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additional measures: drawdown. Snake River storage and 

 improved water use efficiencies, p 7. 



XVIII. It is important to keep in mind that, without these 

 measures, it appears highly unlikely that the region 

 can rebuild salmon populations to the levels called for 

 in the Council's Strategy, p 7. 



XIX. We note omission of the John Day drawdown. This is one of 

 the measures that we believe should be implemented unless 

 insurmountable problems arise. ... Omitting John Day 

 drawdown from a salmon rehabilitation effort at this time is 

 inappropriate, particularly given the fact that its travel 

 time improvements would require some three million acre- 

 feet of storage if they were pursued using flow augmentation 

 from storage sources, p 8. 



Oregon Department of Fish & Wildlife 



XX. We believe that this recovery plan needs productivity and 

 utilization goals, an analytical framework for review and 

 decision-making, measurable biological objectives, 

 rebuilding measures with schedules and performance 

 standards, a structure for monitoring and evaluation, and 

 adaptive management flexibility. . . There is no attempt to 

 quantify or rank the substantial degree of risk and 

 uncertainty associated with most actions discussed in the 

 draft, p 1. 



XXI. For example, there were no management scenarios which 

 evaluated the combination of draw down in the Snake River 

 and flow augmentation in the Columbia River, p 1. 



XXII. Even if transport is marginally effective, it has not 

 halted declines in the listed stocks. From our 

 perspective, based on review of available information, 

 the risks associated with continued transportation are 

 greater than those associated with system changes to 

 improve in-river migration conditions through draw down 

 and flow augmentation, p 4. 



XXIII. Rather than rigorously assess the merits of improving 

 in-river migration conditions, the Team 

 enthusiastically endorsed a proposal that is highly 

 speculative and risky. . . Should the recommended 

 option fail it could prove too late to restore the 

 natural migration route in time to recover these 

 stocks, because the two types of options are largely 

 mutually exclusive, p 4. 



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