76 



COMMENTS OF THE DIRECT SERVICE INDUSTRIES AND PACIFIC 

 NORTHWEST GENERATING COOPERATFVE ON THE NMFS PROPOSAL TO 

 INCREASE ALLOWABLE TOTAL DISSOLVED GAS IN THE COLUMBLV RFVER 



Years ago, state and tribal fishery agencies and the United States Environmental 

 Protection Agency conducted a "comprehensive review and syntheses of [gas bubble disease) 

 research" which was also "reviewed by the Water Quality Section of the American Fisheries 

 Society". (Tab 1, at 1; see also Tab 2.) The state and federal governments ultimately 

 adopted a standard of 110% allowable total dissolved gas supersaturation that was specifically 

 engineered to protect migrating fish in the Columbia River Basin (Tab 2, at 1; Tab 3), 



L.B. Day, then Director of Oregon Department of Environmental Quality, supported 



a limit of 105%: 



"'I maintain that the risk of killing fish by setting the level too high is a much more 

 senous one than the nsk of taking a cautious approach so that the fish are protected." 



(Tab 4) 



Since then, the effects of supersaturated water on salmon remain the same. Only the politics 

 have changed. For the reasons set forth below, NMFS' eleventh-hour request to set aside a 

 sound water quality standard should be rejected. 



1. Enormously signiTicant relaxation or state water quality standards should 

 not be adopted in abbreviated proceedings. Last year, water quality decisionmakers 

 reluctantly approved a spill 'expenment" that state and inbal fishery agencies admit 

 produced no evidence of increased survival from increased spill. ( Sec Tab 5, at 3.) Fishery 

 policy spokepersons have long known that water quality waivers would be required this year 

 to support their desire for increased spill. They were advised by DEQ staff and others to 

 present iheir jusufication for their proposals in a fashion that would allow reasoned 

 consideration, and did not do so. A ten-day comment period on changing a water quality 



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