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The Sierra Club 



LXI. The draft recovery plan offers no assessment whatsoever of 

 the relative impacts among the various factors causing the 

 decline of Snake River salmon. The Team cites hydropower 

 development, habitat destruction, hatcheries, harvest, 

 disease and natural factors, but provides no guidance on 

 which kills most salmon. The National Marine Fisheries 

 Service, Northwest Power Planning Council, and even the 

 Bonneville Power Administration have estimated that at least 

 80 percent of the human-inflicted mortalities to these fish 

 come at the eight mainstem dams of the Lower Snake and 

 Columbia Rivers, p 2. 



LXII. Lacking any analysis of the relative magnitude or 



significance of fish mortalities, the Team presents a 

 long cafeteria line of recovery measures, but cannot 

 predict the effectiveness of those recovery actions, p 

 2. 



LXIII. Thus the central necessary feature of any viable plan - 

 - a critical path to the species' recovery — does not 

 appear in the Team's draft recommendations, p 2. 



LXIV. And consequently the Team sets priorities for recovery 

 actions on the basis of timeliness and/or cost rather 

 than measurable benefit to the salmon — an exercise in 

 futility because, without a rigorous foundation in 

 biology, any and all cost analyses of, or timeliness 

 for, salmon recovery become so much smoke in mirrors. 



LXV. Similarly the Team fixates on the costs of its recommended 

 recovery plan and the proposed actions, but gives no 

 consideration whatsoever to the economic benefits of salmon 

 recovery . p 2 . 



LXVI. [T]he Team ignored biological evidence and computer 



modeling from agency and Tribal biologists that showed 

 that nearly two decades of juvenile fish transportation 

 out of the Snake River Basin have actually contributed 

 to the decline of wild salmon stocks. First, barging 

 and trucking smolts has its own lethal impacts. 

 Second, continued operation of the transportation 

 program has postponed any real effort to improve in- 

 river migration conditions, p 3. 



