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Aspen Applied Sciences Ltd. 



Environmental Scientists and ConsuUanti 

 June 20, 1995 



The Honorable Dirk Kempthome and Harry Reid 



Senators, United States Senate I 



Senate Committee on Environment and Public Works 



Senate Subcommittee on Drinking Water, Fisheries, and Wildlife : 



415 Hart Senate Office Building I 



Washington. DC. 20510-6175 ' 



Dear Scnatori Kempthome and Reid; I 



Thank you for the invitation to appeflr before your committee on June 22, 1995 and for the 

 opportunity to comment on the Nntional Marine Fisheries Service's policy on spill at the 

 Columbia River hydropower dams, gas bubble trauma in threatened and endangered salmonids, 

 and the scientific method used under the Endangered Species Act which resulted In that policy, In 

 response to the five issues identified in your letter, I would like to offer the following testimony. 



1. Are the benedts of using spill as a Tiih passage mechanism cstabiiihed, especially in 

 relation to other Hih paisage rncchanisms? Comment on the iclenf iflc validity of the 

 National Marine Fisheries Service (NMFS) spill policy. I 



It is my opinion that NMFS lias not validated tlic benefits of spill as a fish passage mechanism in 

 comparison to other fish passage mechanisms My main concern is that the benefits of spill have 

 not been quantified to the extent that a comparative analysis of the various fish passage ; 

 mechanisms can be made Without a quantitative comparison of these mechanisms, it is I 

 impossible to establish, on a scientific basis, which mechanism (o: combination of mechanisrns) 

 will produce the greatest overall survival of sahnonids. 



Furthermore, the data for juvenile and adult survival which have been presented by the state and 

 tribal agencies to support high levels of spill do not show a clear benefit of spill. In foct, some of 

 the data suggest that the passage of sniolts through turbines leads to higher survival than the 

 passage over spillways, In developing a basis for this view, I will cite data which comes fVom the 

 document Spill aitd 1995 Risk Managcmciif which was prepared by fish and wildlife agencies of 

 Idaho, Oregon, and Washington and the Columbia River Intertribal Fish Commission. This , 

 document is cited (Voquently throughout the NMFS 1 995 Biohgival Opitiion. \ 



P.O Box S]l, Cranbrook, B,C, Canada VIC 4J1 Tcleplionc; (604) 426-7549 Facsimile: (004) 42G-8J49 



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