79 



5). NMFS also proposes to monitor for visible external signs of gas bubble disease in 

 migrating smolts, but this is "unlikely to provide adequate protection for salmon" because 

 "[b]v the lime gas bubble disease is widely apparent in either the juvenile or adult 

 populations, it is likely that substantial losses will have occurred". (Tab 8, at 6.) NMFS' 

 own scientists note that "[m]any researchers experienced in examining fish for external signs 

 of GBD refute the validity of this method of assessment". (Tab 5, at 5 (referring to adults).) 

 To the extent that a determination is made to reljix the standards, Dr. Larry Fidler notes that 

 it IS essential to conduct a "microscopic examination of gill lamella and lateral lines" 

 (Tab 11) -- monitonng apparently omitted from the NMFS monitoring plan. 



6. The spili program will cost Northwest electric ratepayers at least $40 

 million dollars. Federal, Oregon and Washington law all require water quality standards to 

 be set after consideration of all beneficial uses of the water, including hydropower 

 generation, and consideration of economic impacts.' Douglas Faulkner, senior operations 

 engineer for the DSIs, esumates that granting the water quality variance sought by NMFS 

 will result in the loss of 4,500 megawatt-months of power, enough to power the entire City 

 of Seattle for four-and-one-half months. (Tab 17, at 2.) This in turn will impose some $42 

 million in addiuonal costs on BPA ratepayers. (Tab 17, at 3.) 

 Da«<L Apnl 7, 1995 



/^ 



JaoD^ Tanz^F^ jf R. Erick Johnson y 



Attorney for DSIs Attorney for PNGe 



'Indeed, Washington state law prohibits short-term modifications to water quality 

 standards where, as here, doing so would "significantly interfere with . . . existing water 

 uses". WAC 173-201.A-110(2). 



