229 



DRAFT 



The Fish Passage Center report mentions that the loss of fish between the [Snake 

 complex] projects this season "was higher than normal, based on counts at individual 

 dams." However, it is misleading to rely upon dam counts to assess fish losses due to 

 errors associated with dam counts^ fallback, tributary entrance ("tum-ofP), harvest, 

 and mainstem spawning. 



Page 59, 2.1.5. Downstream Juvenile Passage - General 



'In 1990, ODFW identified some 56,000 surface water diversions that 

 potentially impact fish populations in Oregon. ..Less than 1000 (two 

 percent) are presently screened. . . ODFW ranked the remaining 55,000 

 thousand (sic) unscreened diversions (98 percent) and determined that 

 3,240 water diversions were significantly impacting fish populations 

 (primarily anadromous salmonids) ... Frankly, we were surprised by the 

 magnitude of unscreened diversions in Oregon (5 5, (XX)) ... The priority 

 need for some 3, 240 fish screens out of a total 55,000 unscreened 

 diversions is a disturbing statistic". 



The authors statements and conclusions regarding the magnitude of screening needs are 

 misleading. Information cited out of context from Nichols (1990) implies that 55,0(X) 

 water diversions exist in Oregon that need to be screened. In fact, the cited report 

 clearly states that only 3,240 water diversions, representing less than six per cent of all 

 diversions in the state, require fish screening. The remaining diversions are not located 

 where gamefish or nongame threatened or endangered fish species exist. 



The authors also state that the majority of the 3,240 water diversions needing screens 

 impact anadromous salmonids. However, the cited report (Nichols 1990) provided no 

 information on species composition from which this conclusion could be substantiated. 

 In fact, a significant percentage of the 3,240 total water diversions identified in the 

 report as n^ing screens impact non-anadromous salmonids and/or non-game T&E 

 species. 



'Total anadromous fish losses fi-om unscreened diversions are very large 

 but presently are not estimated. A rough preliminary calculation 

 indicates that losses over the years must be in the billions '. (emphasis 

 added) 



The authors state that anadromous fish losses from unscreened diversions are very large 

 but are not estimated. They then reference a calculation that is not identified, 

 explained, or qualified in any way which indicates the loss over the years to be in the 

 billions . This estimate is speculation that is not substantiated. 



A-23 



