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Fish and Wildlife Program. Spill is the primary means of passage provided for mid- 

 Columbia FERC licensed projects and is central to the court ordered setlJement 

 agreement. Spill was negotiated in a 1987 Regional Spill Agreement, which was 

 later amended to the NPPC Fish and Wildlife Program. 



The NMFS has made every effort to obtain and consider input from diverse orga- 

 nizations in the development of the 1995 Biological Opinion. The steps taken for uie 

 development of the Spill Program represent technicsQ and scientific processes over 

 the years. The risks associated with spill were analyzed and incorporated into the 

 development of the present spill program. 



The Denefits of spill have been established through research and monitoring over 

 several years. Direct studies of project mortality nave been conducted at several 

 mainstem projects and have shown that spillway mortality is consistently lower 

 than other passage routes. Adult return ana run reconstruction analyses have dem- 

 onstrated that some of the highest smolt to adult return ratios have occurred under 

 circumstances when high levels of spill (much higher than observed under recent 

 planned spill programs) occurred during the juvenile migration period. Spill has 

 been recognized and utilized as a fish passage mechanism for decades in the Colum- 

 bia and Snake rivers. 



In 1995 the agency and tribal resource management agencies reviewed all the 

 available literature and studies to develop an assessment of the risks associated 

 with a spill. The "risk" was measured in terms of trading off the benefits to fish 

 by avoiding turbine passage, versus the detriments associated with mortality due 

 to increased levels of^ total dissolved gases (Draft 1995 Spill and Risk management, 

 available upon request). The A&T concluded that spill is beneficial at levels of total 

 dissolved gas greater than the levels adopted by the NMFS in the Biological Opin- 

 ion. Therefore, the NMFS spill policy can be considered both scientifically valid and 

 conservative. 



2. What independent scientific research is being conducted to monitor the effects 

 of spill and its alternatives in the Columbia River system? Please comment on the 

 results of relevant studies. 



I am aware of research presently being conducted related to turbine passage sur- 

 vival, spill passage survival, juvenile reach survival, transportation benefits, and 

 surface spillway collection. Spill research specifically includes studies to determine 

 the association of the signs of GBT and potential for mortality, the impact of pas- 

 sage through bypass systems relative to the observation of signs of GBT, the 

 amount of time spent in bypass systems, and the comparison of signs of GBT of fish 

 observed in forebays and reservoirs versus observations at the projects afler passage 

 through a b3T)ass system. 



SUBLETHAL EFFECTS 



You will hear references to the potential mortality associated with sublethal ef- 

 fects, such as increased vulnerability to predation and long term physiological im- 

 pacts. These are valid concerns, but they are also valid concerns relative to other 

 routes of dam passage. Fish suffer great changes in pressure as they pass through 

 a turbine unit and are immediately either killed or stunned and pass through to 

 the tailrace area. Here these fish also suffer from increased risk of predation. I 

 might interject that one of the benefits of spill is that it disperses predators from 

 the immediate fish passage area below the project by causing velocities that are too 

 high for predators. 



In adoition, the potential impact for transportation on the long term survival of 

 fish has been overlooked. The transportation program has long oeen described as 

 the solution to the problems in the migration corridor, yet despite ever increasing 

 transportation of fisn we continue to see a decline in tlie species. It may be that 

 there are other processes affecting the survival of these fish, or it may be that sub- 

 lethal effects of transportation are manifesting in the population. Yet in spite of 

 having no knowledge regarding this subject the Biological Opinion recommends im- 

 plementing ihe transportation program and expands its implementation to fall Chi- 

 nook migrants from the Snake River while no research has ever been conducted 

 with Snsie River fall chinook. 



INADEQUACY OF THE MONITORING PROGRAM 



You will hear comments relative to the mortality being imposed on fish from dis- 

 solved gas and the inability of the monitoring program to be able to detect the signs 

 of GBT. This is not true. There have been at least two instances in the last 5 years 

 when the monitoring program detected fish with signs of GBT as a result of spill. 

 The first was in 1990 when a fire at John Day Dam caused the entire powerhouse 

 to fail and 100 percent of the river flow to be spilled approximately 300 kefs for 5 



