330 



While the Council has attempted to evade cost-effectiveness for salmon recovery planning, 

 others are taking a more rigorous approach. It is significant that the National Marine Fisheries 

 Service (NMFS) has convened an Economics Technical Committee to advise NMFS on the 

 economic merits of its recovery plan. The Committee— composed of economists from federal and 

 state agencies, academia, and industry—has formally endorsed a cost-effectiveness framework for 

 salmon recovery planning. The Conmiittee is presendy evaluating a comprehensive set of salmon 

 recovery measures and determining those measures that will meet cost-effectiveness criteria. 

 Likewise, both the Army Corps of Engineers and Boimeville are using a comprehensive cost- 

 effectiveness analysis approach to salmon recovery planning within the System Configuration 

 Study (SCS) and work undertaken by Bonneville to assess the most effective means of 

 implementing Basin-wide salmon mitigation and enhancement (studies conducted by Resources 

 for the Future). 



The importance of using cost-effective for ranking recovery measure actions can be 

 illustrated by some of the work that has been completed by members of the NMFS Technical 

 Economics Committee. In one review of a con^rehensive set of recovery measures, it has been 

 estimated that the costs per returning adult salmon back Idaho waters— for one complete 

 optimized salmon life-cycle— could range between hundreds-of-doUars per fish (for smolt 

 transportation enhancements) to as much as several hundreds-of-thousands-of dollars per fish 

 (for a John Day Pool drawdown). This difference in magnitude, dollars per returning adult, 

 between the various measures reflect the degree of both biological effectiveness and economic 

 cost (see Attachment A). 



Advancing Law Risk Alternatives: 



The lack of priority for measures considered within the Strategy for Salmon plan affects 

 other key principles for successful salmon recovery plaiming. Most significantly, the Council's 

 fixation with reservoir drawdowns on the Lower Snake River and for the John Day Project 

 tUsplays an inherent lack of apprehension for pursuing high-risk, low-benefit alternatives (see 

 Attachment B). 



The Endangered Species Act (ESA) administrative record abounds with technical 

 documentation and expert testimony cautioning the region about the high biological risks 

 associated with reservoir drawdown proposals. This technical record reveals that many 

 biologists are concerned that the drawdowns would do more harm to the salmon resource than 

 good. For example, a Snake River drawdown would likely lead to: additional project mortality 

 due to reduced fish guidance efficiency; problems surrounding gas supersaturation; increased 

 predator concentrations; latent smolt mortality below Bonneville Dam due to the effects of 

 cumulative project passage through the Snake-Columbia River system; and increased adult 

 passage mortality. Also, the Northwest Power Planning Council staff agreed with industry 

 analysts that a drawdown under low water conditions would not be as effective in protecting 

 juvenile salmon as the existing smolt transportation program. 



On the John Day Reservoir, scientists with the University of Washington have 

 determined that a John Day drawdown would be completely ineffective with the smolt 



