on resident fish and invertebrate populations ofthe Columbia and .Sn«lwgr Mommwuai. ind loc Hi/Mr tun. 'No (tieuo wer« made In 1991. Table 2. Rock Island SMF Juvenile Travel Time Releases Year Prop Recap Arerage TDG' (May) Average Flow* (May) Dally Average Spill* (May) 1989 Ch St 0.342 0.367 112.3 157.7 31.1 ia£.<^ 1990 Ch St 0,240 0.257 IU.5 151.1 32.5 we. 6 . 1991 Ch Si 0.320 0.345 114.6 187.4 56.5 (30,^ 1992 Ch St 0.340 0.381 112.1 140.7 24.4 wcz 1993 Ch St 0.211 0.172 118.5 149.6 39.4 n o.z ! 1994 a 1 St 0.303 0.238 U2.6 124.6 20.4 lO^.Z. • Avtnje now for R«lc Wind Dwn pwn itmi Oicft). 96 Table 3. Surrival scalv* and envtronmental data during tbejurrcoilc migration yean 1980- IWO. JuTeoUe Migration Year ADULT SCALAR *TDG' Flow* Manh Crack WUd Spring Ck WUd SunuMT Ck Spill' (kdW 19S0 0.04 .26 107.3 7.54 1981 0,14 .93 89,9 11.68 1982 0.83 .87 122.9 134^.1 54.85 1983 0.16 43 120.2 121.7 39.93 1984 0,31 .64 116.9 152.5 48.12 1985 0.66 .73 110.1 90.0 8.20 1966 0.097 .19 115.2 112.9 27.38 1 1987 0.07 .15 107.4 63.4 2.88 1 1988 0.09 .18 108.6 67.1 2.31 1 1989 0.05 .098 111.1 82.9 9.66 1 1990 0.12 ,32 109.3 69.0 805 1 "''' Average djllyl DO durinj Ml)' ai Im H irW Dim. ' Avcnje lUlljr flow during Miy u [u Hubor Dam. ' Average dally iplll during May urou Ou lower SnaXc KJvcr projecu: Lovm Onnlic, Unlc 0«ow, Lower I and Iw Hartar dimi. 97 MARSH CREEK IMNAHA RIVER X M Q ►J > > D CO E- < O 1.0 -1 2 r = 0.19 0.8 - P - 0.182 • 0.6 - • 0.4 - • 0.2 - 0.0 - 1 1 1 40 1.0 -, 2 80 120 160 40 FLOW (KCFS) 60 r = 0.22 p = 0.141 1 1 160 120 0,8 - 0.6 - 0.4 - 0.2 - 0.0 r - 0.28 p = 0.091 O r^ = 0.23 p = o.iak 1 f— — 1 1 1 -I r- 12 24 35 48 60 0 ' 20 SPILL (KCFS) 40 60 1.0 n r^ = 0.25 O.a - p = 0.171 • 0.6 - • 0.4 - * 0,2 - 0.0 - I — I 1 ■ ■' i r = 0.38 p = 0.075 1 \ — ■ — I 1 105 110 115 120 125 105 110 115 120 125 TOTAL DISSOLVED GASES {% SATURATION) RelatlTe »urvi"T&l of JuTonilo spring chlnoolc migrants veraus rlvar condltioni, 1980-80. Figure 1 98 W E- < > 1—1 > D CO E- < O 15 -| Y = 0.022 X / - 0.35 + 1.69 10 ' p = 0.013 • • • 5 - • • • t •• • 0 - • 1 1 • 1 1 1 100 15 -1 1 ; 150 200 250 300 350 400^ FLOV (KCFS) 10 - ^' Y = 0.023 X -f 5.68 t • • r = 0.31 p = 0.021 0 15 n 10 - 50 _ 1 1 100 150 SPILL (KCFS) 20Q r = 0.16 t • • p = 0.112 100 105 110 115 120 12? TOTAL DISSOLVED GASES (% SATURATION) \ Survival (corrected (or ocean condltloas) of Juvenile f&U Chinook migrants versus river conditions lor marked releaaes from Prleit Rapids Hatchery, 1980-87, Data ia from Hilborn at al. (1993) Fiuure 2 99 Prepared Statement of William Stelle, Jr., Director, Northwest Region, National Marine Fisheries Service Good morning Mr. Chairman and members of the subcommittee. My name is Will Stelle and I am Director, Northwest Region of the National Marine Fisheries Serv- ice. I am pleased to be here this morning to discuss water flows and salmon on the lower Snake and Columbia Rivers. Background For many people, salmon are one of the most profound and enduring symbols of the Pacific Northwest. Salmon have been the economic mainstay of many commu- nities and Native American tribes and are representative of the wild character so cherished by the people of Idaho, Washington, and Oregon. Unfortunately, the salm- on populations are now a small fraction of their former abundance. Where millions of salmon once returned to spawn, hundreds are expected in 1995. After listing three stocks Snake River salmon as threatened or endangered, NMFS initiated an ambitious effort to develop a recovery plan for these stocks in January of 1993 by appointing an independent recovery team. Their final rec- ommendations to NMFS comprised many of the major elements of NMFS' recently published Proposed Recovery Plan for Snake River Salmon. The Proposed Recovery Plan addresses all of the causes for the decline of salmon, including dams, harvest, habitat alteration, water withdrawals, the effects of hatchery fish on the survival and genetics of wild fish, and predation. While no single factor is responsible for the full extent of the decline of salmon populations in the Snake River, it is widely believed that hydroelectric dams have been the dominant reason for declines. For this reason, the Proposed Recovery Plan contains critical measvu^s designed to reduce the loss of juvenile fish caused by mainstem dams. NMFS is pursuing an adaptive management approach to increasing survival and, therefore, the prob- ability of recovering the listed salmon. The agency is working through the Corps of Engineers (Corps) and Bureau of Reclamation to adapt or improve the operation of the power system while evaluating the efiects of the modifications on fish survival. One part of this program is an evaluation of the merits of in-river migration (through the hydropower system) under the best conditions achievable compared with transportation (barging around the hydropower system) under the best condi- tions achievable. This evaluation relies upon augmenting flows and spilling at mainstem dams during both the spring and summer migration periods. The Spill Program history and rationale Spill is not new. "Involuntary" spill occurs in the Snake and Columbia Rivers in most average and above average water years because river flows exceed hydraulic capacity at the dams (water that cannot oe handled by the turbines must be passed over the spillways). "Voluntary" or controlled spill has been used since the 1970*8 to pass juvenile salmon around the dams on the lower Snake and Columbia Rivers. Spill has also been included in the Northwest Power Planning Council (NPPC) Co- lumbia River Basin Rsh and Wildlife Program since 1982. The first formal agree- ment specifying an amount of spill at the Corps' dams was a 1989 Regional Spill Agreement signed by the Bonneville Power Administration (BPA) and tne region's fish and wildlife agencies and Native American tribes. This agreement was later in- corporated as part of the NPPC's Columbia River Basin Fish and Wildlife Program. Spill has also been a primary means of moving juvenile fish past the five mid- Columbia Federal Energy Regulatory Commission (FERC) licensed projects since 1979, when the Commission curected the three public utility districts (PUDs), who operate these five projects, to commence fish spill programs and develop bypass sys- tems. Subsequently, through a continuing series of short-term stipulations and two long-term mitigation agreements (1979-1995), the FERC, the PUUs, and the Fish- ery Parties (including NMFS) continue to recognize spill as a cornerstone of fish passage protection at these Columbia River hydropower projects. More recentiy, as upriver salmon runs continued to decline at an alarming rate, it became obvious that business as usual" wasn't working. NMFS concluded in its Proposed Recovery Plan and in its Biological Opinion on the Federal Columbia River Power System (FCRPS) that spill is the only available method for providing an im- mediate increase in project survival of in-river migrants. (All other methods are longer-term solutions that require lengthy design, engineering, and construction.) As a result, the Proposed Recovery Plan calls for spill to meet an 80 percent fish pas- 100 sage efficiency standard (that is, 80 percent of the fish pass through non-turbine routes). NMFS supports voluntary spill because studies have shown that passage through spillways is the safest route for juvenile salmon migrating past a hydroelectric proiect. The spill program reduces the number of young fish passing through tiie turbines at a dam, increasing overall survival of fish migrating in-river. DISSOLVED GAS Water spilled at dams entrains large amounts of air and forces it into a dissolved state. Thus, spill may cause total dissolved gas (TDG) levels in the river to exceed saturation — resulting in gas supersaturated water. When migrating juvenile (or adult) salmon are exposed to areas with high levels of total dissolved gas, they can develop a condition luiown as gas bubble trauma (GBT). The condition is character- ized by air bubbles (embolisms) forming in various tissues of the affected fish (e.g., in fins, vascular svstems, and gills, and along the lateral lines). In extreme cases, the condition can lead to death. At lower levels gas bubble trauma can result in re- duced ability to avoid predators, increased susceptibility to disease, and impaired swimming performance. Reflecting their concerns about the effects of gas bubble trauma on resident and migrant fish, the states have adopted water qutdity stand- ards consistent with EPA guidelines. THE SPILL PRCXJRAM IN 1996 In developing the 1995 spill program, NMFS biologists used scientific literature regarding gas Bubble trauma, spillway and turbine survived, fish guidance, and by- pass and transportation operations. The NMFS analysis included peer-reviewed re- ports, unpublisned government reports, a spill evaluation conducted by the state and tribal fishery agencies, and all the data collected through monitoring the 1994 spill program. NMFS also convened a panel of experts in gas bubble trauma on two separate occasions. The panel's purpose was to help interpret the 1994 monitoring results, to aid in developing protocols for a 1995 monitoring program, and to identify critical research needs. Much of the literature reviewed in developing the 1995 spill program is listed in the FCRPS Biological Opinion and in the State and Tribal Fish- ery Agencies' spill evaluation reference sections. In addition, NMFS relied on the professional judgment of its biologists and re- ceived extensive input fi"om other Federal Government scientists. The review drew on scientists fi-om the Corps of Engineers, the U.S. Fish and Wildlife Service (USFWS), and the National Biological Survey (NBS) and utilized their expertise in the fields of dissolved gas supersaturation, fish biology, limnology, and many other disciplines in developing the scientific conclusions regarding the technical elements of the spill program. ^ The spills on the Columbia and Snake River system have three components: Vol- untary spill at non-collector projects in order to improve downstream migrant sur- vival, voluntary spill at fish collector projects to determine the relative merits of transportation versus in-river migration, and involuntary spill caused by high runoff" events combined with limited hym-aulic capacities at some of the projects. In the case of voluntary spill at non-collector projects (those projects where juve- nile salmon are not collected for transportation), there is little debate regarding its value to the fish. Spill has long been used at these projects as safer than routing the fish through the turbines. The difference is that under the Proposed Recovery Plan, the spill level is somewhat higher than under past operations. Voluntary spill at collector projects occurs only under high flow conditions, when conditions are better for in-river survival. This spill provides important information needed in NMFS' adaptive management strategy. By companng the survived to adults of in-river migrants to that of transported migrants, NMFS obtains critical data on how to improve overall survival of salmon, which is NMFS' ultimate goal. Voluntary spill at both collector and non-collector projects is limited in NMFS' pro- gram to ensure that dissolved gas levels do not pose a danger to migrating fish. Involuntary spill occurs due to high flows fi-om snow melt and heavy rains. The storage (reservoir) facilities in the system have limited capacity to contain these flows. The flows which cannot be routed through the turbines are spilled. The vol- ume of this involuntary spill increases when generating capacity at the Federal projects is impaired, for example during turbine outages. 'This uncontrolled spill causes the greatest challenge for the management of dissolved gases. 1 (The details of the review are given in the last section of this dociunent: Responses to Ques- tions by Senator Kempthome.) 101 THE GAS MONITORING/SPILL MANAGEMENT PROGRAM The spill monitoring program was developed over a period of 10 months and built upon the lessons learned m the 1994 spill program. Its purpose is to ensure that the spill program does not harm migrating juvenUe salmon oy causing gas bubble trauma. The monitoring program is explained in detail in NMFS' Spifl Monitoring Working Document (April 7, 1995). The monitoring closely follows the recommenda- tions of two separate panels of gas bubble trauma experts Uiat NMFS convened in 1994. The program has been comprehensivdv evaluated by a Gas Bubble Trauma Technical Work Group (co-chaired by NMFS and the Environmental Protection Agency), and provided to the Oregon State Department of Environmental Quality, and the Washington State Department of Ecology. The monitoring program has two components: biological and physical. The biologi- cal monitoring consists of sampling juvenile migrants at several locations and exam- ining them for both internal and external signs of gas bubble trauma. Also, resident fish are periodically examined for the same symptoms, total dissolved gas is phys- ically monitored by instruments in place both above and below each dam. In addition, though they are not strictly a part of the monitoring effort, several research studies related to the biological impacts of gas bubble trauma are presently underway. These include: using hateheiy steelhead to develop a non-lethal proce- dure for measuring gas bubbles in gill maments; holding resident fish species and hatehery-reared chinook salmon in net-pens below two dams and in one reservoir and regularly observing them for gas bubble trauma; identifying the most important signs of gas bubble trauma and determining their prognostic value; observing the length of time that radio-tagged individuals spend migrating through a collection system; examining total dissolved gas distribution in reservoirs relative to fish dis- tribution; and comparing the prevalence of gas bubble trauma in fish captured in selected dam forebays to the prevalence of gas bubble trauma in fish collected in dam bypass systems. (This latter research is critical because preliminary laboratory observations suggest that bubbles may disappear (i.e., collapse) as fish pass a dam via a bypass system.) The spill monitoring program and its associated research has provided the operat- ing agencies with iniormation used to adjust spill on a weekly and even a daily basis. The monitoring in 1995 has found that less than one percent of the outmigrating salmon are exhibiting any signs of gas bubble trauma. As recently as last year, it was not possible to make such a stetement with any degree of certainty because comparable data did not exist. As the spill program continues, new informa- tion will emerge from the attendant monitoring and research. This information will be used to continuously redesign the operations to reduce the potential for harm fix)m gas supersaturation. The monitoring program has shown that, despite involuntary spUl at several dams this spring and very, nigh concentrations of dissolved gas at Ix;e Harbor, only an ex- tremely low frequency of gas bubble trauma has been observed. Between May 1 and June 1, over 24,360 river-run juvenile salmonids were examined at the dams, and only 0.2 percent showed any signs of gas bubble trauma. Of these, 0.06 percent of 17,657 juveniles showed exterior gas bubble trauma signs, 0.6 percent of o055 juve- niles exhibited at least one bubble internally in the lateral line, and 1.7 percent of 657 iuveniles had at least one internal bubble in the gill lamellae. Furthermore, no gas bubble trauma signs have been recorded in the several hundred adult salmonids examined at Lower Granite and Bonneville Dams. In-Season Management A technical management team (TMT), comprised of NMFS, Corps, the Bonneville Power Administration, Bureau of Reclamation and U.S. Fish ana Wildlife Service, meets at least once a week to review the most recent data on runoff, the system operations, dissolved gas levels, and numbers of salmon migrating in the river. The TMT prepares recommendations on spill, reservoir operations, ete. The purpose of these meetings is to improve fish passage to the greatest extent possible while man- aging the system to remain witJiin stete water quality stendaros for dissolved gas. The meetings also provide a forum for stete and tribal fisheries managers to make recommendations on system operations. The Corps of Engineers and the Bureau of Reclamation, who are responsiole for the operation of the dams, make the final deci- sions on how the system is to be run. Thus, spill management in 1995 is a highly integrated and adaptive process. It operates using the latest date, and operational adjustmente are made rapidly. Ice Harbor An example of the spill program's real-time operational flexibility is seen in the incident that occvured at Ice Hai-bor Dam earlier this summer. In that instance, tur- 102 ' bine outages, and a hieher-than-anticipated runofiF event at the foiir lower Snake River projects combined to raise total dissolved gas levels above the state standards. In this case, even though Federal Managers could do little about the causes of the situation, a number of operational changes were made to reduce the impacts of the involuntary spill. The options that have been pursued to date to control dissolved gas levels in the river system include: (1) filling Snake River reservoirs in a short-term effort to re- duce spill; (2) distributing spill at Snake River dams above Ice Harbor over 24 hours, instead of 12 hours, to reduce instantaneous spill by 50 percent; (3) running turbine units at the lower three Snake River projects outside of peak (within one percent) efficiency to reduce water being spilled; (4) adjusting the spill pattern at Ice Harbor Dam. (i.e., spilling the same volume, but distributing it among spillways in a different manner) to reduce total dissolved gas levels; and (5) reoucing spill below levels authorized in the FCRPS biological opinion at three lower Snake River dams to reduce cumulative total dissolved gas effects. Some of these measures mav have some negative effects on juvenile survival (e.g., running turbines outside peak efficiency, reducing spill at Lower Granite Dam, and filling reservoirs), but the NMFS and the Corps are agreed that it is important to take all reasonable steps to comply with the state water quality standards. SPILL AND RESroENT FISH NMFS is attentive to the fact that increased flows for salmon may affect resident fish. Augmentation flows affect resident fish both in the reservoirs and in tiie river reaches below them. The Idaho Department of Fish and Game (IDFCJ) offered testi- mony about impacts on resident fish at a May 10, 1995, hearing. They perform bio- logical monitoring in the Clearwater River, and during the hearing they commented on spill at Dworsnak Dam and total dissolved gas levels in the river below the dam. The impact of reservoir drawdown on kokanee and black bass populations in the reservoir was of particular concern to the citizens at the hearing. The district IDFG- biologist for the Lewiston/Orofino area testified that kokanee populations are in very good shape and have increased since the reservoir operation was changed fi-om draiting in the winter (for power production) to drafting in the summer (for fish flows). He also indicated that the decrease in black bass populations is primarily due to lower populations of forage fish, primarily redside smners, and not due to loss of shoreline spawning habitat fi"om reservoir drawdown. Augmentation flows that result in spill can affect resident species in two ways: By entraining and passing residents into the river below; and, if spill volume is high enough, by raising total dissolved gas levels in the river below the dam. In the case of Dworshak Reservoir and Dam, kokanee is the primary (and perhaps the only) species that is entrained. While tiiis can have detrimental effects on the entrained individuals, there is no evidence that the kokanee population in the reservoir has been adversely affected. During the past 3 years, while spill was occurring, the health of resident species has been momtored at several locations. The results to date indicate that resident species exhibit very littie, if any, sign of gas bubble trauma when exposed to total dissolved gas levels generated by voluntary spill. IDFG is monitoring the health of resident fish in the North Fork and main Clearwater River below Dworshak dam. Spill would be reduced at the dam if monitoring indicated that serious impacts on resident fish. A very low prevalence of gas bubble trauma signs was noted in resi- dent species during the spring 1995 spill at Dworshak Dam. CONCLUSION The 1995 spill program reflects the vears of study and evaluation that were the basis for NMFS' Proposed Recovery plan for Snake River Salmon. It has brought Federal managers together in a spirit of cooperation to optimize operation of the Federal Columoia River Power System. At the end of the operating season, NMFS and other fisheries managers will perform a thorough evaluation of the lessons learned by reviewing the results of the operational decisions recommended by the TMT, ansuyzing the data fi-om the gas monitoring program, and examining the re- sults of the numerous research projects. The information derived fi"om this adaptive management process will help resolve questions about alternative ways to improve the survival oi migrating salmon. In closing, I would like to emphasize several points: First, NMFS has decided to employ a managed voluntary spill program as one of the few existing tools to achieve unproved fish guidance around individual projects, and that improved in-river migrations are part and parcel of the larger effort to im- prove fish survivals in the system. 103 Second, spilling too much water can increase the risk of gas bubble disease in downstream areas, and therefore the voluntary spill program must be — and is — properly limited to minimize that risk. The NMFS and the Corps of Engineers have implemented a comprehensive and largely successful monitoring and research pro- gram that will both ensure that we are able to protect as best as possible against undue risks, and that we generate important inwrmation about fish survivals that will help us continue our efforts at improving survivals. Third, the spill program ought to serve as an interim program only. The Proposed Recovery Plan instructs the Corps to modify the individual projects to reduce the amounts of gas they create through the use of vertical slots and surface collectors that would pass more fish over the spillways with smaller volumes of water. These modifications hold the promise of improving substantially the efficiency of the fish passage effort, and therefore save more fish and more money by reducing substan- tially the costs of the spill program. I would encourage this Subcommittee and Con- gress to support these efforts because they hold such promise. Finally, the I>rMFS remains committed to operations based upon the best science available. It therefore intends to convene a group of operational experts and recon- vene its gas technical working group this fall to review all components of the in- season management process and the spill program. We will review the enormous amount of data generated by it and we stand ready to make adjustments and im- provements to the in-season management process and the spill program as the data dictate, in consultation with the states and tribes of the region. This concludes my testimony, Mr. Chairman. I will be pleased to answer any question that you or other Members of the Subcommittee may have. RESPONSES BY WILLIAM STELLE TO QUESTIONS BY SENATOR KEMPTHORNE 1. How did the National Marine Fisheries Service (NMFS) develop its 1994-1995 spill policy for the Columbia and Snake River hydropower facilities? The 1994—1995 spill program was developed in the context of, and is provided in, the biological opinion on 1994-1998 on operation of the FCRPS and the Proposed Recovery Plan for Snake River Salmon. It is peul; of the overall operation of the sys- tem called for in these documents. The system operation proposed by the NMFS was developed as a result of extensive discussions among the NMFS, the U.S. Fish and WUdlife Service, the Federal operating agencies, the state fishery agencies and Na- tive American tribes. These discussions took place primarily as part of the proceed- ings in the IDFG v. NMFS litigation. The NMFS also held several meetings with Recovery Team members and had public workshops with representatives fi-om the power and environmental communities in attendance. The entire biological opinion, including the spill program, was provided to the parties in IDFG v. NMFS for com- ment prior to ite issuance last March. 2. What scientific research supported decisions on the spill policy? What process did NMFS use to reach scientific conclusions? How was the spill policy announced to the public? The spill program was announced to the public through publication of the biologi- cal opimon on the FCRPS in March, 1995 and through puDlication of the Proposed Snake River Salmon Recovery Plan (also in March, 1995). NMFS provided notice of the Proposed Recovery Plan through a press conference and a notice in the Federal Register. The following excerpt from the 1995 biological opinion describes the rationale be- hind the spin program. (See also first two paragraphs under "The Spill Program in 1995" section, previously.) After reviewing available information on dissolved gas exposure as well as information and recommendations submitted by the parties during the IDFG V. NMFS discussions, NMFS concluded that 115 percent total dis- solved gas measured in the forebays was a reasonable interim measure to adopt. Several commenters ar^ed that the Environmental Protection Agen- cjr's recommended water quality limit of 110 percent represented an appro- priate level and should not be varied. Stete and tribal entities developed a risk assessment that suggested that long term emosure to 120 percent did not pose significant risks to migrating fish and that the benefits of im- proved dam passage outweighed these minimal risks of TDG exposure at 120 percent. Still otiier commenters noted the spill at collector projects re- duced the numbers of fish transported and that any risk assessment had to consider the benefits of transportation. The issue of transportation is ad- dressed more fully in measure 3 below. 104 NMFS concluded that it was appropriate to seek an operation that would result in the EPA criteria of 110 percent being exceeded primarily because of: (1) the abUity of fish in a river environment to compensate hydrostatically for the effects of dissolved gas supersaturation, and (2) the daily fluctuation in levels of dissolved gas througnout most of the river. In a river environment, depth of migration reduces total dissolved gas effects on migrants. Each meter of depth provides pressure compensation equal to a 10 percent reduction in total dissolved gas. Shew et al. (Undated) and Turner et al. (1984b) noted through tunnel studies that net entiy rates through McNary and Bonneville Dam ladder entrance tunnels were highest for the deepest (3.4m) tunnels. Other studies indicate that adult and luve- nile salmon tend to spend most of their time at or below one meter of depth (Smith 1974). Blahm (1975) concluded that shallow water tests were "not representative of all river conditions that directly relate to mortality of ju- venile salmon and trout in the Colvunbia River." In deep tank tests, salmonids exposed to 115 percent TDG levels did not emerience significant mortality until exposure time exceeded approximately 60 days (Dawley et al. 1976). NMFS also concluded that it was not appropriate as an initial interim level to seek an operation that would result in chronic exposure to TDG level of 120 percent, as recommended by the states and tribes. In general, chronic exposure to TDG levels of 120 percent with hydrostatic compensa- tion does not cause significant mortality until exposure time exceeds 40 days (Dawley et al. 1976). This is generally more time than it takes Snake River juvenile and adult migrants to travel between Lower Granite and Bonneville Dam. Nevertheless, NMFS concluded that the more conservative level of 115 percent is appropriate because of concerns about the potential sublethal effects of gas bubble trauma. The state and tribal report on "Spill and 1995 Risk Management" summarized the studies showing evidence that swimming performance, growth and blood chemistry are affected by high dissolved gas levels. The report correctly states that it is only inferen- tial that these symptoms may result in susceptibility to predation, disease and delay. In fact, studies conducted in 1993 and 1994 by the National Bio- logical Service indicated that juvenile chinook salmon that have been ex- posed for eight hours to high TDG (and exhibiting microscopic signs of gas Dubble trauma) are no more vulnerable to northern squaw fish predation than control fish that had been held in equilibrated water (Mesa and War- ren, in review). Ultimately the analysis in the state and tribal report did not assume any level of mortality as a result of these sublethal effects. NMFS concludes that the impairments to migrating fish as a result of the sublethal effects of dissolved gas may be sufiiciently grave to warrant cau- tion in setting long term exposure levels above 110 percent. In particular, long term exposure to levels in excess of 110 percent decrease swimming ability (Dawley and Ebel, 1975); fish stressed with high levels of dissolvea gas have been reported to have less swimming stamina (Dawley et al., 1975); and gas bubbles in the lateral line can impair sensory ability. In ad- dition, eilthough fish in deep tank studies are less affected by high levels of TDG than fish in shallow tanks, some mortalities still occur despite.a water depth that is apparently adequate for protection. There is no evi- dence that fish can "sense" TDG supersaturated water and deliberately sound to compensate. At specific projects where specific levels of spill, particularly daytime spill have been shown to be detrimental to fish passage, timing and/or amounts of spill may have to be adjusted (for specific detaus see NMFS 1994b). Spill may also be limited at projects where it can be demonstrated that spill may be detrimental to system spill allocation. One such project is John Day Dam, where very low amounts of spill result in very high TDG levels. These high TDG levels then limit the amount of spill possible at dams down- stream. For instance, by reducing spUl by 10 to 20 kefs at John Day Dam, it may be possible to increase spill at The Dalles or Bonneville Dams by 20 to 40 kefs. The exact relationship will need to be developed through in- season spill/TDG testing. The limitation of spill may also apply at The Dalles Dam to minimize the passage of spilled flow and fish over the high predation risk area in the shoals below the dam (see specific details in NMFS (1994b). The details regarding this limitation will be decided in-sea- son through consultation with predation experts and will likely depend on ambient flow and the spill levels obtainable under the TDG limitations. In 1995, spill at Ice Harbor, The Dalles, and John Day Dams may be modified 105 to accommodate research activities if NMFS determines that the spill modi- fications will not affect the validity of the transport vs. in-river survival study. These spill operations should be treated as interim until the effects of TDG on migrating salmonids are more fully evaluated and until a spill/ transport rule curve can be developed. The rationale for flow targets associ- ated with spill at collector projects is related to transportation policy and discussed under measure 3 below. Migration over the spillways or through the bypass systems are the safest routes of passage at the dams. Injury and mortality can occur through each route of passage (turbines, spillways, ice and trash sluiceways, juvenUe fish bypass systems), but loss rates via the spillways and bypass systems are low relative to passage by the turbines. For both spring/summer and fall Chinook salmon, mortality of fish passing over the spillways or through the bypass systems generally ranges from 0-3 percent (ochoeneman et al. 1961; Heinle 1981; Ledgerwood et al. 1990; Raymond and Sims 1980; Iwamoto et al. 1994). Direct turbine mortality can range from 8-19 percent for yearling Chinook salmon and 5-15 percent for subyearling chinook salmon (Holmes 1952; Long 1968; Ledgerwood et al. 1990: Iwamoto et al. 1994). Values of turbine and spill mortality are not available for sockeye salmon. However, it is reasonable to assume that these values are similar to or greater than values for yearling chinook salmon due to size and timing of migration and due to the greater susceptibility of sockeye to physical imury and mortality in project passage and handling (Gessel et al. 1988; Johnsen et al. 1990; Koski et al. 1990; Parametrix 1990; Hawkes et al. 1991)." 3. How was public review and comment solicited on the 1994 spills? What com- ments were received, and how was this information assessed by the Federal agencies involved in implementing the spill policy? Public review and comment was not solicited for the 1994 spill program, which was implemented as an emergency measure in response to record low returns of Snake River spring/summer cMnook. The spill program in 1994 was modified after internal examinations of steelhead revealed a high incidence of gas bubbles. After the 1994 program, NMFS solicited expert scientific input which took the form of convening two panels of experts on gas bubble trauma. The first examined the ques- tion of how the gas bubbles found in the internal examinations of the steemead should be interpreted. The second met to recommend what elements should be in- cluded in a monitoring program in future spill operations. The draft 1995 bioloeical opinion containing the 1995 spill program was distrib- uted to the parties in uie IDFG v. NMFS litigation for review and comment before it was finalized. The spill program is also part of the Proposed Recovery Plan, which is currently undergoing extensive public review. With respect to spill specifically, there was a public hearing at the Oregon Department of Environmental Quality, both in 1994 and 1995, wluch provided an opportunity for public comments on the spill program. 4. How did NMFS incorporate scientific and other information gained during the 1994 spills into decision making for the 1995 spill policy? See question number two, above, and the general text of this testimony. 5. Please comment on how NMFS works with the many government and independ- ent entities and concerned stakeholders doing research on issues related to salmon mortality and the Row of scientific information. The NMFS worked closely with many other Federal agencies, state fisheries agen- cies. Native American tribes and others during the development of the 1995 spill program. The agency also works closely with these parties in developing its research programs and coormnating them with those of others in the region. Most recently, the NMFS has proposed to pursue a project that would create a comprehensive re- search, monitoring and evaluation framework for all research in the Columbia River Basin. This project, called the Plan for Analyzing Testable Hypotheses (PATH), will be developed by experts from the Federal agencies, state fisheries agencies and tribes, with assistance from outside experts. Trie NMFS has proposed that develop- ment of the project be overseen by a group of Federal, state and tribal technical and management representatives. Once the comprehensive framework is completed, this same group of technical and management representatives would be responsible for ensuring tnat future research and monitoring in the Basin is consistent with this framework. 6. Please comment on the role that various government entities played and should play in the decisionmaking process and the advisability of establishing a single Co- lumbia River policymaking body. There are four states and 13 Native American tribes with a direct interest in the Columbia River Basin and its resources. 106 In addition, a host of Federal agencies have responsibilities for river operations, aquatic and watershed resource management, water quality, and dozens ot other ac- tivities in the basin. All of these governments and entities must have a role in the many decisions that affect the health of the basin and its economic uses. There is presently no one organizational body that includes all of the various government en- tities with some interest or role in the Columbia Basin, and any single fonun that tried to include every affected entity would collapse under its own weight. NMFS, in its Proposed Recovery Plan, has recommended to the sovereigns of the region that they work with NMFS through a regional forum designed to bring to- gether the state, tribal and Federal entities on those issues that are most conten- tious or have the greatest impact on the health of the basin and its resources. This forum is not intended to replace existing coordinating bodies, such as the Power Planning Council. Rather, it is intended to create a more open process in which all governments in the Basin can coordinate their activities, nave input into Federal decisionmaking and ensure that entities with decisionmaking authority are account- able for their decisions. Ultimately, the goal is to ensure that decisions are based on the best available scientific information. To that end, NMFS has recommended that a Scientific Advisory Panel be esteblished as part of that forum. Prepared Statement of Dr. Philup R. Mundy, Fisheries and Aquatic Sciences, Lake Oswego, OR Thank you for the opportunity to present this testimony. For the record, I am an independent fisheries scientist currently serving on the Independent Scientific Group, the scientific peer review body for the Northwest Power Planning Council (NPPC), Portland, Oregon. I also serve as a peer reviewer for the fisheries research program of the Exxon Valdez Oil Spill Trustee Council, Anchorage, Alaska. My spe- cialties are the application of mathematical and statistical methods to the study of salmon biology, fisheries management, and the design of fishing regulations. I will answer the questions posed to me in your letter of invitation of June 15 in the order they were presented, and then I will offer some comments on the how the nature of the institutional structure of salmon recovery research in the Colum- bia River basin may be modified to improve the decision making process. 1. Are the benefits of using spill as a fish passage mechanism established, espe- cially in relation to other fish passage mechanisms ? Please comment on the scientific validity of the National Marine Fisheries Service (NMFS) policy. The benefits of using spUl as a juvenile fish passage mechanism are established for a broad varietv of localities, however each hydroelectric dam is different, so the actual benefits achieved will depend on the design of the hydroelectric facility, the species, the life history type, and junbient physical conditions, among other factors. The benefits of spill are established in relation to the passage mechanisms of tur- bines and bjrpass in some localities for some species and life history types, however the same limitations of time and place apply to these comparisons as described above for the overall benefits of spill as a passage mechanism. As described below, the NMFS has recently completed data collection in its first attempt to compare the benefits of spill to those of transportation. It should oe noted that comparing the benefits of spill and transportetion may be misleading. I do not view spill ana transportetion as comparable mitigative meas- ures they are fundamentally different actions in terms of their effect on the juve- niles. Although transportetion of juvenile salmon in btu^es and trucks is often cited as a short term alternative to spill, I believe that transportetion is at best a stop gap mitigation measure, and I note that the ability of transportetion for returning adulte to the spawning grounds is unknown, as a matter of science. Transportetion is not acceptable as a long term recovery measure because collection of salmon for transportetion inflicte bypass and handling mortalities which are not factored into the transport-to-control ratios which have oeen used to justify the use of transpor- tation. Transportetion is antithetical to the preservation of genetic and life history diversity of salmonids, since mechanical bypass collection methods discriminate against certain species and life history types which are among the endangered spe- cies. Correcting the problems in the transportetion program may come too late to help endangered salmon. It takes many years to engineer and implement changes in the bypass systems which serve to collect juveniles for transport, and time is running out for the Snake River salmon. The bypasses themselves may be little better than turbines as passage mechanisms; very few evaluations have been conducted to com- pare the benefite of spill, turbines, and bypass at the same time with the same spe- cies. In so far as the benefite of turbines and bypasses have been simulteneously 107 evaluated, the survivals of juvenile salmon-in bypasses have been slightly better, to slightly worse than in the turbines. Transportation carries risks of its own. So far this year, more than 21 thousand mortalities of juvenile salmonids have been counted during the process of collection and loading for transport. Two single instances of mass mortality involving tiiou- sands of juvenile salmon as a consequence of human error have been docvunented in the transportation program since 1987. Since monitoring of the well being of the juveniles in the transport barges is difficult, I have little confidence that other than catastrophic mortalities during transportation could be detected. In summary, I believe the National Marine Fisheries Service has acted prudently in selecting spill as a recovery tool for endangered salmon in the Snake River. I also note that the spill policy of NMFS is as scientifically vfdid as any recovery policy for Snake River salmon can be, given the limitations of the available data. I also note that the limitations of the available data are due to a research process which lacks coherent direction and independent peer review, even though it has been his- torically very well funded. I address improvements needed in the research process under decision making, item 5, below. 2. What independent scientific research is being conducted to monitor the effects of spill and its alternatives in the Columbia River system? Please comment on the results of relevant studies. Since all scientific research on salmon in the Columbia River basin is financed by public and private institutions which can dictate the scope, objectives, and con- tent of the work, I am not aware of any independent scientific research to monitor the effects of spill and its alternatives in the Columbia River system at the present time. There are a number of relevant studies being conducted by state. Federal and tribed entities. A. THE NMFS JUVENILE FISH TRANSPORTATION STUDIES Coastal Zone and Estuarine Studies Division (CZES) of NMFS is conducting a study to compare the survival of transportation to that of fish which have started via spill. The design of the study does not permit the effects of transport and spill to be measured on the spawning grounds, and the final results will not be available for several vears, but potentially important information may be forthcoming. The ef- fects of spill are averaged with those of turbine and bypass down river fi'om where the fish are transported. B. THE NMFSAJW JUVENILE SALMON REACH SURVIVAL STUDIES Also by CZES/NMFS and the University of Washington (Skalski) is the reach (a portion of the river) survival study which should help to understand the ability of spill to deliver juveniles through the lower Snake River hydroelectric system. The enects of spill, turbines, and bjrpasses are not separable in these studies, but these data make it possible to compare average survivals during controlled spill to aver- age survivals under no spill. Results fix)m 1995 have been collected and they should be available in September, or earlier. C. FISHERIES AGENCIES AND U.S. ARMY CORPS OF ENGINEERS TRIBES MONITORING PROGRAMS Under the aegis of the Columbia Basin Fish and Wildlife Authority, a number of state. Federal and tribal entities are conducting individual and cooperative studies of gas bubble trauma, and the Corps is monitoring total dissolved gas levels at a number of localities adjacent to the dams it operates. Juvemle salmon, adult salm- on, and resident fish species are monitored for symptoms of gas bubble trauma in the Columbia River system. Monitoring of juvemle salmon occurs at the hydro- electric dams where sampling facilities make this possible. Preliminary studies to observe gas bubble trauma in active emigrants in the reservoirs are in progress. Re- sults from up to eight juvenile salmon dam sampling sites in the Snake River basin and the middle Columbia River are reported daily for juvenile salmon by the Fish Passage Center, Portland, Oregon. Adults are examined at the upper most of the lower Snake River dams after they have passed through the zone of nitrogen Supersaturated waters downstream. Resident fish are monitored below Dworshak Dam on a Snake River tributary. Results so far show little if any symptoms in juveniles and adult salmon and resi- dent species. These programs provide useful information, but they are relatively new so results need to viewed with caution. My best professional judgment is that the results indicate no apparent problems for the migrating juvenile salmon as a result of nitrogen supersaturation. Some symptoms of nitrogen supersaturation have been detected in a small portion of resident fish so far examined, however the 108 significance of these symptoms for the overall well being of resident fish populations is not known. In contrast to the monitoring at the dams, pen holding studies of juvenile salmon conducted by NMFS below Ice harbor dam have produced quite a few dead juvenile salmon, especially during uncontrolled spill events earlier this vear. The net pen studies are conducted for the purposes of reproducing effects of laboratory studies, and they are not indicative of survival of fi-ee swimming juveniles in the reservoirs. The net pens unnaturally restrict the movements of the juveniles, and small changes in depth can protect the juveniles fi-om the effects of even severe supersaturation. Hence the pen holding studies are implemented for the purposes of describing pathology, and not for determining the svirvival benefits of spill. 3. Are there risks to migrating smolts and returning adults associated with high levels of dissolved nitrogen resulting from spill? Nitrogen supersaturation poses risk to migrating salmon and to resident species, since prolonged exposure to nitrogen saturation levels above approximately 115 per- cent at the surface has been demonstrated in the laboratory and in net pens held in natural waters to be lethal to fish. The risks mav be negligible or serious, de- pending on the degree to which the distribution of the fish coincides with the dis- tribution of the supersatvirated waters. To put nitrogen supersaturation risk into perspective, I do not regard the risks of mortality for salmon which are actively migrating through nitrogen supersaturated waters to be as serious as the risks posed by migrating through tur- bines or bjrpasses for a number of reasons. Number one, supersaturation drops off sharply witn depth. For example, the potentially lethal total dissolved gas level of 140 percent at tne surface is reduced to the still potentially lethal, but lower, level of about 126 percent just 39 inches below the surface, and it is reduced to a safe level of about 113 percent less than eight feet below the surface. Number two, mi- grating adult Chinook are known to travel closer to the bottom than to the surface of the reservoirs when they have the opportunity. Number three, although juveniles have been observed at all depths in the water column, the m^'ority of juvenile salm- on are likely to travel at an average depth of about ten feet according to one study. Number four, if gas bubble trauma is affecting large numbers of juveniles, I would expect to see much higher rates of symptomatic juveniles than the negligible rates observed in 1995. Number five, although the depths occupied by resident fish de- pend on factors such as feeding and reproductive behavior, monitoring studies have found few resident fish with gas bubble trauma symptoms. Number six, the effects of nitrogen supersaturation on juvenile salmon appear to be reversible, since juve- nile salmon are fi-equently reported to recover from the effects of exposure to nitro- gen siipersaturated water when they are free to move. 4. Have there been investigations of the effect of supersaturated water on resident fish? Have the results of these studies been incorporated into current policy? Yes, there have been studies which examine resident fish for sjmiptoms of gas bubble trauma conducted by the Idaho Department of Fish and Game. Yes, the im- pacts of spill on resident species are incorporated into current spill policy. I under- stand the IDFG studies were conducted in order to advise Federal spiU managers of the potential risks to resident fish species. Since these studies have revealed no apparent effects of nitrogen supersaturation on resident fish, there was no need to alter current spill management actions. 5. To what extent has scientific research from the states been incorporated into the current spill policy? How can the present decision making process be improved? Analyses of available data conducted by scientists employed by the stetes of Idaho, Oregon and Washington, and the treaty fishing tribes were instrumental in establishing the current spill policy. These analyses called into question the effec- tiveness of juvenile salmon transportation, and at the same time indicated that spill could provide survival benefits under certain circumstances. Hence, the scientific work of the states and tribes was central to establishing the scientific basis of the NMFS spill policy. The decision making process functions on at least two levels, the management process of executing operational procedures at the dams to implement the spill pol- icy, and the research process of esteblishing the scientific basis of these manage- ment actions. I do not wish to comment on uie management decision process, since I have never been a part of it. The management process now involves only rep- resentetives of Federal agencies with statutory authorities and responsibilities for implementation of the Endangered Species Act and operation of the Federal power system. I do, however believe it is important for me to comment on how the decision mak- ing process may be improved by improving its scientific basis. The lack of estimates of the survivals of juvenile sedmonids through the Federal hydroelectric power sys- 109 tem, despite the fact that apphcable technology has been available for at least 20 years, should be seen as a stunning indictment of the institutional structures and golicy frameworks under which fisheries research is conducted in the Columbia iver basin. The ability to separate survival during hydroelectric passage from sur- vival in the estuary and ocean is fundamental to understanding Uie relative benefits and cost effectiveness of various mitigation measures. Since the historical data base contains so few opportunities to separate the effects of the hydroelectric system fi-om those of the ex-hydroelectric environments, there can be no resolution of competing scientific hypotheses about the benefits and risks of the role of actions such as spm and transportation in salmon recovery. For example, the Oak Ridge National Laboratory study by Bamthouse et al., iden- tified fundamental differences in the assumptions governing the Bonneville Power Administration's model of hydroelectric effects (Anderson, University of Washington) and the state, Federal and tribal version of the same model. The Bamthouse report concluded that the differences in these models, which are extensively used to fore- cast the benefits of salmon recovery actions, could only be resolved by collecting ob- servations on the survivals of the fish through tiie hydroelectric system, among other data. Hence a good deal of the present salmon recovery controversy is due to the fact that all parties rely on models which contain critical quantities which have never been estimated. These critical quantities are best professional judgments of the sci- entists involved, so the model results are no more, and no less, uian the opinions of the scientists who create and operate the models. There is a widespread mis- conception that "running the model ' with the latest data can add something to the decision making process which is superior to that which can be obtained by simply polling knowledgeable scientists for their views. If the Columbia basin models actu- ally had critical quantities estimated by observation, these model runs would pro- vide insight superior to informed opinion, but they do not, so they cannot. It is therefore important to recognize that the decision making process for spill is guided bv qualitative assessments of individual scientists, hence the comparison of benefits oased on the percentage of juveniles supposed by the models to transit the hydroelectric system alive is not a statistically or mathematically valid proce- dure. The figures cited by the Snake niver Recovery Team in its letter of May 30, 1995 to Mr. Will Stelle, Northwest Regional Director of NMFS, fall into this cat- egory. The Team notes in its letter that it does not know how to tell if the percent- ages calculated for the spill and no-spill scenarios are statistically significantly dif- ferent fixtm one another, but paradoxically, the Team goes on to conclude that the differences in benefits are, in lact, significant, and the Team rejects spill as a recov- ery option based on these differences. The logically inconsistent position taken by the Team in advising the decision making process is a direct consequence of the log- ical inconsistencies in ita modeling approacn. This modeling approach is an unhappy mixture of observation and bsdd speculation which is impossible to remedy without observations on the survivals of juvenile salmon in the hydroelectric system. My contention is that Ae absence of data to estimate quantities so crucial to the validation of tiie modeling process that advises the management decision making process would never have been permitted by an independent scientific peer review process which had influence over the funding of projects. In my experience as an independent peer reviewer of proposed fisheries research for the Exxon Valdez Oil Spill Trustee Council, Anchorage, Alaska, the actions of the Federal and state agen- cies which conduct the research can be modified by independent peer review to con- form to a central theme which produces logically consistent sets of observations for evaluation of specific effects. My experience as a fisheries scientist in the Columbia River basin is that the absence of independent scientific peer review allows Federal and state agencies to overlook critical information in implementing research pro- grams, and to confound the mission of salmon recovery with the missions of the in- dividual agencies. Note that I am not presuming that a peer review process could, or would, usurp legislatively mandated agency prerogatives. Rather it is my view that when agencies taie research money in the name of the Endangered Species Act and the closely al- lied Fish and Wildlife Program (NPPC), their proposed actions should be subject to an independent scientific review process which certifies that the proposed research actions are consistent with developing information critictd to the implementation of the Fish and Wildlife Program. I am also counseling that research projects should not be funded without this certification. In my experience with the Trustee Council, the requirement for certification has not cost any agency its share of the oil spill funding, but rather it has imposed standards on the types of research which are conducted by the agencies with oil spill funding which focus the research efforts on the attainment of established restoration objectives. 110 There is much literature from the field of public administration to support my ar- guments. To cite one example, Clark and Harvey (1991; Chapter entiued, Imple- menting Recovery Policy: Learning As We Go? In balancing on the Brink of Extinc- tion, Cathryn A. Kohm, editor) argue that successful implementation of endangered species recovery programs is dependent on more than just good technical and bio- logical tools. While participants in such recovery programs often attribute imple- mentation failures to 'Taad luck, lack of resources, pontics,' or lack of commitment in other organizations," Clark and Harvey (1991, p. 147) contend that implementa- tion failures can be a result of inappropriate organizational and decisionmaking ar- rangements. Since most recovery challenges go well beyond the boundaries of a single organization, coalitions are formed that must integrate diverse structures, ideologies, and standard operating procedures. But agencies setting up a new recovery program rarefy give explicit thought to how the recovery coali- tion should be structured. Programs are often set up along standard bu- reaucratic lines — not because tnis arrangement has proved most effective but because no other structure is considered. This in turn limits the set of solutions that seem plausible (Clark and Harvey, 1991, p. 153). I believe that an independent peer review process with financial influence and ex- tensive interagency participation and coordination would eo a long way toward solv- ing the institutional and organizational problems of the Columbia River basin's En- dangered Species Act implementation decision making process. In closing I note that most mtyor national research programs such as those of the National Science Foundation, the Environmental Protection Agency, and the Na- tional Institutes of Health, have coherent program goals and peer review processes. Should the Fish and Wildlife Program and Endangered Species Act implementation, a research program that spends on the order of $100 miHion a year on information of vital national interest, not have a peer review process? I appreciate the opportunity to share my information and professional opinions on this matter of importance to the implementation of salmon recovery under the En- dangered Species Act. If I may be of further service to you or the Subcommittee, please let me know. Prepared Statement of Edward C. Bowles, Anadromous Fish Manager, Idaho Department of Fish and Game overview Idaho Department of Fish and Game (IDFG) supports the concept of providing spillway passage of smolts as they migrate over dams in the lower Snake and Co- lumbia rivers. Managed spill is a valuable and scientifically valid recovery tool that does not require flow augmentation from upriver storage reservoirs to be imple- mented. The National Marine Fisheries Service's spill policy reflects the potential benefits this management tool can provide to recovery efforts. Salmon and steelhead represent a tremendous financial, recreational and cultural heritage for the citizens of the Northwest. The Snake River component of these fish represent an ecological cornerstone for spring/summer chinook and summer steelhead throughout the Columbia River basin. Loss of this resource would strike a devastating blow to the heritage and character of Idaho and the entire Northwest. It is generally accepted that dams on the lower Snake and Columbia rivers are one of the m^or factors in the decline of Snake River salmon (CBFWA 1991; NPPC 1993; NMFS 1994, 1995). Most of these stocks once thrived by spawning far inland in mountainous headwaters and sending their progeny to the ocean on the wave of natural snowmelt each spring. This journey has been altered dramatically as a re- sult of the mainstem hydroelectric system. This broken link in the salmon's eco- Sstem must be repaired for recovery to occur. Managed spill at mainstem dams on e lower Snake and Columbia rivers is one of our b^st and most practical tools to repair this broken link. answers to specified questions 1. Are the benefits of using spill as a fish passage mechanism established, espe- cially in relation to other fish passage mechanisms? Idaho Department of Fish and Game (IDFG) generally supports the NMFS spill policy. This policy is closely tied to spill measures recommended in the Northwest Power Plamung Council's Jish and Wildlife Program (NPPC 1993). A carefully man- aged spill program at dams on the lower Snake and Columbia rivers is essential to interim salmon recovery efforts. Spill is necessary because: (1) it is the best way Ill to get in-river smolt migrants past the dams, and (2) it is the best wav to provide an equitable balance between smolts transported in barges and tiiose allowea to mi- grate in-river. A key component of improving in-river migration is getting the smolts past each dam. Tnere are currently three possible ways for in-river iuvenile migrants to pass the dams: through the turbines, through the mechanical Dvpass and transport col- lection system, or through the spillway. IDFG, and all other fisherj; management agencies and tribes in the Northwest, believe that managed spill provides the safest route for in-river migrants to get past the dams. The turbine route (8-19 percent mortality) results in approximately five times more mortality than spill (0-3 per- cent) or mechanical bypass (1-3 percent) routes (NMFS 1995). The best way to mimmize turbine passage for in-river migrants is via a controlled spill program. Without spUl, all fish that are not mechamcally bypassed must go through the turbines. The efficiency of the bypass system at Lower Granite Dam is typically less than 60 percent. Thus, without spill, over 40 percent of the smolts will be forced to pass through the turbines. SpUl can be managed in concert with the bypass system at most dams to achieve an 80 percent fish peissage efficiency (FPE). This means that 80 percent of the fish will be provided a non-turbine route past the dam (either spiU or mechanical by- fass), and only 20 percent of the in-nver migrants will pass through the turbines. DFG beUeves adopting an 80 percent FPE standard at all dams on the lower Snake and Columbia rivers is one of the most important interim steps we can take toward recovery. Managing spill to achieve an 80 percent FPE requires no flow augmenta- tion fi^m upstream storage reservoirs, but simply reapportions existing water flow- ing past the dam. The National Marine Fisheries Service's spill policv includes an 80 percent FPE standard, but does not implement that standard xinless flow targets (e.g., 85 kefs or 100 kefs) are met at the lower Snake River dams (NMFS 1995). These flow tar- gets may not be met during much, or any, of the smolt migration season, resulting in over 40 percent of the smolts passing through the turbines at the first dam they encounter. iDFG believes spill should be decoupled from these flow targets, and that the 80 percent FPE standard should be implemented regardless of flows, except per- haps during extreme drought conditions. IDFG also believes that spill should be provided at transportation collector dams as a means to achieve a more equiteble balance between smolt transportation and in-river migration. This important interim strategy is necessary until long-term so- lutions can be implemented (e.g., dam modifications, surface collectors, ete.). The smolt transportetion program — which often transports over 85 percent of the total number of migrating spnng/summer chinook — ^has failed to reverse the downward trend in returning adult smmon (Olney et al. 1992; Mundy et al. 1994). Given the uncertainties regarding salmon biology, common sense dictates that we should not "put all our eggs" in uie transportation basket. Providing spill at mainstem dams allows a portion of the downstream run to continue their in-river migration under the best oam passage conditions we can create. Scientific information supports a more even balance between the number of fish transported and the number of fish allowed to migrate in the river. Higher adult returns are tvpically associated with smolt outmigration conditions that have higher flow and spill, with more smolts migrating in-nver and fewer smolts transported (Figures 1 and 2). Preliminary adult return information fii^m PIT togged juveniles indicates that in-river migrating smolts returned at least as well as transported smolts, even though in-river conditions were far fix)m optimal (Harza Northwest 1994). Independent scientific review also failed to support continued emphasis on transportation (Mundy et al. 1994). Improving in-river smolt migration conditions will always be important because, even if full transportation is continued, it is impossible to transport all juvenile mi- grants. At maximum transport 40-50 percent of smolts leaving Idaho will go through the turbines at the first dam they encounter (Lower Granite Dam) and not be transported. This is because of the inefficiency of the smolt bypass system. Many of Uiese fish will be picked up at downriver dams but at least 10-15 percent of the smolts will remain in the river. Improving in-river migration conditions is also im- portont for getting smolts to the transportation collection facilities. 2. What independent scientific research is being conducted to monitor the effects of spill and its alternatives in the Columbia River system? Spill is a management tool with known benefits, risks and applications. There are no critical uncertainties that preclude immediate implementation of spill as an adaptively managed recovery tool. As discussed above, there is firm scientific sup- port of usingmanaged spiU to aid recovery now, not just implement as a limited experiment. This scientific basis for spill was recognized recentiy by a Federal En- 112 ergy Regulatory Commission (FERC) Judge who rejected smolt transportation in favor of spill and in-river migration (FERC 1992: FERC 1994). This decision regard- ing two mid-Columbia River dams followed lengtny technical study and debate. The scientific, legal and ecological basis for spillway smolt passage does not pre- clude the need for rigorous monitoring and evaluation to fine time this management tool. Adaptive management requires continued critical analysis of the spill program in order to maximize benefits and minimize risks. The NMFS spill policy embraces this need effectively. This approach allows managers to learn as they go in order to con- tinually improve the effectiveness and efficiency of recovery efforts. These efforts allow managed spill levels to be modified on a real time basis to address specific concerns such as gas supersaturation or adult passage. 3. Are there risks to migrating smolts and returning adults associated with high levels of dissolved nitrogen resulting from spill? Gas Dubble trauma (GBT) in fish associated with operation of hydroelectric dams is a risk taken very seriously by the Federal and state fish management agencies and tribes. IDFG agrees with every other anadromous fish management agency and tribe in the Colunibia River Basin that benefits associated wiOi a carelully con- trolled spill program, coupled with extensive monitoring and evaluation, far out- weigh potential risks associated with GBT. Dissolved gas levels in rivers can be elevated by the operation of hydroelectric dams, particularly when spill occurs. Under such "supersaturated" conditions, gases tend to come out of solution, potentially affecting fish and other aquatic orgamsms. Gas bubbles or emboli can develop in circulatory systems and tissues. This occur- rence is referred to as gas bubble trauma (GBT) because it is a physical, not patho- lorical, response to an environmental condition (Jensen et al. 1986). To reduce risk of GBT in migrating salmon, IDFG supports a controlled dissolved gas management program designed to keep gas concentrations in the 120-125 per- cent range. This range will allow for enough spill to reap the benefits of this recov- ery tool, yet maintain risk of GBT within acceptable umits. Gas supersaturation standards in most states typically call for no more than 110 percent saturation to avoid GBT in fish. This is a general standard and does not account for the ability of fish to effectively avoid GBT. All Snake and Columbia River dams have adequate water depth in their tailrace for GBT avoidance. The spill policy implemented by NMFS includes adequate provisions to adaptively manage spill and minimize risk of GBT through monitoring, evaluation and re- search. State and Federal agencies and tribes worked collectively to develop the spill monitoring program. Implementation of the biological monitoring component of tnis program has run smoothly this year, and has maintained the flexibihty to respond to in-season concerns and modifications. The managed spill program implemented in 1995 has had virtually no detectable adverse impact on migrating juvenile and adult salmon and steel head. Extensive monitoring has consistently revealed that less than 1 percent of migrating juveniles sampled have symptoms of GBT. The symptoms that were found in a few fish were at very low levels and were unlikely to cause mortality. Adult salmon that have been sampled have not shown any symptoms of GBT. It is important to note that the monitoring program was able to respond quickly and effectively to sampUng con- cerns voiced by scientists representing tne power utilities (e.g., internal sampling for GBT symptoms, and examinations of fish collected prior to entering the bypass sys- tem). Tliis result is not surprising, and is the result of carefiil risk assessment by the agencies and tribes prior to implementation of the spill program this year. It is re- grettable that the flul benefits of spill have not been realiz^ this year. NMFS and the Army Corps of Engineers had the opportunity to achieve 80 percent fish passage efficiency at tne dams this spring, yet tell short because of excessive emphasis on transportotion and lack of confident adherence to the spill program and its biologi- C£d monitoring program. IDFG is concerned that this timid approach to spill has re- duced surviv^ from what could have been realized. 4. Have there been investigations of the effect of supersaturated water on resident fish? Have the results of these studies been incorporated into current policy? IDFG monitored resident fish in the North Fork and mainstem Clearwater rivers below Dworshak Dam during and after spill events this past spring. The Corps of Engineers total dissolved gas monitoring sites indicate that dissolved gas levels in the river ranged up to 120 percent saturation during spill. No mortality of resident fish has been detected as a result of spill. Less than 1 percent of the 453 resident riverine fish sampled fi*om April 24, 1995 through May 26, 1995, had external symp- toms of GBT, and these symptoms were very low level (i.e., only one or two bubbles observed per fish). 113 Monitoring of resident fish associated with spill in the lower Snake and Columbia rivers has not indicated adverse effects to resident fish populations. There has been very limited mortality of caged resident fish held for 4 aays in known areas of high gas concentrations. These fish were not allowed to seek out areas of the river with lower concentrations of gas. In spite of these adverse conditions that do not reflect mobUe resident fish populations, mortality remained low. Monitoring GBT in resident fish is part of the overall monitoring and evaluation program. Results from this program are used to make necessary m-season adjust- ments to fine tune the spill program and minimize risks of GBT in both resident and anadromous fish. 5. To what extent has scientific research from the states been incorporated into the current spill policy? How can the decisionmakirig process be improvea? The National Marine Fisheries Service (NMFS) has done a complete job of solicit- ing scientific information regarding the benefits and risks of spill at mainstem dams. NMFS convened a panel of dissolved gas experts in the summer of 1994. This was followed in August of last year with a series of technical workshops with the state and tribal salmon management agencies as well as representatives of the Di- rect Service Industries, Public Power Council, Pacific Northwest Generating Cooper- ative, and environmental groups. The workshops were followed by a series of meet- ings at which all these parties had an opportunity to express tneir views on spill issues. NMFS also invited all interested parties to submit written information on spill in December 1994, and to comment on its draft biological opinion in February 1995. Although NMFS has allowed ample opportunities for public comment on the gen- eral merits of spill, it has not done all it should to include the state and tribal sSm- on management agencies in the day-to-day decisions regarding the implementation of its spill program. NMFS and the dam operating agencies have not responded to a number of specific requests from the state and tribal fish managers regarding pro- vision of spill and measures to abate dissolved gas. As a result, we believe that the region missed some opportunities to improve salmon survival in 1995. The decision- making process on spill policy can be improved by ensuring that the state and tribal salmon management agencies have a voice in decisions regarding in-season manage- ment of the hydropower system. I would also like to call the Subcommittee's attention to two high priority actions that the states have long supported but have not yet been implemented by the Corps of Engineers. First, it is imperative that the Corps install dissolved gas abate- ment devices at Ice Harbor Dam. Much of the concern with dissolved gas levels at that dam this year could have been avoided if the dam were equipped with these devices. Second, the fish bypass system at Lower Granite Dam must be improved. This is the first dam that endangered ssdmon smolts encounter. Yet, the dam has one of the least effective bypass systems in the basin and results in the largest num- ber of smolts passing tiirough turbines of any of the lower Snake River dams. Im- portant modifications are stul years out in the Corps of Engineers's funding and im- plementation process, and the states and tribes are powerless to speea up this schedule. SUMMARY Managed spill is an important tool for salmon and steelhead recovery. It is the best interim tool available to spread the risk more equitably between transportation and in-river migration, the best tool to minimize the number of in-river migrants passing through turbines, and the best tool to get in-river migrants past the dams. Gas Dubble trauma associated with managed spill is a legitimate concern that is being effectively managed with a comprehensive monitoring and evaluation pro- gram. IDFG agrees with NMFS that a variance in state supersaturation standards to approximately 120 percent is necessary to meet flow targets and provide adequate spill provisions for springtime juvenile migrants. Recovery of Snake River basin salmon can be accomplished with a net positive effect on the Northwest economy, culture and lifestyle. Managed spillway passage of migrating smolts is an important tool in this recovery process. REFERENCES Columbia Basin Fish and Wildlife Authority (CBFWA). 1991. Integrated system plan for salmon and steelhead production in the Columbia River Basin. Columbia Basin System Planning for the Northwest Power Planning Council, 91-16, Port- land. FERC. 1992. Initial decision of Judge Stephen Grossman. Project Number 2114-024. Docket Number E-9569-003 (Grant County Phase). Washington, DC. 19 pages. 114 FERC. 1994. Order on interim license conditions. Project Niunber 2114-024. Docket Number E-9569-003 (Grant County Phase). Washington, DC. 19 paces. Harza Northwest. 1994. A trend analysis of Snake River spring ana summer Chi- nook PIT-tag data (1987-1993). Slide presentation to the Snake River Drawdown Committee. February 7, 1994. Jensen, J.O.T., J. Schnute, and D.F. Alderdice. 1986. Assessing juvenile salmonid response to gas supersaturation using a general multivariate dose-response model. Canadian Journal of Fisheries and Aquatic Sciences 43:1694-1709. Mundy, P.D. et al. 1994. Transportation of juvenile salmonids from hydroelectric projects in tiie Columbia River Basin; an independent peer review. Final Report to the U.S. Fish and Wildlife Service, Portland. Northwest Power Planning Council (NPPC). 1993. Columbia River Basin fish and wildlife program strate^^ for salmon volumes I and II. Documents 92-21 and 92- 21A, Northwest Power Planning Council, Portland. National Marine Fisheries Service (NMFS). 1994. Biological opinion on the Federal Columbia River power svstem and juvenile transportation program, 1994-1998. NMFS. 1995. Endangered. Species Act Section 7 Consultation. Biological Opinion. Reinitiation of Consultation on 1994-1998 Operation of the Federal Columbia River Power System and Juvenile Transportation F*rogram in 1995 and Future Years. March 2, 1995. NMFS, Northwest Region, Seattle. Olney, F.E., and members of the Ad Hoc Transportation Review Group. 1992. Re- view of salmon and steel head transportation studies in the Columbia and Snake rivers, 1984 to 1989. Report submitted to CBFWA, Portland. Prepared Statement of Margaret J. Filardo, Fish Passage Center, Portland, OR My name is Dr. Margaret J. Filardo. I have worked for the past 8 years as a biolo- gist for the Fish Passage Center (FPC) in Portland, OR. The Fish Passage Center was established in 1984 by the Northwest Power Planning Council. The Fish Pas- sage Center staff consists of individuals with expertise in oiology, biostatistics, hy- drology, and data management. The FPC is responsible, in part, for the annual im- plementation of the Smmt Monitoring Program as well as collecting and distributing data to all interested parties. The Smolt Monitoring Program monitors juvenile salmon in the Snake and Columbia River systems at seven dams and five tributary traps. Information is collected relative to the overall species abundance and health, ana timing of the migration for in-season management of flow, spill and hydrosystem operations. Since 1994 the Smolt Monitonng Program has been an in- tegral pan of tne overall Biological Monitoring Program (see attached figure) devel- oped by the National Marine Fisheries Service (NMFS) for Spill Implementation under the Biological Opinion. Spill is presently being implemented according to the NMFS Biological Opinion for 1995, with restrictions on the spill levels imposed bv the State limits (Oregon, Washington, and Idaho) for total dissolved gas. The risks associated with the pro- gram have been analyzed and incorporated in the development of the present con- trolled spill program. The 1995 SpiD Implementation Program includes both phys- ical and Diologi(^ monitoring programs. I am confident that the present monitonng program is accurately assessing uie occurrence of total dissolved gas and will pro- vide early indications of developing signs of gas bubble trauma (GBT). The following are my comments developed in response to the questions posed to me by the Committee: 1. Are the benefits of using spill as a fish passage mechanism established, espe- cially in relation to other fish passage mec?ianisms? Please comment on the scientific validity of the NMFS spilt policy. Spill for fish passage is not a new concept, it has been the long standing goal of the natural resource agencies and Indian tribes (A&T) to proviae a safe passage route for fish passing a hydroelectric project. The goal of the A&T has been to achieve non-turbine passage routes for 80 percent of the fish passing a dam. Spill has long been considered a viable method of project passage because studies have consistently shown that it is the safest route of passage past a dam. in the early to mid-1980's the provision of spill was compatible with the operation of the hydrosystem. since tnere was an energy surplus and the power operators had excess water. As the region shifted from the enero^ surplus, the issue of spill became more problematic. The volume of spill called for uirough the Biological Opinion is actually substantially less than has occurred in past years. (See attacned graph). The evolution of the 1995 Spill Program began in the early 1980's. Spill was in- cluded in the original recommendations to the Northwest Power Planning Council's 115 Fish and Wildlife Program. Spill is the primary means of passage provided for mid- Columbia FERC licensed projects and is central to the court ordered setlJement agreement. Spill was negotiated in a 1987 Regional Spill Agreement, which was later amended to the NPPC Fish and Wildlife Program. The NMFS has made every effort to obtain and consider input from diverse orga- nizations in the development of the 1995 Biological Opinion. The steps taken for uie development of the Spill Program represent technicsQ and scientific processes over the years. The risks associated with spill were analyzed and incorporated into the development of the present spill program. The Denefits of spill have been established through research and monitoring over several years. Direct studies of project mortality nave been conducted at several mainstem projects and have shown that spillway mortality is consistently lower than other passage routes. Adult return ana run reconstruction analyses have dem- onstrated that some of the highest smolt to adult return ratios have occurred under circumstances when high levels of spill (much higher than observed under recent planned spill programs) occurred during the juvenile migration period. Spill has been recognized and utilized as a fish passage mechanism for decades in the Colum- bia and Snake rivers. In 1995 the agency and tribal resource management agencies reviewed all the available literature and studies to develop an assessment of the risks associated with a spill. The "risk" was measured in terms of trading off the benefits to fish by avoiding turbine passage, versus the detriments associated with mortality due to increased levels of^ total dissolved gases (Draft 1995 Spill and Risk management, available upon request). The A&T concluded that spill is beneficial at levels of total dissolved gas greater than the levels adopted by the NMFS in the Biological Opin- ion. Therefore, the NMFS spill policy can be considered both scientifically valid and conservative. 2. What independent scientific research is being conducted to monitor the effects of spill and its alternatives in the Columbia River system? Please comment on the results of relevant studies. I am aware of research presently being conducted related to turbine passage sur- vival, spill passage survival, juvenile reach survival, transportation benefits, and surface spillway collection. Spill research specifically includes studies to determine the association of the signs of GBT and potential for mortality, the impact of pas- sage through bypass systems relative to the observation of signs of GBT, the amount of time spent in bypass systems, and the comparison of signs of GBT of fish observed in forebays and reservoirs versus observations at the projects afler passage through a b3T)ass system. SUBLETHAL EFFECTS You will hear references to the potential mortality associated with sublethal ef- fects, such as increased vulnerability to predation and long term physiological im- pacts. These are valid concerns, but they are also valid concerns relative to other routes of dam passage. Fish suffer great changes in pressure as they pass through a turbine unit and are immediately either killed or stunned and pass through to the tailrace area. Here these fish also suffer from increased risk of predation. I might interject that one of the benefits of spill is that it disperses predators from the immediate fish passage area below the project by causing velocities that are too high for predators. In adoition, the potential impact for transportation on the long term survival of fish has been overlooked. The transportation program has long oeen described as the solution to the problems in the migration corridor, yet despite ever increasing transportation of fisn we continue to see a decline in tlie species. It may be that there are other processes affecting the survival of these fish, or it may be that sub- lethal effects of transportation are manifesting in the population. Yet in spite of having no knowledge regarding this subject the Biological Opinion recommends im- plementing ihe transportation program and expands its implementation to fall Chi- nook migrants from the Snake River while no research has ever been conducted with Snsie River fall chinook. INADEQUACY OF THE MONITORING PROGRAM You will hear comments relative to the mortality being imposed on fish from dis- solved gas and the inability of the monitoring program to be able to detect the signs of GBT. This is not true. There have been at least two instances in the last 5 years when the monitoring program detected fish with signs of GBT as a result of spill. The first was in 1990 when a fire at John Day Dam caused the entire powerhouse to fail and 100 percent of the river flow to be spilled approximately 300 kefs for 5 116 days. A bargeload of fish being transported fi^m the Snake River (approximately 0.6 million) was released above iJie project and passed in spill with high levels of dis- solved nitrogen. Juvenile monitoring at The Dalles Dam immediately began detect- ing signs of GBT in fish with anywhere from 7 to 33 percent of salmonid species aifected within two (Lays. Bonneville Dam monitoring indicated that approximately 74 percent of the steelhead sampled 4 days later exhibited visual signs of GBT. The second instance was in 1993 over the Memorial Day weekend. Power demands were extremely low and 100 percent of nighttime flow was spilled at Little Goose Dam. Dissolved gas levels in the forebay of Lower Monumental Dam (the next down- stream project) were measured in excess of 130 percent. Subsequent to this high spill operation approximately 19 percent of fish at Lower Moniunental Dam exhib- ited signs of GBT. Since these incidents our methods of detecting the early signs of GBT have improved with specific areas of fish being observed for GBT, extensive training and the use of magnification. 3. Are there risks to migrating smolts and returning adults associated with high levels of dissolved nitrogen resulting from spill? There are certainly risks to migrating smolts and adults associated with high lev- els of dissolved nitrogen fi-om spill. The program for spill that was developed by the NMFS recognizes those risks and limits the dissolved gas levels fi'om fish spill. The operation of the hydrosystem is not benign to passing juvenile and adult salmonids. Passing the structure itself and through the slack water lake created by each project imposes mortality on fish. The responsibility of the resource management agencies is to adjust the passage of fish through the hydrosystem in a way that optimizes fish survival. Passage over the spillway is the most benign of the project passage routes, and if total dissolved gas levels are kept low enough, the benefits of spill passage exceed the detrimental effects imposed by high gas levels. The dissolved gas levels specified by the NMFS are conservative relative to the recommendations fa- vored by the state and tribal fishery resource agencies. The recommendations of the states and tribes and the justification for those recommendations is contained in the drafi; 1995 SpUl and Risk Management. 4. Have there been investigations of the effect of supersaturated water on resident fish? Have the results of these studies been incorporated into current policy? The concern regarding the effects of dissolved gas on resident species has not been investigated on tiie Columbia and Snake systems to the extent that research has been conducted on salmonids. However, studies conducted on other river systems have prompted the region to be concerned regarding the impact of TDG on fish that are spending longer periods of time exposed to higher levels. Therefore, the NMFS has incorporated tasks related to assessing the extent of signs of GBT in resident fish and invertebrates into its monitoring efforts. In addition, the distinction has been made, at least by the state agencies, regarding their preferential management for native salmon over introduced exotic species. 5. To what extent has scientific research from the states been incorporated into the current spill policy? How can the decisionmaking process be improved? To my knowledge the research conducted by the states has been incorporated into the current spill policy. There are some that view the current spUl program as more conservative than necessary but support its implementation. The monitoring pro- gram currentiy being implemented is based on the recommendations of the expert panel on dissolved gas convened by NMFS and on recent research results on signs of gas bubble trauma. Additional research is being conducted in 1996, which will be incorporated into future monitoring programs. Research and monitoring rec- ommended by state, tribal. Federal and private special interest consultants have been incorporated into the monitoring and into the research programs for 1995. In- dividual aspects of the present program are being conducted by state, tribfd. Federal scientists and' independent consultants. Virtually all aspects of the impacts of dis- solved gas trauma are presentiy being studied or will be addressed in the near fu- ture. In 'Conclusion, spUl has been shown to be the safest route of dam passage. The controlled spill for fish passage program was developed on the basis of past research and monitoring. It was developed with broad regional input by public and private entities. The spill for fish program was developed using a conservative analysis of the risks and benefits associated with spiU and dissolved gas. An extensive research and monitoring program has been implemented to verify the program. A broad range of research and monitoring data is being collected to evaluate the impacts and benefits of the spill program. All of this information will be incorporated into analy- ses to evaluate the effect of recovery (measures on Snake River salmon). 117 1995 GBD Biological Monitoring/Research Program Monitoring Juveniles Smolt Monitoring Program (Fish Passage Center) 1 . External Observations a.) Fins, Head, Mouth Area B.) Lateral Line Adults Snake, Mid-Columbia, Lower Columbia 1 . External Observations (Columbia River Inter-Tribal Fish Commission and National Marine Fisheries Service) Research A.) Lab studies initiated Fall/Winter 1994 to develop monitoring techniques to determine link between signs of Gas Bubble Trauma and mortality. (National Biological Service) B.) 1. Prevalance of signs of GBD in resident fish below Ice Harbor, Bonneville, and Priest Rapids dams. 2. Holding of resident fish and fall hatchery chinook in net pens. C.) Migration time through collection system. (National Biological Service) D.) Fish distribution in reservoirs. (Columbia River Inter-Tribal Fish Commission) E.) Reservoir versus collection system sampling. (National Biological Monitoring Service and Columbia River Inter- Tribal Fish Commission) F.) Gill filament sampling versus external signs. (National Biological Service) 118 CO E o O a5 CO -J §5- ■D< i CO D) i' CD o " co£ T3 (/) = iz *^ 'q. CO "co -I— • o 'F=^ o o o o O CD (D ■^ (M y- y- T- o o o o o o o C\J O 03 «0 ^ C\J (dvi/\i) inds 119 1995 COLUMBIA RIVER SPILL IMPLEMENTATION • SPILL IS BEING IMPLEMENTED ACCORDING TO: TERMS OF THE 1995 NMFS BIOLOGICAL OPINION STATE VARIANCE ON DISSOLVED GAS STANDARDS *120% TAILRACE - 115% FOREBAY OVER 12 HOUR PERIOD WITH 125% INSTANTANEOUS MAXIMUM SYSTEM WIDE PHYSICAL MONITORING OF DISSOLVED GAS LEVELS SYSTEM WIDE BIOLOGICAL MONITORING OF GAS BUBBLE SYMPTOMS 'ACTION LEVELS TO REDUCE SPILL, 15% OF FISH EXHIBIT ANY BUBBLES ON UNPAIRED FINS OR 5% OF FISH EXHIBIT BUBBLES COVERING 25% OF THE SURFACE OF AN UNPAIRED FIN. ' ACTION LEVEL TO REDUCE SPILL WHEN ANY MONITORED ADULT FISH EXHIBITS GAS BUBBLE SYMPTOMS. • THE PHYSICAL MONITORING PROGRAM DISSOLVED GAS LEVELS ARE MONITORED BY THE CORPS OF ENGINEERS CONTINUAL MONITORING IS CONDUCTED IN THE TAILRACE AND FOREBAY OF EACH PROJECT REDUNDANT AND BACK UP MONITORS ARE ALSO OPERATED GAS LEVELS ARE RECORDED AT EACH SITE 4 TIMES PER HOUR RIVER TRANSECT DATA IS COLLECTED IN CONJUNCTION WITH RESEARCH BIOLOGICAL MONITORING MONITORING PLAN WAS ESTABLISHED BY DISSOLVED GAS TECHNICAL WORK GROUP AND ON THE BASIS OF RESEARCH RESULTS OCCURS AT ALL MAINSTEM DAMS WHERE SAMPLING TAKES PLACE ADULT SAMPLING TAKES PLACE AT LOWER GRANITE AND BONNEVILLE DAMS RESEARCH SAMPLES FISH IN THE RESERVOIRS SAMPLING CRITERIA IS BASED UPON RESEARCH RESULTS EXTERNAL LATERAL LINE AND PAIRED FINS ARE EXAMINED, ALL SITES GILLS ARE EXAMINED AT THREE SITES AND THE RESERVOIRS RESULTS OF PHYSICAL AND BIOLOGICAL MONITORING 1995 DISSOLVED GAS HAS EXCEEDED THE STATE STANDARDS AT SOME SITES, DUE PRIMARILY TO UNCONTROLLED SPILL RESULTING FROM HIGH RIVER FLOWS AND TURBINE OUTAGES RATHER THAN THE FISH SPILL PROGRAM BIOLOGICAL MONITORING HAS SHOWN THAT THE ESTABLISHED ACTION LEVELS HAVE NOT BEEN REACHED RESERVOIR SAMPLING HAS NOT DOCUMENTED FISH WITH SYMPTOMS DAM SAMPLING HAS DOCUMENTED LESS THAN .7% FISH WITH SYMPTOMS ' PAIRED AND UNPAIRED FINS, GILL LAMELLAE, DAM AND RESERVOIR SITES NET PEN RESEARCH BELOW BONNEVILLE AND ICE HARBOR IS SHOWING ANTICIPATED LEVELS OF RESPONSE BASED ON DISSOLVED GAS LEVEL AND EXPOSURE TIME ADULT SAMPLING HAS NOT SHOWN FISH WITH DISSOLVED GAS SYMPTOMS OVERALL THE CONDITION AND MOVEMENT OF THE FISH MIGRATION IN RESPONSE TO THE SPILL PROGRAM HAS BEEN EXCELLENT 120 Prepared Statement of Col. Bartholomew B. Bohn, Deputy Command, North Pacific Division, U.S. Army Corps of Engineers introduction Mr. Chairman and Members of the Subcommittee, I am pleased to be here today to provide information on the U. S. Army Corps of Engineers efforts related the de- velopment of the spill policy for the Columbia River hvdropower dams. I am Colonel Bartholomew Bohn, Depuh' Division Engineer of the North Pacific Division. Accom- panying me today is Mr. Doug Amdt, Senior Fish Program Planner with the North Pacific Division. Northwest salmon stocks are in serious trouble. Three species of Snake River salmon are listed under the Endangered Species Act. In 1994, only one Snake River Sockeye Salmon returned to the Redfish Lake spawning grounds in Idaho. Returns of listed spring/summer and fall chinook salmon runs were very disappointing last year, and are even more dismal this year so far. The Corps of Engineers has been working with other Federal and State agencies, j Tribes, Northwest Power Planning CouncU, and other interested parties in the re- i f'.on for years to determine the causes of salmon run declines and to find solutions. \ ut the listing of these three salmon species and their precipitous declines over the past few years have focused our programs and directed us to more intensified efforts to improve conditions for this important resource. A number of factors have contributed to the cvurent state of the salmon stocks in the Colvmibia and Snake River Basin. These include: adverse effects of logging, mining, cattle grazing and pollution on spawning and rearing habitat: increased competition for food and spread of disease fi'om hatchery stocks; dams that impede the migration of juvenile salmon from their upriver rearing areas to the ocean and as they return as adults to spawn; and, over harvesting — historically in the 1800s and since then by ocean take and sport and commercial fisherv in the Basin. The situation is further compounded by poor ocean conditions which have also brought coastal salmon and steelnead stocks along the Pacific Northwest coast to similar lev- els of decline. All of these have combined to lessen survival chances of the wUd salmon stocks. OPERATION of HYDROPOWER DAMS TO MINIMIZE IMPACTS ON SALMON The Corps' eight hydroelectric dams on the lower Columbia and Snake Rivers are widely believed to be a major factor in the decline in numbers of wild Snake River salmon stocks. Besides physically impeding fish migration, the dams create res- ervoirs that alter water velocities and temperatures, interfering with juvenile migra- tion patterns and improving conditions for predators. We have sought and continue to seek solutions for the impacts of the Federal dams. Adult fisn ladders have been built into each of the ei^t lower Snake and Columbia River dams. These allow adult fish to follow a series of graduated steps and pools to scale the 100-foot rise in elevation from the tailrace to the forebay of the aams. The ladders work very well. In the years since the dams have been in operation, many improvements have been made to juvenile fish passage routes at the dams. There are a number of ways for juvenile fish to pass the dams: through the turbines, over tJie spillways, through the juvenile bypass systems, and in specially designed tanks for transport around the dams by barge and truck. Based upon juvenile passage studies, projects are op- erated to provide optimum passage conditions. The survival rate for turbine passage ranges fi'om about 85 percent to 95 percent, depending on the hydraulic ana hydrologic conditions at the dam, tvpe of turbine, efficiency range of turbine operation, and other factors. The survival rate for spill- way passage is considered to be about 98 or 99 percent. Survival rate through the bypass systems is about 97 or 98 percent. The svuvival rate for barged fish is about 98 percent to the release point. Jish collected at the bypass systems for transport at four dams are conveyed past all remaining dams. Survival numbers depend upon how many of the juvenile fish use each passage route and upon conditions they encounter. Turbine passage may disorient some fisn, making them easy prev for squawfish and gulls in the tailrace downstream of the dam. High levels of spill result in gas supersaturation levels that can cause gas bub- ble disease in fish. Another factor is the percentage of fish using each different passage route. Juve- nile bjrpass systems deflect 80 to 90 percent of steelhead, 60 to 70 percent of spring/ summer chinook and as few as 30 percent of fall chinook salmon away fi'om the tur- bine intakes and through the bypass channel. Recent improvements in deflector screens — especially the extended length screens — are expected to improve this sig- 121 nificantly. Those screens are scheduled to be installed at Lower Granite and Little Goose Dams in 1996. Spilling is generally believed to have a one to one effect, that is, when 50 percent of the water is spilled, 50 percent of the juvenile fish are as- sumed to be passed over the spillway. BIOLOGICAL ASSESSMENT OF HYDROPOWER DAMS EFFECTS ON FISH Under the Endangered Species Act, the Corps prepares a Biological Assessment of the effects on listed species of planned operation of the Federal Columbia River Power System (FCRPS), prior to the Spring start of the operating year. Following consultations between the National Marine Fisheries Service (NMFS) and the Corps, NMFS issues a Biological Opinion. In its March 2 Biological Opinion for 1995 and future years, NMFS found that the Corps planned operation of the FCRPS would jeopardize the continued existence of the listed salmon. Accordingly, the Biological Opinion provided reasonable and prudent alternative measures to avoid jeopardy. On March 10, 1995, Major General Ernest J. Harrell, Division Engineer for the North Pacific Division, signed a Record of Decision documenting the Corps intent to fulfill the recommended actions in the Biological Opinion. In its decision, the Corps relied upon NMFS professional scientific determination that the reasonable and prudent alternatives and measures will provide the necessary actions to halt and reverse declines of listed Snake River salmon species. The Biological Opinion calls for a variety of actions and studies for salmon. Flow augmentation, spills, juvenile transport, lowered reservoir levels, improvements to existing passage systems and other actions are being implemented in the 1995 oper- ating year. Further improvements to the existing system, and alternative configura- tions of the physical projects, are being evaluated for the long term. One of these is the surface bypass system for juvenile fish. This is a relatively new technology whereby migrating juvenile salmon would be guided in the top 20 to 30 feet of the reservoir surface where they normally travel, and passed over or through the dam. INFORMATION GAINED FROM 1994 SPILL FOR FUTURE SPILL POLICY In 1994, NMFS, responding to the states of Idaho, Washington and Oregon and the four lower river Tribes, requested, and the Corps implemented, an emergency Srogram of spUling at all eight of the lower Columbia ana Snake River dams. The [ay 9, 1994, request went beyond spUl measures in the 1994 Biological Opinion and previously agreed upon spill measures, such as those provided in the 1989 long-term spill agreement. The 1995 Biological Opinion again called for spill at all eight dams, including at "collector" dams where a msgority of juvenile fish would normally have been collected and transported. The Corps incorporated information fi-om the Scientific Panel convened by NMFS on the 1994 spill operation in its Biological Assessment dated December 15, 1994. The Corps eacpressed concern about exceeding current state water quality stand- ards in the Biobgical Assessment and referenced a letter dated November 9, 1994, to Federal agencies, the states, and other regional interests, from General Harrell. That letter indicated the Corps would attempt to adhere to the state water quality standards in operating its projects, and that requests to exceed state standards should be coordinated by the requesting agency. For the 1995 out-migration season, NMFS has obtained waivers fi^om Idaho, Oregon and Washington. WORKING WITH OTHER STAKEHOLDERS ON SALMON MORTALITY ISSUES The Corps assures that evaluations which it fiinds on salmon passage at its projects are fully coordinated internally and with regional entities and programs. It accomplishes this through an interagency technical review and oversight process called the Anadromous Fish Evaluation Program (AFEP). The Corps is working with NMFS to bring AFEP into coordination processes established under the Pacific Salmon Coordinating Committee (PSCC) or the forum currently proposed by NMFS for implementing the Recovery Plan. Under the new structure, a Corps AFEP Coordination Team oversees the program and provides command and control, program management, quality assurance and regional interface for all anadromous fish evaluations. The Coordination Team will consult with appropriate Indian Tribes, assure regional coordination with the PSCC or some other body as identified by NMFS and the PSCC, and inform the Power Planning Council of activities. . , t, j A Technical Coordination Team provides a process for interfacing with Federal and State fish agencies. Tribes and other interested parties to assure that they have adequate opportunity for review and to provide recommendations throughout the de- velopment and implementation of AFEP studies. The Team will also coordinate sci- 122 entific peer review of AFEP proposals, test-fish needs, and study results with tech- nical experts, the agencies. Tribes and others. Corps representatives are working with the agencies. Tribes and other interested parties to encourage active participa- tion in the APEP process. We will continue the annual study review meetings to provide the region with preliminary results of current studies. Final study reports and data will be provided to all interested parties as they become available. SUMMARY In conclusion, we have underway in the region a comprehensive and ambitious plan of measures and evaluations to improve survival of salmon at the Federal nydroprojects. Because of the complex life cycle of the salmon and the many factors that influence their survival, there is much uncertainty about the quantitative im- provements achievable from any individual measure. We must continue to learn from our actions and modify them as necessEiry. The NMFS Biological Opinion and proposed Recovery Plan and our research process are intended to assure that. Re- sults from turbine efficiency, gas abatement and surface collection evaluations, among others, will be considered as we make future decisions. Spilling is to provide interim protection for the juvenile fish until better tech- nic[ues for moving juvenile salmon around individual projects can be implemented. Spill is considered to be a safe method of passing the fish as long as it is carefully monitored to control gas supersaturation. The Corps has a network of gas monitor- ing devices at locations throughout the basin. The physical monitoring is unique in its intensity and coverage, and allows us to closely align our spill levels witn the water quality standards of the states and EPA. We have relied upon NMFS to provide a biological monitoring plan of action. While there continues to be refinements in the biological monitoring plan, an all- out effort is being made in the monitoring to provide for the safety of the juvenile fish. Thank you Mr. Chairman, that concludes my remarks. I would be very happy to answer any questions. Prepared Statement of Dr. Wesley J. Ebel, Biologist, Seattle, WA My background: I was employed by the National Marine Fisheries Service and its Fredecessors for 31 years as a "Fishery Research Biologist. For 26 of those 31 years worked on fish passage problems in the Columbia River. I retired in 1988 as Direc- tor of the Coastal Zone and Estuarine Studies Division (previously called the Fish Passage Research Division). Since 1988, I have worked as a consultant on fish pas- sage and other related research. I obtained a Ph.D. in Forestry and Wildlife Man- agement from the University of Idaho in 1977. My comments regarding the 5 questions you wish addressed are as follows: 1. Are the benefits of using spill as a fish passage mechanism established, espe- cially in relation to other fish passage mechanisms? Please comment on the scientific validity of the National Marine Fisheries Service (NMFS) spill policy. The benefits of using carefully controlled levels of spill as a fish passage mecha- nism are established if there is no other alternative than passage through turbines. Available research indicates that juvenile salmon will survive at a significantly higher rate passing over a spillway than through turbines at Columbia River dams. Thus spilling water at dams where fish are not collected and transported or where juvenile bypasses are inadequate does have some scientific validity as long as spill volumes are held at levels that do not cause excessive mortality from gas bubble trauma. The benefits are spill are not established in relation to smolt transportation. To the contrary, the best available data indicates that survival of fish collected and trsmsported is greater than in-river survival of migrants even during periods of high flow and spill. Since 1968, over 29 tests were conducted to evaluate the effects of transporting iuveniles, spring, summer and fall chinook and steelhead. In these tests, marked groups of fish released in the river as controls and transported (by barge or truck) were enumerated when they returned as adults to the fishery and to the dam where they were marked. All but two of these tests showed a benefit from transportation (transported fish returned at a significantly higher rate than fish released in the river). Two tests that did not show a benefit indicated no signifi- cant difference in retvim of transported and non-transported fish. Unfortunately, since 1983 there have been only 2 years (1986 and 1989) when both transport and control releases were marked lor proper evaluation of the trans- port operation. During the remainder of the years, no fish were marked or only 123 transport groups were marked making comparison with in-river migremts impossible most years. However, the research results available today demonstrate unequivo- cally that transport of chinook and steelhead from \he Snake lUver Dams benefits salmon and steelhead more than does in-river migration. I have seen no convincing scientific studies that indicate spilling at Lower Granite, Little Goose and McNary Dams is better than collecting and transporting the fish from these upstream dams. State and tribal fishery agencies have attacked the transportation research, but their criticisms lack merit. In an April 7th letter to Oregon and Washington water quality regulators (copy attached), I have addressed some of these issues (at p. 6 & Ex. A). 2. What independent scientific research is being conducted to monitor the effects of spill and its alternatives in the Columbia River system? Please comment on the results of relevant studies. In 1995, substantial numbers of juvenile spring chinook were marked to evaluate transportation and in-river migrations. The resmts of these studies will determine whether transport is better or worse than in-river migfration which included spill as specified in the biological opinion of the National Marine Fisheries Service (NMFS). These studies most likely will not be able to determine differences in survival of in- river migrants during periods of spill and non-spill because spill was occurring at several dams throughout the spring migration season. 3. Are there risks to migrating smelts and returning adults associated with high levels of dissolved nitrogen resulting from spill? There are risks to migrating smolts and returning adults associated with high lev- els of dissolved gases. Whenever gas levels approach or exceed 120 percent satura- tion, mortality to juveniles and adults can be substantial depending on exposure time, depth distribution of the fish and level of gas saturation. In the April 7th let- ter (at 2-5), I have discussed some of the relevant effects of gas supersaturation. The fishery agencies and tribes prepared a risk analysis, titled "^ill and 1995 Risk Management", addressing spills, gas saturation, and mortality. There are sev- eral errors in interpretation of results of some key studies cited in this analysis. As a result, some values used are incorrect and the conclusions drawn from some im- portant research are either distorted or incorrect. Thus, the risk depicted in this analysis that is associated with spilling water at dams is underestimated. The April 7th letter addresses these issues (at p. 4). 4. Have there been investigations of the effect of supersaturated water on resident fish? Have the results of these studies been incorporated into current policy? There have been investigations of the effect of supersaturated water on resident species of fish in the laboratory and in 1994 and 1995 in the Columbia River. Gen- erally, resident fish are more resistant to supersaturated water, but those that re- side in shallow water in the river (1 meter or less) would be severely affected. Pre- sumably, the results of studies completed in 1994 are incorporated in the current policy to the extent that NMFS continues to monitor the effects of supersaturation on resident fish. 5. To what extent has scientific research from the states been incorporated into the current spill policy? How can the decisionmaking process be improved? The states have not done any recent research on spill and gas bubble trauma. The agencies and tribes have conducted various analyses of studies conducted by others, including the risk analysis. The decisionmaking process can be improved by continuing to properly evaluate the actions taken to increase adult returns of salmon and steelhead to the Columbia River. Key studies are tiiose designed to evaluate transportation and in-river sur- vival of juvenile migrants under various flow and spill scenarios. If the proper stud- ies had been continued through the 1980's and 1990'8 as NMFS proposed, we wouldn't be here today testifying before this committee. NMFS proposed continued evaluation of transportation ana in-river survivsd of juvenile migrants during the 1980's and 1990's, but these proposals were rejected by the various committees that must approve NMFS researcn proposals before they can go forward. Those commit- tees are dominated by the state fishery agencies and tribes. Hiring freezes and lack of funding have also severely hamstrung 5ie NMFS units charged with carrying out the above needed research. 124 April 7, 1995 William W. Wessinger, Chairman Oregon Environmental Quality Commission 121 S.W. Salmon, Suite 1100 Portland, OR 97204 Eric Schlorff Washington Department of Ecology P.O. Box 47600 Olympia, WA 98504-7600 Dear Sirs: My understanding is that my letter of February 13, 1995, regarding the state and tribal "1995 Spill and Risk Assessment" document arrived at Oregon DEQ after the close of the last public comment period and has therefore not been considered by DEQ. For the convenience of all concerned, I have undertaken to consolidate the contents of that letter, a previously-filed affidavit, and some additional comments addressing the new proposal by NMFS to increase allowable levels of total dissolved gas in the Columbia River. I worked as a fishery research biologist for the National Marine Fisheries Service and its predecessors for 31 years, retiring in 1988 as Director of the Coastal Zone and Estuarine Studies Division, formerly the Fish Passage Research Division. Since 1988, I have worked as a part-time consultant on fish passage research problems. I obtained a Ph.D. in Forestry and Wildlife Management from the University of Idaho in 1977. In brief, my conclusions concerning NMFS" request are: 1. Denying the request would not likely to result in greater harm to salmonid stock survival through in-river migration than would occur by increased spill. Granting the request is likely to reduce salmonid stock survival because increased spill will decrease the percentage of fish that are transported in addition to any direct and indirect mortality arising from gas bubble disease. 2. Allowing the request does not provide a reasonable balance of the risk of impairment due to elevated total dissolved gas to both resident biological communities and other migrating fish and to migrating adult and juvenile salmonids when compared to other options for in-river migration of salmon. Indeed, allowing the request poses a risk of long- term harm to the Columbia River ecosystem. 3. Assuming proper monitoring and appropriately-designed experiments were in place, it might be reasonable to experiment with allowing spill to TDG levels of 115% in the stilling basin. Such an experiment should only be conducted at dams where salmon cannot be collected for transportation, since transportation remains a superior passage alternative. 125 (For purposes of these conclusions I have assumed that "in-river migration of saJmon" may include transporting juvenile salmon downriver in barges.) State and tribal fishery managers prepared the Risk Assessment document to justify increasing the dissolved gas concentrauon in a range of 120 to 125 percent based on 12 hour averages. The risk assessment model compares the predicted mortality that will occur to juvenile and adult migrants from TDG (total dissolved gas) induced by spilling against that which occurs from passage through turbines. A nsk assessment model is only as accurate as the values used to calculate the risk. I found several errors in interpretation of the results from some of the literature cited. As a result, some of the values used are incorrect and some of the conclusions drawn from some important research are either distorted or incorrect. The specific deficiencies are set forth below and in the attached Exhibit A. Background: G«nerai EfTects of Gas Supersaturation I have conducted a number of studies concerning the effect of gas supersaturation on juvenile salmon and other fish. Gas supersaturation arises when excess gas is dissolved in water; that is, an amount of gas over what the body of water would hold normally. In the Columbia and Snake Riven, the process of spilling water over dam spillways concentrates atmospheric gases in the water in levels that exceed the norm. These excess levels are measured by percentages. Normal saturation is 100%. In the Columbia River, values as high as 148% have basn recorded. Gas supersaturation adversely affects fish in a number of ways. Excess nitrogen enters the circulatory system of the fish and diffuses out, causing gas bubbles or emboli in the circulatory system and gas bubbles under the skin. These gas bubbles have a number of adverse physical effects. Gas bubbles occlude blood fiow in the gills, thus suffocating the fish. Gas bubbles also occlude the mouth and throat of the fish, and can cause blindness in the fish due to hemorrhaging or exopthaimia. The gas bubbles can also result in overextension or rupture of the swim bladder, particularly in juveniles under 50 mm in length. Collectively, these symptoms are referred to as gas bubble disease. Sublethal effects of gas bubble disease are not always evident as external visible symptoms. For example, Schiewe (1974) and Dawley and Ebel (1976) determined that sublethal effects such as decreased swimming performance and growth occurred at gas supersaturation levels as low as 106%. Poor swimming performance can result in increased predation by predators in the river. Laboratory research conducted by several researchers showed that the threshold levels for supersaturation where direct mortality begins occurring is about 110 to 115% for juvenile salmonids, depending on size and species. In shallow water, laboratory experiments have shown that, for example, at 125% saturation, 50% mortality to Chinook occurs in 13.6 hours. At 120%, 50% mortality occurs in 26.9 hours for chinook. To my knowledge, recent studies do not contradict these results. I note that the U.S. Environmental Protection Agency relied upon some of these studies in esublishing 110% TDG as the water quality critenon. 92-531 0-96-5 126 The authors of the Risk Assessment place substantial emphasis on in-situ live ca^e studies done by Meeldn, Turner and WeiLkamp. The authors state that concentrations were as high as 126 and 128 percent and no mortality occurred. For most of the duration of these tests the concentrations were nearer 120 percent. Considering the clearer water (fish tend to be deeper in clear water, Dawley et al., 1975) and the duration of the tests (7 days), I would not expect mortality. They do not refer to a test done in the Snake River where concentrations of TDG were 127 percent for the entire duration (7 days) and 48 percent mortality occurred in the volitional cage 4.5 m. deep. It appears the modelers must have given more weight to in-situ experiments that showed lower mortality rates. In figure S, page 42, there are several observations above the mortality line between 120 and 130 TDG. Depth Compensatioa _ The depth of a fish in the water affects the level of gas supersaturation that the fish can tolerate. For example, each foot of depth compensates for approximately 3% excess saturation. Thus a fish at 3 feet of depth in water supersaturated at 120% will be subjected to the equivalent of a gas supersaturation level of only about 1 10%. Tests done in deep tanks and in four-and-one-half meter deep live cages in the river showed that significant mortality still occurred at exposure times as short as six days. Dawley et al. (1976); Ebel (1971). NMFS has determined that "there is no evidence that fish can 'sense' TDG supersaturated water and deliberately sound to compensate". (Biological Opinion at 108). I agree with this conclusion. The authors of the Risk Assessment suggest that fish will detect and avoid supersaturated water by either sounding or moving laterally. There is some evidence that salmonids can avoid supersaturated water by moving laterally to normally saturated water, but this is irrelevant when large areas are supersaturated and there is no normally saturated water to escape to. While fish cannot avoid TDG supersaturation, the normal depth distnbution of salmon does compensate for some excess gas supersaturation. This compensating effect is limited by the fact that a significant portion of migrating juveniles travel in the upper 3 feet of the water column. For example, Smith (1973) found approximately 30% of juvenile chinook salmon in the upper three feet of the water column at Lower Monumental Dam. Dawley (1986) found similar distributions of chinook in the forebay of the The Dalles Dam. It should also be remembered that juvenile salmon, particularly fall chinook juveniles, feed as they move downstream. Most of their food supply appears to be insects and insect larvae which are found at the surface, suggesting that juveniles spend a substantial fraction of the time in shallow water to feed. According to press accounts, gas supersaturation recendy killed a large proportion of juvenile salmon awaiting release in net pens in the Willamette River. Oregonian (1995). ODFW reports that mortality occurred at TDG levels measured by saturometer at 114-117%, and that the effective depth of the net pens was at least six feet. If juvenile salmon could 127 sound to avoid gas supersaturation, the Willamette net pens provided ample depth to compensate for the recorded gas levels and no fish should have died. Indeed, at the bottom of the net pen, juvenile salmon could have compensated for approximately 18% (3% times six) excess gas supersaturation. SpiU Passage vs. Turbine Passage At reasonable levels, spill results in lower mortality to migrating juvenile salmon than passage by turbines or bypass facilities. As set forth below, however, conditions are different at every project. The available data do not suggest that the benefits of passage by spill are sufficiently clear or large to gamble with the known adverse effects of gas supersaturation in the way proposed by NMFS. There is little information available concerning the comparative risk of passage by turbines at Bonneville Dam and passage by spill. Turbine mortality at Bonneville is assumed to be on the order of 12-15% based on an unpublished study in 1952. Holmes (1952). Since 1952, a second powerhouse has been constructed at Bonneville Dam with a more fish- friendly design. Direct turbine mortality at this powerhouse has consistently been estimated at 1-4% - not terribly different than direct spill mortality (i.e.. non-GBT mortality). Ledgerwood et al. (1990); Ledgerwood et al. (1994). Those studies did show very high predation mortality in the river below the second powerhouse which more than offset the benefits of the lower turbine mortality, but the consistent disuse of the second powerhouse has created slackwater conditions favoring resident predators; presumably, consistent use of the second pxDwerhouse would avoid this problem and was in fact recommended by the study authors. Spill mortality at Bonneville is uncertain. The Ledgerwood studies did show lower mortality for salmon passed by spill at Bonneville than when passed through either powerhouse. However, that spill program was specially designed to avoid use of the bays that spill onto large concrete tetrahedrons designed to dissipate the kinetic energy of the water, and involved spill levels that did not generate dangerous levels of total dissolved gas. Dau are available concerning spiU mortality and turbine mortality at other projects. Probably the most serious erron in tne Risk Assessment are in the values used for turbine mortality at these other projects. They use 32 percent for turbine mortality at Ice Harbor Dam. The correct value if 14.5 percent. Thirty two percent mortality was recorded by Long for releases in the backroll. Fifteen percent mortality was cited for Bonneville I. The study by Holmes gave a range of 12-15 percent. Thus 13.5 percent would be a more appropriate value. Eighteen percent turbine mortality is incorrect for Bonneville n. The correct value is 2-4 percent. Not recorded is a turbine mortality of 3.5-9.2 percent for Rocky Reach Dam and 5 percent recorded for Lower Granite Dam. A 27 percent spillway mortality (sieelhead) for Lower Monumental Dam for Bonneville is not mentioned. 128 Adverse EfTects on Adult SaLmonids Past research has shown that high spill at dams may lead to confusing tailwater currents that make it difficult for adults to find fishway entrances. Generally speaking, adult fish passage facilities were engineered on the assumption that a substantial portion of the flow would go through turbines. When spillway fiows exceeded turbine flows at the Snake River dams in the 1960s and 1970s, adverse tailwater currents and delays of adult migrants were observed. Junge (1966); Junge (1971). If the proposed spill levels recommended by NMFS are implemented, confusing tailwater currents may occur, with accompanying delays of migrating adults. Moreover, according to NMFS, spilling at the levels proposed will create gas supcrsaturation in the spillway side of the dain as high as 120% (12 hour average) and 125% (two hour maximum). (Biological Opinion at 106.) Adults exposed to these levels for extended periods of time are likely to suffer gas bubble disease. For example, in 1968, when excess water was spilled at John Day, adults were delayed for several days and a substantial mortality of chinook and sockeye was recorded. The State of Oregon estimated that over 20,000 adult chinook were lost. Beiningen and Ebel (1970). Meekin and Allen (1974) estimated that 6% to 60% of adult salmonids in the middle region of the Columbia River died between 1965 and 1970; carcasses of adult salmon were found in the river when gas supcrsaturation reached 120% or higher. The spill recommended by NMFS would occur from April through August. Endangered Snake River spring/summer chinook adult salmon will be returning during this period of time to pass upstream. NMFS spill plan will expose these adults to elevated gas levels during their entire migration past the eight mainstem dams, but also delay. that migration. Since adult salmon have finite energy reserves, delay in their migration will tend to decrease survival in addition toany survival decrease resulting from gas bubble disease. I note that when the United States Fish and Wildlife Service made its request to increase TDG, they asserted that a cap of 115% measured at the Camas/Washougal monitoring station would equate to approximately 125% TDG in the stilling basin. NMFS appears to assume that measurement of 115% at Camas Washougal will equate to levels of only 120% in the stilling basin. Before embarking on a spill program of this magnitude, it would seem appropriate to understand what levels of TDG will in fact result in stilling basins at given downstream TDG levels. NMFS proposes to measure TDG at the Camas/Washougal monitoring station. The Camas/Washougal station has consistently the lowest TDG measurements at the first three monitoring stations downstream from Bonneville Dam: Warrendale, Skamania, and Camas/Washougal. Bonneville Dam is structured with the first powerhouse on the Oregon side, a man-made island, a spillway in the middle, another man-made island, and the second powerhouse on the Washington side. The second powerhouse is used last, so that most flow will pass through the first powerhouse and the spillway. These flows mix slowly as they 129 pass down the river, which can be seen by comparing the Warrendale (Oregon side) and Skamania (Washington side) measurements; when the second powerhouse is not fully operational, the Skajnania measurements will tend to reflect the higher concentrations from the spillway water. In order to give maximum protection to Columbia River fish and wildlife, it would be prudent to measure TDG at the Skamania station. Traospcrtation as a Passage Alternative In the Risk Assessment, collection and transportation is dismissed as having no value and it is unclear what value screening and bypass systems might have. Sublethal effects of higher than normal TDG levels are not addressed. I understand that this assessment only deals with survival of in-river fish and therefore the effects of transportation are omitted. However, if the goal is to increase adult returns, transportation and its value must be considered. As spill increases at collector dams, fewer fish are transported, thus fewer fish receive the benefit from transportation. The reports by Mundy et al. and the Ad Hoc Transportation Review Group cited to dismiss transportation are seriously fiawed. I am intimately familiar with the transportation studies because I initiated and carried out the first study in 1968 and was either co- investigator in later studies or assisted in planning and direction of the studies. From the first study conducted in 1968 to the present studies underway, the experimental design of the experiments mandates that the primary point of evaluation of adult returns is at the dam where the juveniles were marked and assigned to treatment groups. In addition, the studies were designed with replicates for both transport and control groups so that variance in return rates could be computed for various statistical tests. Thus, data must be treated in aggregate for proper analysis. The Ad Hoc review group chose to separate returns and analyze data from alternative sites such as hatcheries and spawning grounds where in many cases they were analyzing adult returns ranging from 0-15 fish from one or two replicates of one experiment. From this type of analysis they chose to draw their main conclusions, ignoring the main and most valuable data. They also did not review any data obtained prior to 1980. Since 1968, over 29 tests utilizing spnng, summer and fall chinook in transport and control releases have been carried out. All but two of these tests showed a benefit from transportauon. The two that did not show a benefit indicated no significant difference in returns of transported and non-transported (control) fish. There are also some errors and omissions in the Mundy report, but the main fiaw in this report is that the executive summary and conclusion do not always agree with the data and information contained in the text. The executive summary also omits commenting on the fall chmook data from McNary Dam which is clearly in favor of transportation. Generally, the executive summary highlights the negauve aspects of transporution and omits the positive. The quote by the Mundy report: "available evidence is not sufficient to identify transportation as either a pnmary or supporting method of choice for salmon recovery' is simply incorrect. (S^ detailed comments attached as Exhibit A.) 130 The Adequacy of Biological Monitoring Monitoring for visible signs of gas bubble disease is unlikely to provide adequate protection for salmon. By the time gas bubble disease is widely apparent in either the juvenile or adult populations, it is likely substantial losses will have occurred. During the serious dissolved gas problems in the 1960s and 1970s, it was uncommon for large numbers of migrants to be observed with gas bubble disease symptoms. Why NMFS Can Achieve 80% FPE Without the Risk of Elevated TDG NMFS' plan is designed to achieve 80% "Fish Passage Efficiency" or FPE, which is a measure of how many fish pass by a dam by means other than turbines. It is not a measure of how many fish pass the dam alive. For example, with 80% FPE, 20% of the fish would go through the turbines; assuming 10% turbine mortality and zero bypass or spill mortality, 2% of the fish would die, and 98% of the fish would pass the dam alive. When a significant portion of the fish are transported around the dam, the percentage of fish surviving passage around a particular project is even higher. If half the fish are transported, then 99% will pass the project alive (assuming insignificant barging mortality). In the biological opinion, NMFS presents its estimates of the amount of spill required to achieve 80% FPE. NMFS does not present the bases of its calculations. To understand how the amount should be calculated, it is necessary to understand the concept of "Fish Guidance Efficiency" or FQE. Many of the projects have bypass systems to divert juvenile salmon away from the turbines, which generally consist of moving or "traveling" screens. By placing fyke nets behind these traveling screens and testing how many fish get past them, fishery agencies calculate the percentage of fish guided away from the turbines, or FGE. Thus at projects with bypass systems (Lower Granite, Little Goose, Lower Monumental, McNary, John Day and Bonneville), to reach a given level of FPE, one must merely know the FGE, and then spill until the proportion of juveniles passing over the spillway reaches the desired level. For example, if FGE is 50%, and the target FPE is 80%, the amount of spill required to reach 80% FPE is the amount of spill that passes 30% of the juveniles over the spillway. I have recently re-examined the latest data on fish guidance efficiency (FGE) of the traveling screen-bypass systems and some reports on fish passage behavior during periods of spill. I am convinced that the 80% FPE can be achieved at all the dams with bypass systems without exceeding 115 percent TDG in the spillway tailrace. NMFS appears to assume that the number of fish passing by way of the spill is directly proportional to the volume of water being spilled. Several studies indicate that this is most likely not correct (Faurot et al. (1982), Stuehrenberg et al. (1986), and Giorgi gt al. (1988)). In these studies, the effect of spill on juvenile spring chinook and steelhead behavior was examined at Lower Granite and John Day Dams. All indicated that significantly more fish pass via the spillway than the 1:1 ratio apparently assumed by NMFS. 131 For example, at 20 percent spill, 40 percent of the marked fish passed via the spillway at Lower Granite Dam; at 40 percent spill, 60 percent passed via the spillway. Studies at John Day indicated that passage of fish via the spillway was 44 to 56 percent higher than the percentage of water spilled. Considering these studies, and that that the mean FGE of the improved bypass systems at Little Goose, Lower Monumental, McNary, and John Day all exceed 69 percent (Lower Granite 75-77%, Lower Monumental 69%, McNamy 80%, and John Day 72%), a much smaller percentage of the water need be spilled than 80% specified by the Biological Opinion to achieve 80% FGE (Kroma et al. (1986), Ledgerwood et al. (1987), Brege £LaL (1992). McComas et al. (1994)). The Risk Assessment stotes that 30 to 92 percent of the fish pass through turbines even where screening and bypass systems are installed. This is a very misleading statement. As set forth above, the mean FGE is much higher. At dams where turbines are completely screened (Lower Granite, Little Goose, Lower Monumental, and John Day) guidance ranges from 40 to 80 percent for spring chinook, 75 to 86 percent for steelhead, and 25 to 35 percent for subyearlings. Guidance values for Bonneville II are lower, but testing continues there. Some of the recent PIT-tag recovery information indicates that the FGE values measured during the studies cited may be too high and the real FGE may be closer to 50% at Little Goose and Lower Monumental Dams. Even accepting these lower FGEs as accurate, given that 40% of the fish will pass at 20% spill, it appears unlikely that TDG of 115% percent in 'the tailrace need be exceeded to achieve 80% FPE. This is apparent from an examination of the data concerning specific projects. For example, at Lower Monumental Dam, where the lowest FGE occurs, 15% spill would achieve 80% FGE. Thus, at 100 thousand cubic feet per second (kefs) river fiow, only 15 kefs spill would be required. Based on the rating curves for spillway defiectors, this level of spill would probably not exceed 110 percent TDG. At Lower Granite Dam, fish guidance efficiency appears to range from 50% early in the season to 80% late the season. Early in the season up to 40 kefs spill may be required to achieve 80% FPE, but if one considers the studies cited earlier, 20% should be more than sufficient. As the season progresses, this spill could be reduced and 80% FPE could still be achieved. At Bonneville FGE for spring migrants is about 50%. Again 115% TDG does not need to be exceeded to achieve 80 percent FGE. The only dam where an FPE of 80% percent may not be achieved by maintaining the tailrace concentrations at or below 1 15 percent TDG would be Ice Harbor. The efficiency of the sluiceway at the Dalles Dam without any screens is near 50 percent. Because of the configurations of the dam, small volumes of spill there can pass a 132 high percentage of fish. Again 1 15 percent does not need to be exceeded to provide reasonable fish passage conditions. CoDclusioD I see little merit in spilling up to 120% TDG at all dams, when I consider the above facts. The risk of GBT to both adults and juveniles at 120% TDG at all dams for the long duration proposed (April 14 to August 31) outweighs the possible benefit of improved FPE. I recommend that the Commission and the Department deny NMFS' request, and would restrict tailwater TDG concentration to a maximum of 115%. Sincerely, Wes Eb^ 133 References Beiningen, K.T. and W.J. Ebel. Effect of John Day Dam on dissolved nitrogen concentrations and salmon in the Columbia River. Trans. Am. Fish. Soc. 99:664-71 (1970). Blahm, T.H. Report to the U.S. Army Corps of Engineeers: Prescott Facility. NMFS CZES (1974) Blahm, T.H., R.J. McConnell & G.R. Snyder. Errect of gas supersaturated Columbia River water on the survival of juvenile Chinook and coho salmon. NOAA Technical Report SSRF- 688 (1975). Brcgc, Dean A., Stqjhen J. Grabowski, William D. Muir, Steven R. Hirtzel, Steven J, Mazur, and Benjamin P. Sanford, 1992. Studies to Determine the Effectiveness of Extended Traveling Screens and Extended Bar Screens at McNary Dam, 1991. CZESD, NWAFC, NMFS, NOAA, 2725 Montlake Blvd. East. Seattle, WA 98112. Dawley, E.M. and Ebel, W.J. Effects of Various Concentrations of dissolved Atmospheric Gas on Juvenile Chinook Salmon and Steelhead Trout, Fishery Bulletin: Vol. 73, No. 4, 1975. Dawley, E.M., Schiewe, M., and B. Monk, 1976. Effects of long-term exposure to supersaturation of dissolved atmospheric gases on juvenile chinook salmon and steelhead trout in deep and shallow tank tests. In: Gas Bubble Disease. D.H. Fickeisen and M.J. Schneider (eds.), pp. 1-10. CONF-741033. Technical Information Center; Oak Ridge, Tennessee. Dawley, E.M. Effects of 1985-86 Levels of Dissolved Gas on Salmonids in the Columbia River. Final Repon of Research Financed by U.S. Army Corps of Engineers Contract DACW57-85-F-0623 (November 1986). Ebel, W. Dissolved gas concentrations m the Columbia and Snake Rivers in 1970 and their effect on chinook salmon and steelhead trout. NOAA Tech. Rep. NMFS SSRF-646 (1971). Ebel, W. Letter to R. Baumgartner (Oregon DEQ) (Feb. 13, 1995). Faurot, David A., Lowell Stuehrenberg and Carl Sims, 1982. Migrational Characteristics of Juvenile Steelhead Trout in the Columbia River System 1981. Volume II Radio Tracking of Juvenile Salmonids in John Day Reservoir. CZESD, NWAFC, NMFS, NOAA, 2725 Montlake Blvd. East, Seattle, WA 98112. Giorgi, Albert E., Lowell Stuehrenberg and John Wilson 1988. Juvenile Radio-Tag Study: Lower Granite Dam, 1985-86. U.S. Department of Energy, BPA, Division of Fish and Wildlife and CZESD. NWAFC. NMFS. NOAA. 2725 Montlake Blvd. East, Seattle, WA 98112. 10 134 Johnsen, R. & Dawley, E.M. The effect of spillway flow deflectors at Bonneville on total gas supersaturation and survival of juvenile salmon. Report to the U.S. Army Corps of Engineers, Contract No. DACW-57-74-F-0I22 (December 1974). Junge, CO. Indications of Loss and Delay to Adult Salmonids Below Ice Harbor Dam (1962-66). Report prepared for Oregon Fish Commission, Portland, 1966. Junge, CO. Effect of Peaking Operation on Passage of Adult Salmonids over Columbia River Dams. Report prepared for Oregon Fish Commission, Portland, 1971. Kroma, Richard F, Dean A. Brege, and Richard D. Ledgerwood, 1986. Evaluation of the Rehabilitated Juvenile Salmonid Collection and Passage System at Jobn Day Dam- 1985. CZESD, NWAFC, NMFS, NOAA, 2725 Montlake Blvd. East, Seattle, WA 98112. Ledgerwood, Richard D., George A. Swan and Richard F. Kroma, 1987. Fish Guiding Efficiency of Submersible Traveling Screens at Lower Monumental Dam- 1986. CZESD, NWAFC, NMFS, NOAA, 2725 MonUake Blvd. East, SeatUe, WA 98112. Ledgerwood, R.D., E.M. Dawley, L.G. Gilbreath, P.J. Bentley, B.P. Sandford & M.H. Schiewe. Relative survival of subyearling chinook salmon which have passed Bonneville Dam via the Spillway or the Second Powerhouse Turbines or Bypass System in 1989, with Comparisons to 1987 and 1988. NMFS CZESD (July 1990). Ledgerwood, R.D., E.M. Dawley, L.G. Gilbreath, L.T. Parker, B.P. Sandford & S.J. Grabowski. Relative survival of subyearling chinook salmon at Bonneville Dam, 1992 (1994). McComas, Lynn R., Benjamin P. Sanford, and Douglas B. Dey, 1994. Studies to Evaluate the Effectiveness of Extended-Length Screens at McNary Dam, 1993. CZESD, NWAFC, NMFS, NOAA, 2725 Montlake Blvd. East, Seattle, WA 98112. Meekin, T.A. and Allen (1974) Nitrogen saturation levels in the mid-Columbia River, 1965- 1971. Washington Department of Fisheries Tech. Rep. 12:32-77. J. R. Smith, "Distribution of Seaward-Migrating Chinook Salmon and Steelhead Trout in the Snake River above Lower Monumental Dam", Marine Fisheries Review, Vol. 36, No. 8, August 1974. Schiewe, M.H. Influence of Dissolved Atmospheric Gas on Swimming Performance of Juvenile Chinook Salmon. Transactions of the Amencan Fisheries Society 103:717-721. Siatick, E., L.G. Gilbreath. J.R. Harmon, CS. McCutcheon, T.C Bjomn and R. Ringe. Imprinting salmon and steelhead for homing. NMFS report to BPA, Contract No. DE- A179-82BP39636 (September 1984). II 135 Stuehrenberg, Lowell C, Albert E. Giorgi, Carl Sims, Jane Ramonda-Powell and Jay Wilson, 1986. Juvenile Radio-Tag Study: Lower Granite Dam, 1985. CZESD, NWAFC, NTvlFS. NOAA, 2725 Montlake Blvd. East, SeatUe, WA 98112. U.S. Environmental Protection Agency. Quality Criteria for Water, 1986. EPA Document No. EPA440/5-86-001 (May 1, 1986). 12 136 Exhibit A Specific Comments on the Risk Assessment Document P. VI. Par. 2. Line 6: 30 to 92 percent is misleading at dams where turbines are completely screened (Lower Granite, Little Goose, Lower Monumental and John Day). Guidance ranges from 40 to 80 percent for spring chinook, 75 to 86 percent for steelhead and 25 to 35 percent for sub- yearlings. Guidance values at Bonneville second powerhouse are lower, but testing continues there. Guidance values for Bonneville First Powerhouse are similar to the upstream dams. P. VT. Par. 3. Line 6: Research carried out in the 1960's, 1970's and 1980's (Bjomn 1992) indicated high spill delays adult migrants. Observation of pre-spawning mortality during periods when gas levels ranged between 120 and 125 percent (p. 29) seem to refute this statement. P. 4. Par. 2. Lines 8 and 9: The direct and indirect mortality components are not known for bypasses except for the data obtained at Bonneville Dam. P. 5. Par. 2. Line 3: The turbine range 8-32 percent is not correct. See later comment page 30. P. 5. Par. 3. Lines 1-3: See comment P. VI, Par. 2, Line 6 above. P. 5. Par. 3. Line 4: There are no data to support this contention. In fact, data shows that stresses encountered in the bypasses are completely alleviated during holding and transport (Maulo si aL (1988) and Congelton et al. (1984)). P. 5. Par. 3. Line 2: This was true because mid-Columbia dams do not have bypass systems nor do they collect and transport. 13 137 p. 5. Par. 3. Lines 4-6: Hilbom found this relationship for the same reason Raymond did. Petrosky's analysis is flawed because he does not account for fish transponed. How does one know whether the high return rates were not due in large part to transport? In 1983, over 6,000,000 fish were transported. There is no disagreement over the fact that low adult returns result from extreme low flow years such as 1973 and 1977. Fish amving at Lower Granite Dam were in very poor condition in spite of the fact that no dams had been encountered before their arrivals. P. 5. Par. 3. Last Line: Same comment at P. VI, Par. 3, line 6. P- 7. Par. 2: It is conceded that juvenile salmon receive compensation because of their normal depth distribution, but it isn't sufficient to completely avoid symptoms of GBT (gas bubble trauma) or mortality. Intermittent exposure is irrelevant to juvenile migrants. Once the fish are in a block of supersaturated water they have no means of recovering in unsaturated water. P. 7. P^, $: Throughout the duration of the studies done by Meekin and Turner and Weitkamp and concentration of TDG were nearer 120 percent than 126 or 128 percent. The high concentrations of the 126 and 128 percent occurred only on one day of the tests. Considering the clear water (fish tend to be deeper in clear water, Dawley et al., 1975) and the duration of the tests, I would not expect mortality. They do not refer to a test done in the Snake River where concentrations of TDG were 127 percent for the entire duration and 48 jjercent mortality occurred in the volitional cage 4.5 m. deep. P. 8. Par. 3: Both the Ad Hoc Transport group report 1992, and the Mundy et al. 1994 repon are seriously flawed. There are some errors and omissions of data in the Mundy report, but the main flaw in this report is that the executive summary and conclusions do not always agree with data and information contained in the text. There are criticisms of the experimental design throughout the report. Appjarently the review group was not aware of the fact that many elements of the experimental design are dictated by the agencies. Such things as numbers of fish marked and location of releases were usually changed or regulated by sute and tnbaJ agencies. For example, on several occasions NMFS was not allowed to mark any experimental releases. The executive summary also omits commenting on the fall chinook data from McNary Dam which is overwhelmingly in favor of transportation. Generally, the executive summary highlights the negative aspects and omits the positive. The quote by the 14 138 Mundy report: 'available evidence is not sufficient to identify transportation as either a primary or supporting method of choice for saJmon recovery" is simply incorrect. See my detailed comments attached regarding the Ad Hoc Transport group report. P. 8. Par. 4. Last Line: Mundy's statement is incorrect. No controls returned from the groups marked, but 9 marked transported fish returned to Lower Granite Dam when trap efficiency was only 12 percent and 24 to upstream hatcheries. No statistical analysis was done because no controls returned. It is likely that if smolts had not been transported in 1977 no adults would have returned from that year's out-migration (Park et al. 1980 and 1981). P. 9. Par. 1. Line 8: "Physiological stress, such as that associated with transportation operation and salt water transition --." They should add: "and passing over spillways." There is no reason to suspect that passing over a high spillway does not cause stress! P. 9. Par. 4. Line V. ' ' 9mk comment as dbovt (p. 9, par. 1, line 8). P. 14. Par. 2. Line 8: There are numerous other studies that are also used. P. 20. Par. 4. Line 2: Lateral avoidance apparently does occur but this is irrelevant when there is no normally saturated water to escape to. P. 27. Par. 3. Line 2: The higher juvenile recovery proportions are based on adjustments for spill but not for fish guidance efficiency. Fish guidance efficiency must be adjusted, if for example, more turbines are placed on line during high fiow periods. Again, adult returns could be in part due to the proportion transported especially if fish were in better condition in higher flow years. P. 28. Par. 1. Line 9- It appears the modelers must have given more weight to the in-situ experiments that showed lower mortality rates. In figure 5, page 42, there are several observations above the mortality line between 120 and 130 TDG. 15 139 p. 30. Table 4: Some values are incorrect. Ice Harbor (1968) was 14.5 percent not 32 percent. 32 percent was recorded for releases in the backroU of the turbine discharge. Bonneville first powerhouse mortality estimate was 12-15 percent so 13.5 percent would be a more appropriate value. The Lower Monumental data was for 1975, not 1972. This same expenment indicated 27 percent mortality for steeihead passing over a standard spillway. It is interesting that they chose not to use this value. The value quoted for Bonneville II of 18 percent is not appropriate. This was based on only one year of adult returns. The adult returns were not sufficient from that one year of returns to conclude anything. The appropriate data to use is the combined juvenile recoveries from all years. When this is done the mortality ranges from 2-4 percent (Gilbreath et al., 1993 and Dawley et al., 1994). The value of 18 percent for turbine mortality obtained in 1993 should not be used. The study was designed mainly to determine if estimates of turbine, spill, and reservoir mortality could be accurately estimated. Experimental difficulties in 1993 may have compromised this estimate of turbine mortality. A revised, more accurate estimate will be available for the 1994 data. Not recorded is a turbine mortality 3.5 - 9.2 percent estimated by RMC 1994) at Rocky Reach Dam and 5 percent estimated by RMC (1994) at Lower Granite Dam. P. 30. Par. 2. Line 1: Smolt passage index. There are serious problems in using the smolt passage index to develop reasonably accurate population estimates because the method does not account for seasonal changes in FGE (fish guidance efficiency) which varies considerably through the season and numbers collected also vary drastically depending on volume of spill. Assuming a 1:1 ratio of spill volume to fish passage and a constant FGE for the season for each species results in significant error. The smolt passage index is useful for comparison between or among years, but could result in substantial errors, in estimating population at various locations (dams) in the river. P. 43. Par. 3. Line 1: In light of some of the errors (i.e. turbine mortality, FGE, and spillway mortality) noted in values used in the risk analysis, I don't believe this is very accurate. P. 56. Par. 2. Depth Distnbution: Adults may remain at sufficient depth to compensate for fairiy high levels TDG, but the fact remains that mortalities do occur when there are delays in migration and adults are seeking fishway entrances. Even if there are minimal delays, adults must ascend t a maximum of 6 feet of depth to enter and pass up the fish ladders. 16 140 p. 66. Par. 4. List of Activities: Otie important research activity that was recommended by the NMFS working group of experts was research to determine the quantitative relationship among visible signs of GBT and direct effects (mortality) and indirect effects such as disease resistance and ability to avoid predators. This is extremely important information that is needed to determine what various symptoms of GBT mean when they become evident in the fish. 17 X 141 Phillip R. Mundy, PhD Fisheries and Aquatic Sciences 1015 Sher Lane Lake Oswego, OR 97034-1744 503-636-6335, Voice or facs, auto-switch July 7, 1995 COPY FOR ATTACHMENT TO TRANSCRIPT The Hon. Dirk Kempthome. Chairman Subcommittee on Drinking VV ater. Fisheries and Wildlife C ommittee on Ln\ ironment and Public Works L nited States Senate Washington, D( 20510-6175 RK Response to \our request for comments on the role of scientific peer review in the implementation of reco\ erN actions for endangered salmon Dear Senator Kempthome As chair of the oxersight hearing of Thursday. June 22nd, 1995, on the National Marine Fisheries Ser\ ice policv on spills at Columbia Ri\ er hydropower dams, gas bubble trauma in threatened and endangered salmon, and the scientific method used under the Endangered Species Act which resulted in the spill policy, you in\ited me, as a member of the scientific panel, to submit wiitten comments on how to impro\e the process of applying science to recovery actions for endangered salmon Vly comments are as follows. The problem of getting a workable salmon reco\ei> plan in place is not one of the nature and origin of scientific expertise, but of forming the appropriate institutional structure As recognized by the Snake Rner Salmon Recoveiy Team, among others, factionalism and controversy in the salmon recovery program are guaranteed by the wide variety of federal, state, and tribal agencies now assigned to implement various pieces of the salmon recovery program. Fnsunng that the salmon recovery plan is scientifically well grounded means de\ eloping an institutional structure that both requires, and enables, the monitoring, analysis and research to conform to relatively simple, yet clearly articulated, recovery objectives. During my service as a scientific peer reviewer to the Exxon Valdez Oil Spill (F\ OS) Trustee ( ouncil in Anchorage (907-278-8012, Molly McCammon. Executive Director), I have watched the oil spill peer rev ievv process evolve from a role of seizing litigation to one of sers ing policy makers in shaping the scientific content of salmon restoration activities The basic elements of both Endangered Species .Act (ESA) salmon recovei> and the EVOS programs are the same; many millions of dollars are paid annually to state and federal agencies for implementation of a salmon recovery program (E\ OS addresses restoration of oil-injured species in addition to salmon) The two main institutional advantages of EVOS over the ESA salmon recovery are that 1 ) all science 142 Senator Kempthorne Scientiric peer review in the recovery of endangered salmon COPY FAS - July 7, 1995 - Page 2 projects must pass through an independent peer rev iew process before they are 2) considered for funding b\ a single bod\ of go\ emmental representatives, the Trustee Council. The EVOS peer review examines two basic questions. 1 ) Is the proposed project consistent with restoration objectives established b\ the fiiistee Council'.', and 2) .Are the proposed scientific methods likely to deliv er the product intended'' C ombining experiences with the hVOS Trustee ( ouncil those of the Columbia Riv er basin. I see the elements of an institutional structure to serve endangered salmon recov ery as follows; A. Consolidate federal expenditures in the C olumbia Basin for salmon recov ery into one Salmon Recovery Fund. B .\nnually publish a request for proposals (RFP) to implement salmon recov ery which explains the objectives of salmon recovei^ The RFP is based on the federal salmon recovery plan which shows due deference to the salmon recovery plans of state and tribal governments; the Fish and Wildlife Program of the Northwest Power Planning Council, and the Tribal Recovery Plan of the Columbia River Inter- Tribal Fish Commission. C. Annually send all responses from state, federal, tribal, univ ersity. and other sources through an independent scientific peer rev iew process which certifies the extent to which each proposed project supports recov ery objectiv es, and constitutes scientific methods appropnate to the proposed tasks. D. Forward the proposals which pass peer review to a council of trustees of the Salmon Recovery Fund, composed of agency repi esentativ es, who dev elop an annual program based on av ailable resources from among those projects which have passed peer rev iew. Creating such an institution and process would clearly take much effort and substantial re-direction of fiscal resources. However, having an appropriate institutional structure and process would go a long way toward effectively focusing expenditure of public monies on achieving salmon recovery objectiv es It would also prov ide a regional forum for evaluating the science applied to salmon recov ery actions. Such a regional forum could draw on scientific expertise from anywhere, as required by the circumstances. Please call on me if I may be of further service. Sincerely, COPY Phillip R. Mundy. PhD 143 Phillip R. Mundy, PhD Fisheries and Aquatic Sciences 1015 Sher Lane Lake Oswego, OR 97034-1744 503-636-6335, Voice or facs, auto-switch July 13, 1995 ORIGINAL FOR ATTACHMENT TO TRANSCRIPT The Hon Dirk Kempthonie. Chairman Subcommittee on Drinking V\ ater. Fisheries and U ildlife Committee on En\ ironment and Public Works L nited States Senate U'ashmgton, D.C. 20510-6175 RE: Additional comments from in response to your request for comments on the role of scientific peer review in the implementation of reco\er\ actions for endangered salmon. Dear Senator kempthome: As chair of the oversight hearing of Thursday. June 22nd. 19Q5. on the National Marine Fisheries Ser\ ice policy on spills at Columbia Ri\ er hydropower dams, gas bubble trauma in threatened and endangered salmon, and the scientific method used under the Endangered Species Act which resulted in the spill polic>. \ou in\ited me. as a member of the scientific panel, to submit written comments on how to impro\ e the process of applying science to recovery actions for endangered salmon In response. I submitted a set of comments directl> to your office earlier this month. As additional commentary on how to focus the best science on endangered salmon recovery actions. I am attaching comments from Nanc> M Vlundy. MPA Ms. Mund\ is a PhD candidate in Public Administration at Portland State L ni\ ersity who is preparing a dissertation on how governmental institutional structure may hinder implementation of endangered species recovery measures. Thank > ou for the opportunity to comment. Sincerely. Phillip R Mundy. PhD /Attachment 144 Thousands of Adults T3 c 03 ^ CM 'o cp ^^ to CO h- 0) O) >, "^ c E o . O Art E ^ 2 CO ■D .95Q a> F Q) o ^ c «^ E i o 2 -J E ^ o *^ ^ j^ o ^ o ■p -i= o m OJ c O ^ JZ ^^ " ^ ^ E 5 ^ E CO © c ^ CO CO o o o CO o CM 0 O) CO C g E ■•— « o o E CO in CO CNJ paiJodsuBJi suojiiiiAi 145 Thousands of Adults § E CT CO 0 Q (O JD ^ M- c .9 Q) Q. TO •5 '^ ^ ^ oE CD E O '= =5 "Si ^ 0) 5 i_ 1— ^ _l CD ^ CNJ o Oi 00 00 00 00 CO 00 CO 00 CO 00 CM 00 00 o 00 00 CO o 00 o CD o o CVJ o o o CO o CD o o CvJ CO c CO "E o 4— » o E CO (sp>i) 96jBL|0S!a ueaiAj 146 Analysis of Snake River Spill Information Based on the CRiSP Research Project remarks by Dr. James Anderson Associate Professor School of Fisheries and Center for Quantitative Science University of Washington Seattle, Washington before the United States Senate Fisheries, Drinking Water and Wildlife Subcommittee Hon. Dirk Kempthorne, Chair June 22, 1995 147 Sntkt Rlv*r Spill Analysis of Snake River Spill Information based on the CRiSP' research project James Anderson University of Washington The impacts of the 1995 Snake River Spill actions were analyzed with the CRiSP smolt passage model. The CRiSP model considers mortality associated with dam passage and gas bub- ble trauma produced from spill-generated gas supersaturation. In addition, the model considers the effects of fish depth and exposure time on the gas bubble trauma. The model was calibrated with a variety of data sets and model predictions were checked against independent data in a model validation (page 2). A model sensitivity analysis indicated that spill can have a small benefit on in-river pas- sage if the total dissolved gas level is below 120% supersaturation. Above this level the mortality from gas bubble trauma is significant. Under the current assumptions on transportation of fish, spill at collector dams has no benefit since the survival of transported fish is larger than the sur- vival of fish passing in-river (page 3). The 1995 spill actions and monitoring studies were analyzed with CRiSP. The model pro- duced levels of mortality similar to those observed in the cage studies below Ice Harbor dam. The model indicated that survival between Ice Harbor Dam tailrace and Bonneville Dam trailrace was between 31 and 34% depending on the depth of fish passing through the river. In comparison, with no spUl the predicted in-river survival was 35% (page 4). Monitoring of fish passing in-river has revealed few signs of gas bubble trauma and the CRiSP modeling has likewise predicted little impact. Furthermore, model analysis indicates that the small increase in dam survival resulting from the spill program was negated by a small increase in mortality from gas bubble trauma. Uncertainty exists as to the precise levels of the fac- tors, but given the available information the result of the spring 1995 spill program was most likely small and negative. 1. The University of Washington has developed the Columbia River Salmon Passage model under funding by Bonneville Power Administration, The project began in 1989. 2. Dr. James J. Anderson is an Associate Professor in the School of Fisheries and Center for Quantitative Science at the University of Washington. His work on salmon issues has been funded by Bonneville Power Administration and the Army Corps of Engineers. The views in this document are a result of that research. This paper was supponed by the Direct Service Industries, Inc. Ja/^M Anderson Un»v*rvty 01 Wa&^u^glon A,"* 22. 199S 148 Snike RIvc Sp Spill as a recovery action Spill is used to pass fish over dams. This reduces total mortality in dam passage since mortality resulting in passage by spill is less than passage resulting through turbine passage. Tailwater Bypass Turbine Spill also produces gas supersaturation in the water downstream of dams. Fish exposed to the supersaturation suffer some additional mortality from gas bubble trauma. The amount of mortality depends on: •level of gas supersaturation •length of time fish are exposed to supersaturation • depth of fish in the reservoir Jemes ArxJonon UnlverEiTy of Wathlngion 149 Snak* RIvtr Spill The results of spill Spill has counteracting effects: • (+) Fish survival in spill passage is higher than in turbine passage. •(-) Spill increases gas supersaturation in tailwaters and reservoirs. • (-) Gas supersaturation in water kills fish downstream of dams. • (-/+) Spill at transport dams lessens the fraction of fish transported, which, under current assumptions of transportation, lessens total survival. 100 110 120 130 Nitrogen Saturation {%) CRiSP-predicted survivals with spill-produced gas levels The dashed line indicates forebay and tailrace gas levels allowed in the NMFS spill plan. The solid lines indicate the range of total dissolved gas below Ice Harbor Dam in the 1995 spill program. Jam»( Arvl«r«on Unfversity of Washington Juno 22. 1395 150 ■ Snak* RIvar Spill CRiSP predictions and cage studies For the period June 9 to 13, 1995, the observed mortality in the cages downstream of Ice Harbor Dam were 88% in the 0 to 1 meter cage and 57% in the 0 to 4 meter cage. CRiSP-predicted mortalities were 94% for the 0 to 1 meter cage and 41% for the 0 to 4 meter cage. Cage study to assess mortality CRiSP mortality 41% Observed mortality 57% CRiSP predicts higher in-river survival with no Snake River spill. Z Cage study' O SQ ^.->^ - ^-^ 130% TDG 108% TDG 35% survival with no spill in Snake River 34% survival with current gas levels and fish depth 30 ft. 31% survival with current gas levels and fish depth 10 ft/ TDG = total dissolved gas under 1995 spring spill program James Anderson Unlverwly of Washington June 22. 1995 151 Gerald R. Bouck. Ph.D.. Consulting Aquatic Biologist 9691 SW Alsea Dr., Tualatin, OR 97062 (503) 692-4907 June 20, 1995 Honorable Dirk Kemptliome and Hany Reid. Senate Subcommittee on Drinking Water, Fisheries, and Wildlife. 415 Hart Senate Office Building, Washington. D.C. 20510 Dear Senators Kempthome and Reid: 1 appreciate the opportunity to present my views regarding oversight of tiie National Marine Fisheries Service's (NMFS) policy on spills at Columbia River hydropower dams, gas bubble trauma (disease) in tlireatened and endangered salmon, and the scientiflc method used under tiie Endangered Species Act. By way of introduction. I retired as Senior Fisheries Scientist in April, 1994 from the Division of Fish and Wildlife. Bonneville Power Administration. Most of my 31 years of Federal Service were spent researching the water quality requirements of Columbia River Pacific salmon, either in tiie Environmental Protection Agency (EPA) or the U.S. Fisli and Wildlife Service (USFWS), 1 have publislied over 20 articles specifically concerning dissolved gas effects on fish, and I have provided free consultation to numerous persons and institutions both across the United States and around the world. At BP.A my work concerned salmon hatcheries, habitat, and fish health. I received both a Gold and a Siher Medal from the EPA for my work on gas supersatiu-ation and salmon, a special achievement award from the USFWS for my work on measuring dissolved gases, a BPA Administrator's award for achievement in envirorunental protection, and at my retirement the BPA Administrator's award for Distingviislied Service. 1 8er\'e on tiie National Marine Fisheries Service's (NMFS), Northwest Fisheries Center, Advisory Panel On Gas Bubble Di*ease and Supersaturahon. This Panel has provided NMFS witii recommendations on several issues, but we have not been asked to re\iew the Fisli Passage Center's Spill and 1995 Risk Management Analysis (dated L 17,95), the NMFS's 1995 Biological Opinioa or the draft Snake River Salmon Recovery Plan. Your questions and my specific comments are as follows: 1. Are the benefits of using spill as a flsti passage mechanism established, especially in relation to other fish pa.isage mechanisms? What is the scientific validity of the National Marine Fishertes Service (NMFS) spUl policy? No 1 believe that definitive data from field studies of spill benefits are lacking, and therefore, it isn't clear whether spill per se actually recmits more adult salmon (or 152 steelhead), tiaan would be flio case without spill, given otherwise comparable conditions, bi my risk analysis in Question s* 3, I estimate that spill is, on balance, hurting survival. The benefits of spill will be a difficult problem to research and resolve, mainly because the calculated incremental survival benefit of spill (assuming uo mortality from gas) is a small percentage of the total run (ca. 1-3 %). The basic experimental design to test this has been worked out over man>' years and generally requires about 10 years to complete from beginning to end. Perhaps for this reason. NMFS has not de\'eloped a similar experimental design to evaluate spill, despite millions of smolts available at federal hatcheries in the Snake and Columbia Rivers. As a general rule, these evaluations require smolt releases from at least four consecutive brood years, each having marked experimental and control groups, each group with two or more replicates, and each replicate with about 100,000 smolts. This design is necessary to estimate variation within and between years, and thus form the confidence intervals about tiie mean for the experimental and coiitrol group. Since variation expands the confidence interval, and since variation is usually high, differences of less than 5 % survival are not likely to be statistically significant. This alone may preclude evaluation of spill, .^s an altemati^'e to the nece8.saril>' long and difficult experiment, some entities have addressed the spiil/gns evaluation problem using laboratory data and computer modeling of various schemata. Many of these analyses are filled witli good intentions, but bad assumptions. For example, the Fishen' Agencies make the unwarranted assumption ih^X all fish will detect and avoid gas supersaturatioii. This assumption must be rejected because several reports document that supersaturation has killed large numbers of wild lish in areas where the fish could tiave sounded to e.sc:ipe the excess gas. If supersaturation avoidance exists in Nature, it is cenaini\' unreliable and untrustwortln', Unfortunately, the resulting and often bitter debate-? over the validity of models, assumptions, appi-opriateness of data, and accuracy of results simply demonstrates that no consensus exists in the scientific community on the potential^j^enefits of spill, except as dictated by agency policy. \ The NMFS policy on spill may represent a well intended preference, but it is not science. Tlie NMFS spill policy puts the entire river at risk, and itb monitoring and evaluation is inadequate to lest whether spill will benefit or depress imolt survival, NMFS apparently hasnt developed a research hypothesis for testing, criteria for judging the resulting data, or a coherent step down plan with protocols for acquiring tlie critical researcli data. The result is a hodge-podge of e.\panded ongoing efforts cy various agencies who avoid peer review and work mostly in camera (secret). The physical gas monitoring is pioviding a glut of expensive but unreliable information which does not appear to be connected to administrati\'e mechanisms for triggering lower gas levels. NMFS's biological monitoring of gas bubble disease is adequate to detect a serious fish kill, but it is inadequate to reveal a low or indirect moitalitN', and tlie investigative approaches and methodology skew dovmward the apparent incidence of GBD. 153 3 Historically, spill at dams has been a sword of Damocles and is a world wide problem. NMien the Columbia River dams were first constructed, heaw involuntary spill was unavoidable. For example. Bonne\-ille Dam became operational in 1938, but it's first powerhouse could only pass 85 kefs — a small fraction of tlie remaining flows and floods — hence the rivei- was mostly spilled and supersaturated. By tlie eaih' 1940's, biologists associated high flows witli excessive mortalit)-, but didn't know why it happened. After about 20 years of investigations, it was proven by Dr. Ebel that spill supersaturated tlie water and tliia killed the salmon. By 1968 excessive supersaturation killed ca. 20,000 adult salmon at John Dav Dam and this shocked tiie Region, NMFS soon announced that gas supersaturation was endangering the salmon runs. E\entually a gas standard of 1 10 °/o was adopted and spill was gi'eatly restricted or nonexistent, The region relied upon previously tested smolt collection and transportation via barges. With the passage of the Northwest Electric Power Planning and Conservation Act in 1980, tiic Northwest Power Planning Council created a water budget for augmenting spring flows. If any was to be spilled, we assumed that llie enviromnental and fishery agencies would hold gas levels to safe limits, i.e. close to 1 10 % of barometric pressure. This as.sumption proved incorrect and supersaturation in the range of 120-130 % quietly returned to the Snake and Columbia Rivers. By 1992. hydro operators were faced with a dilemma: spill as requested and possibly kill endangered salmon, or don't spill and have their operahon i-uled to be jeopaadizing endangered salmon. Fishery agencies requested suspension of the gas supersaturation standard, and this forced public hearings. Therefore tiie gas supersaturation problem has become deja vu all o\er again. 2. What independent scientific research Is being conducted to monitor the effects of spill and its alternative In the Columbia River system? Please comment on the results of relevant studies. Ver\' little independent research is being conducted on any aspect of spill or Columbia Ri\'er salmon. This is because thoro is little opportunity for independent researchers to tap the S400 million dollars' year tliat are being spent on salmon by the Corps, BP.A, NMFS, and NBS. Federal planning processes and difficult procurement regulations effectively preclude open, competiti\'e procurement of most fisher>' projects. Contracting between fishery agencies (via interagency transfers and memos of aVjeement) is typical and far easier than contracting outside tlie govw'mment. Thus, fishery agencies have an enormous ad\antage o\er the private sector in si.curing funds because the> idenrifv- regional fishery research priorities, they can claim any project as their business, and tliey lia\e the resources of the tax payers. The result i^ essentially a closed shop tiiat greatly minimizes participation by uni\ersilies and pri\ate enterprise. If the Senate wishes to expand the role of indeptndent research (private or university') in tlie Columbia and Snake Rivers, adjustment^ will be necessary in the Federal .Acquisition Regulations (FAR) and tlie Bonneville Power Administration Procurement histructions (BPPI). Additionally, inceiirives are needed to encourage the cooperation and collaboration of fishery agencies with independent investigators. 154 3. Are there risks to migrating smolts and returning adults associated with high levels of dissolved nitrogen resulting from spill? Absolutely! I believe that uurroiit dissolved gas levels are directly and indirectly killing salmon smelts in numbers greater tl\an tlie incremental survival benefit from spill. However, I doubt diat tiie smolts typically die directly from gas bubble disease per se; rather, gas bubble disease-weakened smolts are probably eaten rapidly by predators, Gas bubble disease signs are likely to be found in only 1 % of tiie smolts or less at any given time, because they are continuously removed from the river by predators and digested. Thus, predators remove evidence that a supersaturation problem exists, much to the frustration and confusion of all concerned, and we are asked to demonstrate and display that which no longer exists. Additionally, this syndrome makes it esseptiallv impossible to accurately monitor the impact of gas levels from dmns. EPA and several states adopted a dissolved gas standard not to exceed 1 10 % of barometric pressure which is roughly equivalent to 75 mm Hg or 1.5 psi above barometric pres-ture. 'fhis criterion was supported by the National Academy of Sciences, and tiie NMFS's Panel on Gas Bubble Disease. Oregon and Washington granted a variance that allows gas levels in the river to average 120 % in the spill and 1 15 % well down river, but in fact, extensive area exceed these levels, and tlie Corps have been sent letters of non compliance from Oregon and Washington. I approach the risk analysis for .smolts differently than state fishery- agencies. First I estimated tiie proximate portion of the smolt population that spill could benefit at a hypothetical dam, assuming no mortality' related to spill or gas supersaturation (equation 1 below), I assumed tliat spill would increase non turbine passage or fish passage efficiency (FPE) from a conservative low of 60 % to a typical goal of 80 % (equation 2 below), altiiough a rise from 70 % to 80 % would be more typical. I also assimied tliat smolt survival in turbines would be 85 "/o (altliough recent studies support higher survival) and that smolt survival via non turbine routes would be 98%, botii being ft-aditional values. Therefore: smolt survival at 60 % FPE = (0.85 X 0.4U) + (0,98 X 0.60) = 92.8 %; (1 ) and smolt survival at 80 % FPE - (0.85 X 0.20) + (0,98 X 0.80) = 95.4 <>b. (2) The potential benefit of spill at 80 % FPE is equation (2) minus (1) or 95.4% - 92.8 % = 2.6 % higher survival per day (3). Thus an 80% FPE might result in 2.6 % higher survival, while a 70'5b FPE would only result in 1,3 "'o higher smolt survival (but 70 "/o FPE usually doesn't require spill to achieve it). I believe this calculation illustrates the problem and applies to most Columbia River danis. Next I estimated ttie potential adverse impact of gas supersatiiration. Put simply, what is the risk tliat gas supersaturation would kill 3 "o of the smolts per da>, either directly or indirectly, and therefore destroy the potential benefit of spill? To assess the above risk, at least t\vo additional conditions must be known: 155 (1) Are adequate proportions of the smolts likely to be found in shallow water? I conclude that about 30 % of the smolts inhabit the shaJ!v>w water, based on the reports of Smith (1973) who reported about 30 ° b of juvenile cliinook were in the upper three feet of the water at Lower Monumental Dam on the Snake Rj'ver. This was confirmod by Dawley (1986) who found a jiniilar distribution of chiiiook juveniles in the forebay of the Dalles Dam on the Columbia River. (2) Are times to mortality short enougli to kill smolt3 at prevailing gas le\els in shallow water? I concluded that times to 5 "■'o mortality are sufficiently short to be oporative, as judged from Table 1. which lists the a%erace times to 5 % mortalit>- for juveniJ'J rainbow trout in shallow water (30 cm) at \arious hvperbaric gas (dP) pressures. dP mm Hg= 300 % Sat.= 139 Average hrs to 5% 1.6 Table 1. Hours to five percent mortality for rainbow trout Oncorhynchus mykiss at various hyperbaric gas pressures. 250 200 150 100 133 126 119 113 4.0 5.7 J7.1 215 95 % Umit= 0.3 0.8 0.5 4.9 x Range= 1.0-3.0 1.8-5.8 4.1-7.2 13.5.39.9 29.3-502 Ntest»= 16 10 14 14 9 The exposure times needed to kill 5 "-b of *e fish generally falls well within tlie time period of a single night. That is. when nominal zas levels were 139 %. 133 ""u. and 126 %. 5 Vo of the fish were killed in 1.6. 4.0. and ?.7 hours respectively. When gas levels were 1 19 °'o, the mean time to 5 "^'o mortalit>' v\as slightly over one day (27 hour>>. AppKinK a 5 % mortality rate to 30 "o of the population (which is found in shallow water) produces aii estimated average kill of (5° o mortilit>- X 30 ) = 1.3 % mortality of the total smolts per day at gas levels of about 1 19 %. If the gas level 156 approaches 133 '/b, as it has below Ice Harbor D;im, I would expect perhap;. as much as 9 % mortality' per day (5% mortalitj'.'day X 30 "o of fte fish X 24 /4 hrs day)^ Applying these data to Endangered Snake Ri\'er salmon, tiie calculated potential increase in survival of 2.6 % per day from spill tt> achieve 80 % FPE, would be oif set by a loss of 1 .3 °/o mortality per day at a gas level of 1 19 %, assuming no indirect mortality. However, at a gas level of 133 %, the same 2.6 % benefit would be destroyed in about 7 hours . which is approximately the gas level and truvel time from Ice Harbor Dam to the confluence with the Columbia River. The absence of floating dead smolts from gas bubble disease may trouble some, but consider this: turbines may kill upward of 15 "b ol the smolts, yet in nearly 30 years, I have never seen a single dead smolt in the Columbia River, nor do 1 know anyone who has seen one, (On the other hand, tests have allo^vn that onlv about 2-7 % of tlie dead adult salmon are found; I have seen some adult carcasses in the Columbia.) The risk to adult salmon is quite different tlinn exists for smolts, because adults are unlikely to be preyed upon. The risk to adults is real and likely more important than smolt mortality, but unfortunately, it is not well documented, At 120 % or less, adults are unlikely to die directly from gas bubble disease, but if they did, each pair would cost tile run about 5,000 eggs and invaluable genetic diversity. With adults, the main concern is causing sublellial dysfunctions tiiat may interfere with migration, survival, and spawning. For example, in the late 1960's it was common to see blind adult salmon, which most of us ascribe to hemostasis from gas emboli in the ophthalmic rete, with subsequent degeneration of the eye and it rots out of the eye socket. Several scientists including ni>'self, speculate that so called "head bum" lesions in salmon at Snake River Dams are the result of impaired xosion from sub lethal gas bubble disease. Dr. Ted Bjomn and students believes that the timing of the spill and passage of chinook sabnon with head scrapes over Lower Granite Dam arc circumsttuitial evidence that tlie head scrapes were related to gas bubble disease. "Wliatever tlie case, in 1993 about 22% of the research- tugged adult salmon that passed Lower Granite Dam had some degree of head bum. Of those with head bum, approximately 38% are estimated to have died prior to spawning, which is almost 70 % higher pre spawning mortality- than among non-head burned adults. 4. Have there been investigations of the effect of supersaturated water on resident ilsh? Have the restilts of these studies been incorporated into curi'ent poUcy? Most of tiie investigations have been done in tiie laboratory, about 20 years ago. coincidental to studies of salmon. No work lias been done on the effects of gas supersaturation on rtie population dynamics of resident fish in tlie Colimibia River Basin. This paucity of information reflects tlie low priority NMFS assigns to other fishery resources, which tliey consider to be expendable trash. Conversely, many sportsmen \alue the trophy walleye and smallmouth bass fishery in the Columbia and Snake Rivers, as well as the sturgeon, catfishes. crappie. bluegills, and various other fishes. Equally important to the resident fish and salmon are the aquatic invertebrates, especially those 157 who live in tiie shallow bur productive littoral zone, and fuel the food web. These components of &e Columbia are very important lo fish and wildlife, but our understanding of them is verv- superficial relative to gas supersaturarion. I attempted to investigate the incidence of gas bubble disease in resident fish in die lower Columbia, but lacking the necessarv- permits, I could only examine fish collecred by Oregon's Department of Fish and Wildlife. Some of tiie wild resident fish near Portland's airport had signs of gas bubble disease at a level equal to NMFS's fall chinook juvenile.^ near Bonneville dam. but I also found signs of GBD m yellow percli, bluegiUs, and peamouth (shiners). NMFS withdrew its offer to collaborate after we gave them some constructi\'e recommendations (attached). Both NMFS and NBS soon declined to let me accompany them, or look at fish collected under tlieir permits (see attached letter), even from a project that had nothing to do with tiie gas issue (project description attached). Working independently of each other. Di'. Ralph Elston and I have botii found epidermal scars in tiie fins of fish that were exposed to gas supersaturation in the Columbia River. While the cause of the lesion is uncertain, tiie size, shape, and location are strongly suggestive of previously healed lesions from gas bubble disease. NMFS is looking for gas bubble disease m resident fish and some zooplankters. but I ha^•en't seen tiie results. Further. NMFS lias no administrative provision for protecting resident fish, i.e. an action level if exceeded to trigger reduced gas levels. 5. To ^hat extent has sdentlflc research from the states been incorporated into the current spill policy? How can the deciflion-making process be Improved? The States have provided considerable data on fish passage, population levels, and natural history, but tiiey have not performed any gas supersaturation or gas bubble disease research. .As far as I know, no one on tiieir staffs has any expertise in gas bubble disease and supersaturation. They have provided a liteialure review, but it was very incomplete and biased. They have developed a computer model for investigating various fish passage issues, but results of tliese adventures in cyberspace should not be confused with real experimentation witii real fish. Aside from tiie recommendations in Question # 2, I believe tiiat most of tiie 92-531 0-96-6 158 decisions could be greatly inipro\'ed by peer review. In this context, peers must have recognized expertise of interest relative to tlie Program. At this point, I favor using the oversight committee approach in tlje Snake River Recovery Team's report. Sincerely. Gerald R. Bouck Physiological Ecologist 159 ■i^*^ 4 S.P. Cramer & Associates, Inc. I ^^E Fisheries Consultants 300 &E. Arrow Cr««k Lar^ Gresham, OR 97080 \\.MWUB S03-«€9-0133 503-669-3437 (FAX) May 23. 1995 ^1 Earl Dawiey National Marine Fisheries Service Point Adams Field Station P.O. Box 165 Hammond. OR 97121 Dear Earl: We greatly appreciate the opportunities you gave Ken Witty and Jerry Bouck to accompany your field crews, and observe your field studies to evaluate the prevalence of gas bubble disease (GBD) in the Snake and Columbia rivers. Ken Witty accompanied your crew to the live cages below Ice Harbor and examined some of the fish on May 8 and May 1 1 . He also accompanied the electrofishing crew at that location on May 1 1 . Jerry Bouck accompanied your crew to the live cages below Bonneville Dam and examined some of the fish on May 9. You and your staff have been most cooperative and pleasant to work with. Both Ken and Jerry were impressed with the dedication and industriousness of your field crews. No one appreciates uninvited criticism, and here I am writing to offer you some constructive suggestions. We share with you a strong desire to preserve the salmon runs in trie Columbia Basin, so we know that you want your studies to produce valid findings. We have some suggestions to offer that we believe are essential in order for your findings to be fully valid. We are aware that your field studies are just getting under way, and that you may already have made some of the adjustments we suggest. We have invested time in writing these suggestions, because we think your work is extremely valuable. Your live cages afford an opportunity count dead and traumatized fish after several days of exposure to the river, whereas such fish may never turn up at the smolt collection facilities or in beach or purse seme catches. We believe that traumatized fish are abnormally vulnerable to predators, such that a disproportionately low number of these fish show up at collection facilities or in seine or electrofishing catches. GENERAL COMMENTS Field personnel need specific training on fish processing and examination 160 techniques for gas bubble disease symptoms, gas measurement, and data recording. The crews at both locations lacked confidence and precision in at least some aspect of what they were doing. A fish health specialist and appropriate equipment should be added to each crew. This will ensure that appropriate decisions are made in the event of non- standard occurrences. As your crews stated to Ken and Jerry, exception seems to be the standard. Larger test fish should be used, perhaps yearling steelhead, to make the examination of symptoms easier. The subyearling chinook are difficult to examine, because of their small size, and bubbles are easy to overlook. The live cages below Bonneville Dam should be moved to a location which receives more direct inflow from the spill plume. Your crew has noted that saturation levels tend to run about 2% lower near the live cages than in the main current of the river. FISH PROCESSING PROTOCOL ► The field technicians for your GBD monitoring project urgently need a written, detailed protocol on how they are to deal with handling fish during initial capture, transport to the live cages, placement into the live cages, and recovery from the live cages. Your crews monitoring the live cages below Ice Harbor Dam and below Bonneville Dam had a good general idea of vA\ai to do, but had to fill in the details based on their own judgement Since they are not trained fish biologists, nor are they trained in the physiology and identification of all gas bubble disease signs, they unknowingly choose some procedures that bias the results. Whenever MS-222 is used for anesthetizing fish, it should be buffered to prevent harm to fish from high acidity. «• Handling of hatchery chinook transported to the live cages should be minimized. These fish were anesthetized and measured prior to placement in the live cages at Ice Harbor. Is this really necessary, since these fish get measured at the conclusion of the test? - Fish should be examined within 1 5 minutes of being removed from the river or live cages. We observed that fish at both locations were held up to two hours after being euthanized, before they were examined This delay allows for some bubbles to redissolve, such that the number of fish with GBD signs would tend to be underestimated. 161 DATA RECORDING ► Standard data forms appeared cumbersome to use in the field We observed that technicians were not sure what data to record, and they had difficulty finding the correct box to record data. FISH EXAMINATION » Fish should be examined with 26-40X magnification, rather than a 2X lens. We observed that bubbles along the lateral line could be seen under a dissecting microscope that were not visible through the head-mounted 2X lens. Your crew at Ice Harbor had both the microscope and the head-mounted lens with them on May 8, but only the head-mounted lens on May 1 1 . » The field technicians urgently need a written, detailed protocol on exactly what to examine on each fish, and what to record about their observations. For example, at Ice Harbor Dam, many of the dead fish were partially decomposed and GBD signs were not observable, because of the decomposition. Yet. it appeared that these fish were recorded as mortalities that have no sign of GBD. They should be recorded as unexaminable ► All field crews need to observe fish with known GBD signs, so they can be familiar with vtrtiat the signs look like. We found that the crews both below Ice Harbor Dam and Bonneville Dam were uncertain about whether or not some features they observed in fish were bubbles. ► Written protocols should also be developed for examinations of invertebrates. Portions of the entire food chain may be affected by gas supersaturation. particularly those organisms that spend time in shallow water. Your crew has observed bubbles in the brood pouch of Cladocerans, so the risk to invertebrates is very real. ► Fish examinations should be expanded to include the gills and prominent internal vessels, especially since the hatchery Chinook are killed anyway. This examination will require some routine dissecting equipment (scissors, scalpel, probe, pins, cradle), not currently available, as well as a microscope. GAS MEASUREMENTS Your practice of measuring gas levels at the live cage sites is excellent, and you also need to measure gas levels inside at least one of the live cages below Bonneville Gas levels were measured inside the deep cage below Ice Hartor, but only in the river near the live cages below Bonneville. The netting of the 162 cages offers an excellent surface for bubble formation, so gas levels may be lower inside the cages than outside. The optimum procedure would be to measure the gas level in each cage. The calibration of each gas instrument should be checked weekly. The discrepancy between gas levels measured by your crew and those measured by the USAGE indicate the need for this calibration. Gas levels in your cages below Ice Harbor Dam on May 1 1 were measured at over 128% when Ken Witty was present, while the 24 h high reported by the Fish Passage Center was only 122% for downstream of Ice Harbor. Such large discrepancies, In measurement are critically important and should be immediately accounted for. We suggest that levels of dissolved oxygen, as well as total dissolved gasses, should be monitored. The protocols listed in "Standard Methods" 1 8th Edition, should be followed. STUDY DESIGN A statistical design, including specification of desired confidence intervals, should be developed This design should specify the number of fish held in each live cage and the number of replicate live cages Our experience with the variability in expression of GBD signs indicates that replication is essential to sound statistical inference. The net pens in use, particularly the volitional depth pen, are too small. Their size is adequate for holding the fish, but is confining enough that it probably affects fish behavior. Fish in the volitional depth pen could feel quite confined, and may not freely range in depth as an unc/a^ged fish would. This problem was aggravated by the tendency of the nver currents to partially collapse the sides of the volitional depth pen. An internal frame, combined with greater width and length of the pen, are needed. Resident fishes should be thoroughly examined at the time they are captured in their natural environment, and a representative sample should be sacrificed for internal examination. The live pens in v\^ich resident fish are held should be substantially enlarged. The present small size of the live pens and the confinement they impose probably causes resident fish (some quite large) to hide at the bottom of the cage. Further, the trauma associated with their capture and processing, followed by lack of acclimation to the live cage, is likely to lead to abnormal behavior of the fish placed in live pens. Sampling of zooplankton and insect larvae should be added. This sampling is easy to do and would serve as an indicator of effects on the food chain. These organisms should be examined immediately after capture, and need not be held 163 in live cages. In particular the effects of supersaturation on emerging insect larvae should be examined. Ear\, we hope you will accept these suggestions as both friendly and sincere. Again, ■ we greatly appreciated the opportunities you gave Ken Witty and Jerry Bouck to accompany your field crews. We were strongly disappointed at the new NMFS policy that prevented us from continuing to accompany your crews. We would like very much to be your allies rather than opponents in completing your important studies There are few biologists in the region wtno are as capable of contributing to your field operations as Ken Witty and Jerry Bouck Please call Ken, Jerry, or me if you have questions regarding our suggestions. Respectfully yours, Steven P. Cramer Jerry Bouck Ken Witty Nanci Tester (DSI) 164 S.P. Cramer & Associates, Inc. "p,mcv Mo Rshef ies Consultants ij*-^^v^*_^ 300 &E. Arrow Cr»«k Lane ' — - Gresham. OR 97060 503-«e9-0133 503-669-3437 (FAX) May 26, 1995 Or. Allan Marmelstein Director, NW Natural Science Center National Biological Service BIdg 204 Naval Station Seattle, WA 981 1 5-5007 Dear Dr. Marmelstein: We laeiieve there is an excellent opportunity to augment the ongoing sampling for signs of gas bubble disease (GBD) in the Columbia River, through work conducted by your staff for other purposes. As we understand it, Or Tom Poe will t>e collecting resident fish along the shoreline of John Day Reservoir during the week of June 5th, as baseline information for future draw-down tests, but does not anticipate examining these for GBD. We understand how busy your staff must be, and therefore seek your permission to provide the examinations for GBD at not cost to the government. We are fonmalizing this request because we were recently denied access to fish being examined for GBD signs by your staff. We are precluded from doing our own sampling, because we cannot obtain the r>ecessary ESA permits before the spill season has passed. As you probably know, there is a paucity of data regarding the effects of gas supersaturation on resident fish in the shallow, but productive, littoral zone. To my knowledge, no one is specifically studying the effects of gas supersaturation on this important zone in the Columbia And Snake Rivers Additionally, a recent report by Donna Lutz (Trans. Am . Fish. Soc. 124:423-426) demonstrated that periodic fish kills from gas supersaturation can result from reseo/oir draw downs similar to that anticipated in John Day Reservoir. Therefore, we believe there is an important scientific opportunity available to the Region that can be captured with the cooperation of your staff. We would be pleased if Dr Alec Maule and his staff (NBS) could complete the examinations rather than us. Dr Jerry Bouck and Ken Witty of my staff have observed Dr.Maule and his staff examining fish in the Snake and Columbia rivers for signs of GBD. As is characteristic of Alec, we found his work and that of his staff to be highly credible. Alec and his aew were following clearly defined protocols, were well trained in their task, and were properly equipped to complete their tasks. 165 We have discussed the possibility of collaborating on some beach seining activities with Dr. Poe, and believe we can complete the GBD examinations without interfering with nonmal operations of the draw-down research crew. We will provide our own boat, our own examination equipment, and expert biologists. Our biologists vkoll gladly assist the NBS staff with seining and the associated activities on any sampling night we are present We would be pleased to supply you immediately with the results of our examinations. If we receive your approval, Dr Jerry Bouck and Ken Witty of our staff would accompany Dr. Poe's crew. Each has a laudatory record of over 30 years service as a fish biologist for government agencies. Dr. Bouck is on the NMFS Technical Oversight Committee for Gas Bubble Disease Monitoring, and was awarded an EPA Gold Medal 20 years ago for his work with gas supersaturation on the Columbia River. Thank you for considering our request. Sincerely, cc Dr. James Seelye (NBS) Dr. Alec Maule (NBS) Dr. Tom Poe (NBS) Dr. Jerry Bouck (consultant) Ken Witty (SPCA) Nanci Tester (DSI) 166 United States Department of the Interior NATIONAL BIOLOGICAL SERVICE Northwest Biological Science Center 6505 NE 65th St SeatUe, WA 98115 (206) 526-6282 June 2, 1995 S.P. Creuaer euid Associa'tes Inc. Fisheries Consultants 300 S. E. Arrow Creek Lane Gresheun, OR 97080 Dear Mr. Cramer: Thank you for the statements of support for our research programs on gas supersaturation in the Columbia emd Snake rivers. We share your feelings about the research being conducted at the Columbia River Research Laboratory. Concerning your request to work with our staff on currently funded research and specifically to examine fish collected by our stiaff, we must decline. We see the reasons as being quite obvious. We are working on permits that explicitly state they are not transferable. Therefore, we simply cannot allow any other use of tihe samples that we collect other than those stated in our applications. In addition, we must not jeopardize our ability to complete the work we have agreed to do by modifying our plans to accommodate your needs. The type and amount of work we have planned is difficult enough without adding new dimensions that were not part of the original planning process. We will provide our data and results to interested parties as required by law. We will also cooperate with your staff if they are working in the area under their own permits and approvals. Please let me know if you wish to discuss this matter fxirther. 167 ^&iUCkLJ»^' ILITARY INTERDEPARTMENTAU PURCHASE RBQUEST ■*^(,v"*\''^ ^'^^^ J. COMTAOL JTMaOL NO. 4, OATC PnCPAMCO 10 March 1995 mi Biological Servica Center NaClon4l Biological Survey 21dg.,20^ Naval Scacion S«atel« WA 9811S-S007 Dr. At Harmalat 1 or 1 P»0E2 ft. AMCMQ MO, BAS IC Coimandtr, US- Army Corps of Engineers Portland District, PO Box 2946 Portland,- OR 97208-2946 . ■ TtNJ n *«« I i »«e MOT 1MCI.UOIO I N T>ie INTI«ie«VlCe JUPOLY s xo ncouiKCO iNTtmCMuicc trm^mtmt tttk rtu mnd/m rfra-/rt« M« CSTIHATCO UMIT 'KICK tlTlMATeo TOTAi. MICE This form authorize* the Rational Biological Sirvey (MBS) t preystudies in Che John Sa/ Pool of the Colunbia Rl th'> attached scope of vork, budget, and research pi NBS Is authorized to Spend up to $111,983 to cc >tarch 1995 through Septenber 30, 1995. 3. TnK aoount authorized by this .order (?111,903) vr.tten approval of thla office. Involeas (origins to address shown in block 13. Two copies of form I address shown in block 13 after acceptance In block 4. This MIPR expires on September 30, 1995. The pc Ma: k Smith (503) 326-6135. This Economy Act order privlsions of AR 37-1/DODI 7220.9M. ver for oposdl. the nduct c ]>redator/ Corps of Ergineera per rk for the period : be e:6ktCand district '•■ • • ■ ATTN: CENPP-a>I-F. PO BOX 2946 IMAMO TOT* t'ort la"nd1" -OR' -"^TgOT-^'gy^Wf-- - ■ J. CG. EL BFP0230CCF2AUDC itm^ 5111,983 "°^^A^< UTHO«lllMC OP'ICIA iTrnv -^mt i»d tliui ^ecvjn t.. Sto>.kL.j.-i. ril, ;J??-PE DO, -is;-, 448 168 ACCEPTANCE OF MIPR TO ( Rtquiring Activity Addr43)) CIncludt ZIP Codt) Commander, US Army Corps of Engineers Porclaiid Discricc , PO Box 29^6 Foreland OR 97208-2946 2. MIPR NUMBER 4. OATE iMirRSit>uu\fy0ti4i 10 March 1995 S. AMOUNT fAii 3. AMENDMENT NO. A^ 5 Tht MIPR identified «hov« is iccepiod and the items requested will be provided as foUowt: (Chick as App(}<\ifiteJ' a. □ ALL ITEMS WILL BE PROVIDED THROUGH REIMBURSEMENT (CaUfory I) MAR 3 1 1995 b. □ ALL ITEMS WILL 8E PROCURED BV THE DIRECT CITATION OF FUNDS fCattgory II) ' V c □ ITEMS WILL BE PROVIDED BY BOTH CATEQCRV I AND CATEGORY [I AS INQICATcQ BELOW __ ..-,,-., d. □ THIS ACCEPTANCE. FOR CATEGORY 1 ITEMS. iS QUALIFIED BECAUSE OF ANTICIPATED CONTINGENCIES lASle from the prey abundance study. However, catches from each year may represent multiple year- classes of squawf ish. products: Data on relationship between juvenile northern sq[uawfish eJsundance and year-class strength. Schedule: Review data and report results by spring 1996. Objective 3. Replicate 1983-86 prey abundance studies in summer 1995. Describe the composition, relative eLbundance, and distribution of fishes in shallow littoral habitats of the John Day Pool. 179 Task 3.1 E>etermine sanpl* sizes- needed to detect largescale changes in catch and cooposition for major species at each sampl* location in previous prey abundance studies (Palmer et al. 1986). Rational*: The ability to detect largescale differences in catch and community composition for major species in the prey abundance study is important since predrawdown data collection is limited to 1995. If major differences in catch and » composition do not exist between the previous database and 1995 collections we may be able to use the prey abundance study as additional baseline information. Methods: We will conduct a statistical power analysis on the existing data set to determine sample sizes needed to detect changes in the relative abundances of important nearshore species. Products: Sample sizes needed at locations within the major strata of the John Day Pool study area. Schedule: Prior to sampling in spring 1995. Task 3.2 Conduct beach seining in selected habitats of the 180 John Day Pool. Collect environmental data concurrent with sampling efforts. Rationale: Little information exists on fish communities and community-level interactions in Columbia River reservoirs. Information on fishes within selected shallow littoral habitats of the John Day Pool before, during, and after proposed drawdown is important to our understanding of habitat use and community composition in impounded segments of the Columbia River. Drawdown could, potentially affect reciuitment of both native and introduced resident fishes, depending on habitat requirements and the availe±>ility of suitable habitat during and following the proposed drawdown. The creation of impoundments and associated habitat alterations have favored some native species such as the northern squawfish and restructured fish assemblages which now contain many exotic midwestern species (Li et al. 1987). • Drawdown may establish a new community equilibriiim through restructuring of the current fish communities depending upon a complex array of factors including pool-level fluctuation, drawdown timing, and various limnological effects. Monitoring these changes will further our understanding of the potential effects 181 on salmonlds. Mathoda: R«plicate 1983-86 prey abundance studies using identical gear and aethodologies at the sane sauopla locations. The prey abundeuice study used a 30.5 X 2.4 m bag seine with 6.4-inia knotless nylon mesh (Falser et al, 1986). They sampled at six general locations (John Day forebay, Arlington, Irrigon, McNary tailrace, and in two backwaters — Paterson and Plymouth sloughs) . At each location, four nighttime hauls were made during each sampling period. samples were collected from April to September. Some 1995 locations may change slightly due to pool level operations. However, we will attempt to sample similar habitat types within the immediate area of the former site. Environmental data on variables such as substrate, vegetation, temperature, and turbidity will be collected concurrent with fish sampling. Additional data on dam operations can be obtained after sample collection. Products: Community- level information for fishes in shallow littoral habitats of John Day Reservoir. Schedule: April through August 199 5. 10 182 Objective 4. Explore the pot«ntial effects of reservoir drawdown on predation through modeling studies. Identify critical processes and assumptions. T*«l: 4.1 Review literature and identify appropriate modeling techniques. Task 4.2 Screen or develop software necessary for predation aodeling studies. Task 4.3 Conduct simulations to identify critical processes that »ay influence predation through drawdown-produced mechanisms. Rationale: Manipulation of complex ecosysteva^ soch as drawdown of John Day Reservoir, often produces unpredictable results. Models of the basic processes in ecosystems (predation, prey movement, habitat change, etc.) can often be constructed and used to identify critical processes and data needs (Adams and DeAngelis 1987) . Drawdown of John Day Reservoir will b« a major manipulation that could redistribute prey, reduce the foraging habitat of ■ • northern sguawfish, and increase smolt migration rate, GIS models could be used- to demonstrate how shallow-water habitat might change at different levels of drawdown, and individual-based models could be used to simulate smolt migration responses 11 183 to velocity during drawdown. Modeling will be a valuable tool for understanding how changes in resident fish communities (Objectives 2 and 3) might influence predation and, ultimately, juvenile salmon survival . Methods: Various modeling approaches will be reviewed and considered (GIS -based approaches, trophic models, bioenergetic models, "individual - based models, etc.) . • ■ , Products: A report including: a literature review of existing fish ecology and predation data for JDR, a determination of the adequacy of existing littoral fish community data (1983-1986) for use in documenting drawdown effcts, model simulation results indicating magnitude of im.pacts of drawdown on predation levels on juvenile salmonids, and recommendations for studies of critical processes or assumptions. Schedule: April 1995 - March 199S (draft report due 01-19-96) . 12 o BOSTON PUBLIC LIBRARY 3 9999 05706 1309 THE LPMPR SOUTTER LIBRARY R0900727075 Rm007 27075 i ISBN 0-16-052174-2 90000 780 60"521744