227 



L. According to the Teaia, they have "concentrated on a thorough 

 evaluation of the various elements that might contribute to 

 recovery of the listed Snake River species." To evaluate 

 implies a ranking or measuring, a judgement. We find few 

 evaluations in this document because the Team did not 

 predict biological gains from actions, or even identify the 

 aggregated or single actions most likely to provide 

 measurable benefits, p 63. 



LI. The draft is contradictory and internally inconsistent for: 

 Failing to propose recovery actions based on scientific 

 information; Failing to propose recovery actions which have 

 some evidence to meet stated recovery goals, environmental 

 criteria and delisting criteria; Failing to propose actions 

 that reverse or ameliorate factors identified as causing 

 decline of the species; Applying different criteria for 

 improvement of spawning and rearing habitat than for 

 migration habitat; and for applying different time horizons 

 for implementation of recovery actions, p 65. 



LII. . . . Petrosky (1992) found that total collection and 

 transportation effort (measured by numbers transported) 

 failed to positively relate to numbers of adult returns. We 

 believe this quantitative information is instructive and 

 should provide a reality check concerning the poor viability 

 of collection and transportation as a conservation and 

 recovery tool, p 66. 



LIII. Instead of recommendations, the Teaua has provided a 



cornucopia of various elements that might contribute to 

 recovery of listed salmon. The document is full of 

 choices to be made, but there is no guidance, advice, 

 or priority to ensure that choices are effective and 

 will contribute to measiurable recovery, p 71. 



LTV. [T]he document and the opinions expressed are extremely 



speculative and almost totally lacking in documentation or 

 substantiating evidence, p 71. 



Federatipn of Flv Fishers 



LV. Salmon cannot recover and probably will not even survive if 

 the dam facilities and their manner of operations are not 

 changed significantly and QUICKLY. Time is of the essence. 

 The proposed Recovery Plan envisions a go slow, cautious 

 approach. This is a recipe for extinction. Survival and 

 long term health of Snake River anadromous salmonids is 

 predicated upon in-river migration by adults and juveniles 

 alike. The Recovery Plan does not reflect this reality. 



