221 



Ted Strong. 

 Columbia River Inter-Tribal Fish C oininission 



XII. The approach in the draft to establishing recovery goals is 

 more political than biological, p 2. 



XIII. The section .... should note that habitat has been 

 widely degraded and that salmon survival in degraded 

 habitat has been significantly reduced. Unless all 

 remaining habitat is fully protected and allowed to 

 recover, the runs will continue to decline, p 2. 



XIV. The draft's rejection of John Day drawdown fails to take 

 into account the survival benefits to salmon originating 

 from tributaries such as the Yakima, Wenatchee, Okanogan, 

 Methow, and Umatilla river basins, p 3. 



XV. The draft asserts that the biological benefits of a four 

 pool river-level drawdown of the Snake River reservoirs 

 compared to improved collection and transport "are similar," 

 and that only these two options "have the potential to 

 increase survival to the extent needed." The draft's 

 recommendations rest heavily on the results of modeling 

 studies discussed above. Considering the draft's mis- 

 characterization of these studies, the foregoing assertions 

 do not withstand careful scrutiny. With such technical 

 infirmities underlying one of the draft's most serious 

 recommendations, it is clearly inadvisable to proceed "so 

 that the decision now must be based on economic and social 

 factors . " p 3 . 



• If transportation actually causes reductions in survival 

 compared to in-river migration (a TBR less than 1:1), 

 increased collection and transportation may be expected to 

 exacerbate the decline of listed stocks. The draft wholly 

 overlooks this possibility, p 3. 



Northwest Power Planning Council 



XVI. We believe these immediate actions could minimize the risk 

 of failure and improve salmon survival; however, our 

 analysis also indicates that they will be insufficient — 

 even when taken together with other significant improvements 

 in other areas of the life cycle — to reach the rebuilding 

 goals set by the Council, p 7. 



XVII. Accordingly, the Council said that as a matter of 

 urgency the region should make all necessary 

 preparations to implement expeditiously a number of 



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