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modeling, and not aware or inclusive of all biological information. Moreover, 

 we know of no real substantive change or reversal made by the Team 

 between the draft and final documents in response to peer review. 



For example, the final document states: The Team notes that there 

 are significant problems with Northwest salmon and steelhead populations 

 in streams that are not tributaries of the Columbia and Snake Rivers and are 

 unaffected by dam development. For this reason, we conclude that the 

 impacts of man on the ecosystem are far greater than just mainstem dam 

 construction" (final, p. VIII-69). This brand of scientific reasoning also 

 reachs the conclusion that cigarettes do not cause lung cancer because some 

 non-smokers contract the disease. 



For instance, the Team gave no consideration to combining reservoir 

 drawdowns of the four Lower Snake reservoirs and flow augmentation in the 

 Lower Columbia pools in order to provide comprehensive juvenile fish 

 passage through the hydropower system. Such an approach lies at the heart 

 of the Strategy for Salmon from the Northwest Power Planning Council and 

 of the 1 994 Detailed Fishery Operating Plan of the Columbia Basin Fish and 

 Wildlife Authority (CBFWA). 



And for example, largely based upon a study contracted by BPA, the 

 Team concluded that tests have proven a positive benefit from the juvenile 

 fish transportation program. In the draft recommendations, the Team 

 wrote: "A review of recent transport benefit tests conducted by a group 

 assembled by CBFWA (Ad Hoc Transportation Review Group 1992) was 

 critical of certain aspects of the tests, but did not provide any evidence to 

 change the conclusions of the Team that the transport program is a better 

 option than others" (draft, p. VIII-23-24). In the final recommendations, 

 the Team amended: "A review of recent transport benefit tests conducted by 

 a group assembled by CBFWA (Ad Hoc Transportation Review Group 1992) 

 was critical of certain aspects of the tests, but did not provide any evidence 

 to change the conclusions of the Team that for most river flow conditions, 

 the transport program is a better option than others" (final, p. VIII-44). The 

 CBFWA group demonstrated that the fish transportation tests were invalid, 

 and that the smolt barging program does more harm than good for young 

 salmon. The purpose of the CBFWA review was not to provide alternatives to 

 fish barging, or for that matter, to convince the Team of anything. 



So the Team's dismissal of the CBFWA review in this manner is 

 patently unfair. Instead of giving due consideration to the CBFWA report, 

 the Team relied upon a study (Park 1993) contracted by BPA in order to 

 reach its findings that juvenile fish transportation provides biological 

 benefits, and can serve in the front wave of salmon recovery measures. In 

 May of this year. Dr. Phillip Mundy and a distinguished group of biologists — 

 with participation by the Corps and BPA — completed a new peer review of 

 the juvenile fish transportation program under contract to the US. Fish and 



Sierra Club —Page 4 



