234 



because it has been built on the blood and sufTering of our coastal communities/ 



The Bevan Report is in our view merely a way to justify continuing to do nothing of any 

 consequence to change the system itself It relies heavily on artificial transportation programs which 

 have recently been shown to have little scientific justification, and in feet may be doing more harm 

 than good The Bevan Report largely dismisses the body of evidence that supports flow 

 augmentation as a means for increasing survival rates by flushing the fish away fi'om the turbines, thus 

 avoiding turbine mortality Turbines have a far greater negative impact (10-20*/o mortality) than 

 observed mortalities (0-3%) resulting fi^om spill programs ' What is fer worse, the Bevan Report 

 blames the beleagered fishermen for losses of salmon when the real blame belongs with the 

 hydropower system itself While there is some good in it, the majority of the recommendations are, 

 in feet, a step backwards -- no more than minor tweakings of the system of the type which have 

 already been discredited in US Ehstrict Court as inadequate, insuflBciem and ineffective and which are, 

 in turn, based heavily on a discredited 1993 NMFS Biological Opinion which has already been 

 thrown out of Court as "arbitrary and capricious "* 



4 AcGOnliiij: to ofonnitioo cited m i recent Canjressionil report "BPA at i Crossroids' ( Miy. 1994). b>- llie 

 specud BPA T»si Force ( Coogresanm Peto Defszio. Chiir) to the House Comminee on Nitiml Resources, the ihnnmum 

 UKtostn IS subsidized b> BPA to the tune of about $15 nullionmiaBth (SI": ouUionATV and the water nngalors m tbe 

 Cohanbu me subsidizai b>' BPA to about another $59 imlboii/>T For compansou. the entire federal relief ptogram for the 

 Pacific coast sabnon mdnstr> recenth declared by ihe Dept of Commerce is $15 7 milboo - about what the federal 

 govenmient pv-es away to these other two oxfaistnes m federal subsidies each month. 



■ 5 Tuibme mortalm- is known to be between 10-20% for each dam. multipbed b> 8 dams ( see Northwest 

 Power Plannmf Council ( 1 986) 'Compilatioa of mformatioa on sabnon and steelhead losses m the Columbia River 

 Basm " 252 pages and appendices. Detaikd Fish Operatmg Plan (DFOP) with 1994 Operatmg; Cnteiu (1993) 44 

 pages and appendices, by Cohnnbia Basm Indian Tribes and the State and Federal Fish A WiJdhfe Agencies) Turbine 

 mortalm- is tbe leadmg cause of salmon destruction m the hjdropowei s>stem. and increased spills and otha flow 

 augmenution programs are effective because the>- guide outmigratmg smolts awa>- from die tuibmes. Am- s»nd> of 

 comparative risks from such spill programs has to be a comparison between die 0-3% mortabtv due to mtrogen 

 supersatnration (so calkd "gas bubble disease") vctsus the known 10-20% mottahtv which would otherwise result m 

 the tmbmes An> reasonable comparison of the two puts spdls head and shouktes above other options for increasmg 

 outmigrant survival rates. 



6 Idaho Dept of Fish & Game vs SMFS. ei. al.. US District Court (Oregon) No 92-973-MA (lead case) - 

 Opmkn of Judge Marsh 3/28/94 as discussed elsewhere in the text of this sutemeot 



