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April 7, 1995 



William W. Wessinger, Chairman 

 Oregon Environmental Quality Commission 

 121 S.W. Salmon, Suite 1100 

 Portland, OR 97204 



Eric Schlorff 



Washington Department of Ecology 



P.O. Box 47600 



Olympia, WA 98504-7600 



Dear Sirs: 



My understanding is that my letter of February 13, 1995, regarding the state and 

 tribal "1995 Spill and Risk Assessment" document arrived at Oregon DEQ after the close of 

 the last public comment period and has therefore not been considered by DEQ. For the 

 convenience of all concerned, I have undertaken to consolidate the contents of that letter, a 

 previously-filed affidavit, and some additional comments addressing the new proposal by 

 NMFS to increase allowable levels of total dissolved gas in the Columbia River. 



I worked as a fishery research biologist for the National Marine Fisheries Service and 

 its predecessors for 31 years, retiring in 1988 as Director of the Coastal Zone and Estuarine 

 Studies Division, formerly the Fish Passage Research Division. Since 1988, I have worked 

 as a part-time consultant on fish passage research problems. I obtained a Ph.D. in Forestry 

 and Wildlife Management from the University of Idaho in 1977. 



In brief, my conclusions concerning NMFS" request are: 



1. Denying the request would not likely to result in greater harm to salmonid 

 stock survival through in-river migration than would occur by increased spill. Granting the 

 request is likely to reduce salmonid stock survival because increased spill will decrease the 

 percentage of fish that are transported in addition to any direct and indirect mortality arising 

 from gas bubble disease. 



2. Allowing the request does not provide a reasonable balance of the risk of 

 impairment due to elevated total dissolved gas to both resident biological communities and 

 other migrating fish and to migrating adult and juvenile salmonids when compared to other 

 options for in-river migration of salmon. Indeed, allowing the request poses a risk of long- 

 term harm to the Columbia River ecosystem. 



3. Assuming proper monitoring and appropriately-designed experiments were in 

 place, it might be reasonable to experiment with allowing spill to TDG levels of 115% in the 

 stilling basin. Such an experiment should only be conducted at dams where salmon cannot 

 be collected for transportation, since transportation remains a superior passage alternative. 



