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economic gains regionally, and in some instances, locally. The Northwest 

 can have salmon and hydroelectricity, and need not choose between them. 

 But to accomplish this goal, the Northwest must promptly and creatively 

 abate all human-inflicted causes of salmon mortality, particularly the impact 

 of federal hydroelectric dams on the rivers mainstems which are 

 responsible for 80-95 percent of these fish mortalities. In our view, the 

 region must proceed with its recovery effort concentrating on how to make 

 the economy work with the salmon rather than the old failed strategy of 

 making the fish fit into hard-wired economic constraints. And scientific 

 guidance for Columbia /Snake salmon recovery must come from the full 

 range of biological expertise, particularly from the professional judgment of 

 the federal and state fisheries agencies and the American Indian Tribes. 



In stark contrast, several parties to the salmon recovery debate, 

 including the Bonneville Power Administration (BPA). the U.S. Army Corps 

 of Engineers, the Pacific Northwest Utilities Conference Committee, and the 

 Columbia River Alliance, have maintained that the Snake River Salmon 

 Recovery Team empaneled by the National Marine Fisheries Service 

 (NMFS). and its recommendations, have a special and superior status, 

 standing, legitimacy, and authority in the recovery planning process. For 

 example, they have argued that, in the biological opinions for operation of 

 the hydropower system, NMFS can or should require only those measures 

 recommended by the Recovery Team. 



These parties do not make this argument on the basis of law because 

 they can not; the Endangered Species Act (ESA) does not require 

 appointment of a Recovery Team much less grant it any special status. They 

 try to make their case by claiming that the Recovery Team recommenda- 

 tions represent a recovery plan based on hard science written by an 

 independent panel of scientists. The Sierra Club respectfully submits to the 

 Committee that, upon close inspection, this case by the hydropower 

 agencies and industry simply does not hold water. 



• The Bevan Team has not produced the recovery plan. 



The Recovery Team recommendations are not a recovery plan. 

 Nowhere in its recommendations does the Recovery Team take the pledge: 

 "If you do this, they will come back." The Bevan Team document does not 

 contain rebuilding schedules, performance standards, and many other of the 

 basic attributes of a recovery plan as required by the ESA as interpreted by 

 the federal courts. 



While acknowledging the fact that petitions are pending to list 

 salmonids in the middle reach of the Columbia River, the Team's 

 recommendations needlessly focus exclusively on the threatened and 

 endangered Snake River salmon, and do not take an ecosystem approach. 

 For example, the Recovery Team rejects a drawdown of John Day reservoir 



Sierra Club —Page 2 



