92 



dimajied If Jlgnlflcsm levels of montlity or signs of (JBT are found in «moltt of the Columbia end 

 Snake Riven This situation may lead to a compromije of the results of the biolotfical monlioHng 

 program. At present, there i« no inrfp.pendert biologjcal monitoring for jignt of OBT being oonduetod 

 on the Columbia and Snake Rivws. Consequently, the monitoring results reported by llie Fi»li Fusaiie 

 . Center cannot be indepondonlly veiifieU. 



Perhaps the moit troubling aspect of the 1995 blolouical monitoring program is that hecauM it Is so 

 unfbeused and poorly designed and iinplAmfintrd, an opportunity lo undariland the effect* of DCS on 

 juvenile and adult salmonldi of the Columbia and Snako Riv«rs has bc«n lost. Scicmistt will f^cc ihe 

 1996 salmonid migrations with Utile itioic iiiA;inut\iun than was available at the beginning of I99S. 

 Thli regrettable sltuadon could have been avoided had NMPS ke«p the DOS and GBT Expert Panel 

 involved In the design of the 199S biological program and in an ongoing review ofthe data. Even af 

 this late date, NMFS appeara relucunt to reconvmie the DOS and OBT Export Panel In order to 

 review the 1995 data, analyze the inistAket of 199S, and develop a eomprchonaive monitoring program 

 for 1996. 



4. Have there been invesll)tatlonj ofthe cfTect of supcnalurated water on resident flsh? Have 

 the reiujti of these itadlea hem InrorporatMi into currtnt pulley. 



The eiTbcti of DOS and GDI on resident flsli spocicii lias been ijuile limited in tumparison to studies 

 of migratory salmonlds. The studies which have been conducted are summerlzed in Fidler and Miller 

 (1994). NMFS is conducting some net pen studies on the elT^tt of DOS on resident fish and 

 invertebrate populations ofthe Columbia and .Sn«l<fl Rivers However, the results of these studies 

 have not been incorporated into ih« NMFS 1995 Biological Opinion in terms of action levels for 

 controlling TOP lervels. 



5. To what extent has Kientillc research (V-om the states been incorporated Into the current spUl 

 pnliry? How ran the decision mnldng proceaa br improved? 



At preienl, a large pioporlion ofllic vuiiciii npill policy m based on annlyses developed by the state 

 agencies. As pointed out earlier, the state and tribal agencies prepared a iipill atid J 995 Kixk 

 Manaxemeul analysis. The purpose ofthe analysis was to support their contention that spill levels 

 which resulted in lotsi gas prMSiirej up to 125% produced grentcr juvenile rurvival than would occur 

 for fish passage through turbines This document wna found to havo numerous flows in the onalyiis 

 iiieiliudi, lu ilic eiiieiu ilivi tlia untilyiiiit results were invalid and underesiimaced the effects of DOS on 

 adult and smolt ulmonida 



Furthermore, as a result of poor design and implementation, there will be very little usable information 

 ac<)uir»d from the 1 995 biologiool monitoring program. These problems could have been avoided if a 

 cumprehennive peer review process were in place. In 1994, N?VIFS convened iwo panels of experts to 

 advise tiiem on the etteas or'DOS on Columbia and Snake River Salmonids. The panels also 

 recommended components for a comprehensive biological monitoring program. Yet, when it came to 

 devrloping k 1905 Biological Opinion and designing ■ biological monitoring program, NMFS ftuled to 

 allow the expert panel to review cither one. The NMFS 1995 Biological Opinion cites muoh of the 

 inlbnnaiion tontained in the flawed Spill wid 1993 Jilik Manageinvni document. Although It was not 



