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pass down the river, which can be seen by comparing the Warrendale (Oregon side) and 

 Skamania (Washington side) measurements; when the second powerhouse is not fully 

 operational, the Skajnania measurements will tend to reflect the higher concentrations from 

 the spillway water. In order to give maximum protection to Columbia River fish and 

 wildlife, it would be prudent to measure TDG at the Skamania station. 



Traospcrtation as a Passage Alternative 



In the Risk Assessment, collection and transportation is dismissed as having no value 

 and it is unclear what value screening and bypass systems might have. Sublethal effects of 

 higher than normal TDG levels are not addressed. I understand that this assessment only 

 deals with survival of in-river fish and therefore the effects of transportation are omitted. 

 However, if the goal is to increase adult returns, transportation and its value must be 

 considered. As spill increases at collector dams, fewer fish are transported, thus fewer fish 

 receive the benefit from transportation. 



The reports by Mundy et al. and the Ad Hoc Transportation Review Group cited to 

 dismiss transportation are seriously fiawed. I am intimately familiar with the transportation 

 studies because I initiated and carried out the first study in 1968 and was either co- 

 investigator in later studies or assisted in planning and direction of the studies. From the 

 first study conducted in 1968 to the present studies underway, the experimental design of the 

 experiments mandates that the primary point of evaluation of adult returns is at the dam 

 where the juveniles were marked and assigned to treatment groups. In addition, the studies 

 were designed with replicates for both transport and control groups so that variance in return 

 rates could be computed for various statistical tests. Thus, data must be treated in aggregate 

 for proper analysis. The Ad Hoc review group chose to separate returns and analyze data 

 from alternative sites such as hatcheries and spawning grounds where in many cases they 

 were analyzing adult returns ranging from 0-15 fish from one or two replicates of one 

 experiment. From this type of analysis they chose to draw their main conclusions, ignoring 

 the main and most valuable data. They also did not review any data obtained prior to 1980. 

 Since 1968, over 29 tests utilizing spnng, summer and fall chinook in transport and control 

 releases have been carried out. All but two of these tests showed a benefit from 

 transportauon. The two that did not show a benefit indicated no significant difference in 

 returns of transported and non-transported (control) fish. 



There are also some errors and omissions in the Mundy report, but the main fiaw in 

 this report is that the executive summary and conclusion do not always agree with the data 

 and information contained in the text. The executive summary also omits commenting on the 

 fall chmook data from McNary Dam which is clearly in favor of transportation. Generally, 

 the executive summary highlights the negauve aspects of transporution and omits the 

 positive. The quote by the Mundy report: "available evidence is not sufficient to identify 

 transportation as either a pnmary or supporting method of choice for salmon recovery' is 

 simply incorrect. (S^ detailed comments attached as Exhibit A.) 



