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[1] Spring Spill Ends: Is There Enough Left For Summer?
[2] Council's Power Reliability Report Questions BPA Spill Strategy
[3] FERC Gives Qualified 'Yes' To Less Spill At Grant Dams
[4] Region Weighs In On FERC's 'No-Spill' Option
[5] Idaho Power To Oppose NMFS Push For Brownlee Water
[6] New Twists To Old Fish Arguments In Journals
[7] Lamprey Harvest Ok'd For Willamette

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The spring spill program at federal dams on the Columbia ended last Friday night, at which point about 600 MW-months' worth of water had gone over the spillways since May in the name of improved fish passage. With the debates over the real value of the strategy for fish still fresh in regional policy circles, salmon and power wonks are ready to re-kindle those arguments over the question of summer spill.

On the one hand, regional load reduction has improved the short-term power outlook. And Grand Coulee is nearly full, or as full as it's likely to get this year.

On the other, BPA power schedulers on June 13 warned Technical Management Team members that flows were expected to drop by last weekend--and continue dropping through the rest of the summer--as Coulee operations will only pass along inflow water from now on.

In addition, the latest water supply forecast is down one more MAF from last month, to 55.5 MAF, or 52 percent of average for January-through-July at The Dalles. Add in a new analysis from NWPPC staffers that shows even less benefit to fish from summer spill than spring migrants, and the region has set the stage for another round of debate.

Though preliminary, the Power Planning Council's analysis, shows that listed Snake River fall chinook would get little or no benefit from a continuing spill effort. Using NMFS' own spreadsheet survival model with full BiOp spill (1000 MW-Mo), total system survival would only be about 4 percent to below Bonneville Dam, or 41 fish out of 1,000. "By eliminating spill at all dams, total system survival is 39 fish out of 1,000," said the analysis. The fish don't get much benefit since few even reach the federal projects to begin with, and once they do, most are barged, leaving few to migrate in the river.

Hanford Reach fall chinook would fare a bit better, since many more stay inriver than the Snake fish. With BiOp spill levels, the NWPPC analysis says 245 fish will make it to below Bonneville out of every 1,000 that reach McNary Dam. Without spill, 232 fish would make it below all the dams. With 600 MW-Mo spill, another 10 smolts would make it all the way downstream, says the report.

The analysis, completed by staffer Bruce Suzumoto, was released for public comment June 13. And it notes that BPA is now forecasting lower summer flows than used in the analysis. "Depending on how these flows are allocated between spill and powerhouse requirements," says the report, "these lower flows may tend to decrease Biological Opinion spill levels and make spill comparatively less effective in increasing fish survival."

Federal agency execs met with states and tribes last Friday to begin taking comment on the summer spill issue (The feds' power, financial and biological analyses are available at their Columbia Basin salmon recovery website). BPA spokesman Mike Hansen, who noted the hydro system is still operating in the power emergency mode declared April 3, said discussion over the spill issue boils down to three parts--whether to spill at all, target spill at certain projects like the spring operation, or go for full BiOp spill. "Around the 29th, we'll make a decision," he told NW Fishletter.

Around the first of the month, rumors were flying that BPA had figured it could spill another 200 or 300 MW-Mo worth of water after the spring season. But the situation has become a bit more pessimistic, said Hansen, who noted that the reduced water supply forecast has been released since then.

NMFS presented its own biological analysis at the execs' meeting that estimated inriver survival for fall chinook. From the upper Lower Granite pool to below Bonneville Dam, policymaker Jim Ruff said his agency estimates that about 3.0 percent would survive with 600-MW-months of spill; with no spill that would be reduced to about 2.6 percent. He noted that with full BiOp spill, survival this year was pegged at only 3.15 percent.

Ruff said the little difference in survival from different spill options was probably due to two things. First, survival of fall chinook through the upper pool to Lower Granite is expected to be extremely poor this year, less than 20 percent of the juvenile fish are expected to make it because of the low flows, high temperatures and associated increases in predation. Second, about 80 percent of the fish that reach the dam will be barged, leaving relatively few fish in the river. NMFS estimates that only 1.5 percent to 17 percent of the non-transported fish would even make it to McNary Dam. Therefore, spill at lower river dams would not be affecting many fish.

NMFS had another table in its presentation that showed total system survival (which includes barging fish from lower Snake and McNary dams) from reduced spill options resulted in a reduction of only two-hundredths of a percent, from 3.56 to 3.54 percent, for Snake fall chinook from BiOp spill levels to no spill at all. Ruff cautioned that the analysis included guesses of relative survival of barged fish because no real studies have been done on the subject, so there is "considerable uncertainty" about the results.

Other stocks, though not listed, would get more benefit from spilling, Ruff said. Hanford Reach fall chinook that migrated inriver were estimated to have a 33.4 percent survival rate with 600 MW-Mo of spill (down only 0.5 percent from full BiOp-mandated spill), with a decline to 29.1 percent survival with no spill. The NMFS presentation didn't show how barging affected the total system survival of the Hanford fish or the Deschutes fall run, another stock the agency analyzed for spill benefits.

BPA representatives told execs that their updated power reliability analyses was still too uncertain to make a decision about summer spill. As for financial reliability, the agency reported that the decision to spill another 600 MW-Mo depended on how high next year's power rates will go, and that depends on a variety of factors. Right now the agency is trying to sign on enough public utilities for reduced loads in the future to minimize BPA's reliance on high priced spot power. If enough sign up, BPA says it can keep a rate increase below 87 percent. To sweeten the prospective deals, the feds have told utilities that the deals won't be honored if BPA can't hold rates below that level.

Another confounding factor is the new FERC order that attempts to keep power prices from spiking this summer. The Administration says the new order is not a cap on prices, but the complicated price mechanism does rely on the cost of natural gas in its formulation. -Bill Rudolph


Winter reliability in the Northwest might be compromised by BPA's spill operations to aid fish passage in the lower Columbia. That's what the latest update of the Power Planning Council's March power study seems to suggest. Staff updated Council members on the study at its June meeting. The new analysis includes recent load reductions, expected new generation and some changes in hydro operations.

NWPPC's Dick Watson stressed the uncertainties that remain in the updated analysis, which now sets the probability of the loss of load next winter at 17 percent--down from 20 percent in March. Major conclusions of the update point to much improved reliability if reservoirs return to BiOp levels by the end of September, with 1500 MW-months stored for next year--but that happens only when the highest predicted runoffs are plugged into simulations of a range of synthetic water years provided by BPA that are used to model different scenarios of volume and shape of the runoff.

"With the current runoff forecast," says the latest analysis, "[the] region must trade off restoring spill against storing for winter reliability." The latest forecast calls for a 55.5 MAF water year, down 0.9 MAF from the previous forecast.

"Can we meet our reliability mandate and still spill?" Montana Council member Stan Grace asked Watson at the Council's June 6 meeting in Portland. Watson responded by saying the results of the analysis were not "that precise." A little later, when Grace pressed him again on the issue, Watson said he wouldn't continue spill right now. He had earlier told Council members that the region was right at the "tip point" as to spill, and noted that BPA's reliability model only includes the federal system, while the Council analysis covers the entire Northwest. Another difference, Watson said, is that BPA wants a smaller "buffer"--an extra amount of generation available if a project goes down.

"We're right on the ragged edge," Watson said.

But that wasn't the message from BPA, as the agency continued to spill water for fish. By that Friday, it had amounted to 400 MW-months, according to Karen Hunt, BPA's manager of legislative affairs. She told Council members that the next recommendation for any changes in the four-dam spill strategy would be announced June 8 at a federal execs meeting in Portland.

Most parties felt that BPA would continue spilling at current levels for at least another week. On June 1, acting BPA administrator Steve Wright said spill would probably continue until mid-June, unless the resolution of reliability analyses by different agencies showed otherwise. Wright had earlier acknowledged that up to 600 MW-months' worth of hydro system spill looked possible to aid fish passage.

That Wright had cited the Council's own reliability study as a reason to increase spill had some Council members, like Montana's Grace, in a huff. "The feds are rationalizing why they're doing this," he said.

Council chair Larry Cassidy agreed that BPA was not communicating well with them. He wanted the federal agency to "get in sync with us."

Washington's other representative, Tom Karier, pointed out the marginal benefits of the spill strategy, especially at McNary Dam (NMFS' own model shows survival benefits of less than 1 percent for spring chinook from the every-other-day spill at McNary).

"We're interested in what you're interested in," said BPA's Hunt, "working better together."

In the end, the Council voted to release its reliability study and called for public comment. But just how reliable it is, is still the big question. NWPPC staffer Watson made that point more than once. Referring to one graph that analyzed spill options and the ability to store water, he was especially blunt. "This chart implies an awful lot of precision that's not there." -B. R.


FERC released a June 1 order that paves the way for a possible spill swap between Grant PUD and BPA--and goes much further. So far, in fact, that PUD spokesmen admitted they were stunned by the speed and intensity of the order, which suggests that power reliability issues in the Northwest may be critical enough to warrant the complete cessation of all summer spill for fish passage at Grant PUD's two dams. The federal agency recommended a staff alternative that calls for no summer spill and requested comments until June 11. The agency has already included a 45-page environmental assessment of its own proposal in the June 1 order.

The issue is complicated by the fact that BPA may not need the spill swap after all. Grant officials had all but written it off since BPA boosted spill in the lower Columbia May 25, citing an improved power outlook. The swap called for suspending spill at Grant's projects for up to 16 hours a day during the summer. FERC has recommended stopping spill for all 24 hours, citing evidence that most smolts migrate between 8 p.m. and 5 a.m.

FERC said the staff alternative could produce an additional 329,400 MWh, with the first 219,600 MWh offset by BPA under the spill swap, but adding up to a net gain of 109,800 MWh for the region.

Grant spokesman Lon Topaz said his utility would like to reach a regional consensus before any changes to its spill program are made this summer. FERC, on the other hand, made it perfectly clear that such agreement was not necessary, citing "minor, short-term" impacts to non-listed species.

Grant, responding to FERC's request for recommendations for increasing power generation during the West Coast crisis, had originally requested a variance of its spring and summer spill operations to maximize power operations without endangering listed fish. The PUD listed three possibilities for operational changes: generating more power from water not spilled, transferring spill flows to other projects at other times, or storing water not spilled for either fish enhancement or power generation this winter or next spring.

Since the spring spill season is over and no ESA-listed fish migrate past the projects in the summer, FERC said reducing summer spill would have no effect on listed fish, and not much on unlisted ones either. In response to tribal comments about reduced salmon harvest from increased mortality from a potential spill swap, the agency said, "...We are not persuaded that the public interest in providing additional regional reliability is outweighed by a need to prevent any potential impacts to any fish species."

FERC also blew off WDFW's request for mitigation from decreased survival rates of summer/fall chinook from the suspension of spill, since it reduced survival rates by only 4 percent and affected just half the fish.

NMFS supported the spill swap, but not Grant's request to possibly reduce spill by any more than outlined in a set of principles with BPA. However, Puget Sound Energy supported Grant's proposal, but opposed the swap because it would not increase generation and could actually decrease it, since Grant proposed reducing spill only if flow forecasts for June and July fell below certain levels.

FERC pointed out that Puget was incorrect when it said the federal agency had the authority to order any party to generate power during emergencies because that power was transferred to the Secretary of Energy in 1980 by the DOE Organization Act.

Grant's Natural Resources and Regulatory Affairs manager Doug Ancona said his utility does not expect to stop spill entirely this summer. "Grant has never planned to go to zero summer spill. It wasn't something we ever considered." But he acknowledged that FERC could order such a change in operations. -B.R.


Comments on FERC staff's recommendation to kill summer spill at Grant PUD projects were accepted until June 11, after the federal agency ruled June 1 to allow the utility to cut summer spill by two-thirds as part of a potential load swap with BPA. Tepid comments by BPA continued to support the idea of a swap, but didn't address FERC's staff alternative. As one participant said, "Everyone's being exceptionally polite."

"Anticipation of possible reliance on the exchange helped Bonneville to initiate spill to benefit spring migration of anadromous fish while maintaining power system reliability," said BPA in its latest remarks. "The spill exchange may be a valuable contingency tool to exercise during the summer, if necessary to maintain system reliability."

BPA attorney Bill Kinsey said his agency was neither for or against the FERC alternative, but he did say BPA appreciates FERC's approval of the spill principles developed for a potential load swap with Grant PUD. As to whether such a swap will actually happen, Kinsey said BPA is still analyzing the situation in regard to spilling water to aid fall chinook, and it might be an option in a couple of weeks. "Stay tuned," he said.

In its own comments, Grant noted the 16-hour-a-day potential swap was in a state of flux and would probably stay that way until the end of June, though BPA's critical power supply situation seemed to improve, while the water supply forecast was still declining.

Grant said its own proposal "is quite similar" to FERC's recommended alternative, which calls for Grant to base its decision on "need and benefit, and in consultation with other interested parties as more up-to-date runoff and electric load information becomes available."

FERC's June 1 order did not require Grant to have others' concurrence before suspending summer spill--pursuant to the spill exchange--because impacts would be "minor, short-term and limited to non-listed species."

Puget Sound Energy told FERC it should suspend Grant spill "irrespective of regional unanimity" on the spill exchange principles between Grant and BPA. PSE also said Grant may have a potential conflict of interest because it's involved in its relicensing process. "Because Grant PUD's own customer base is small (about 60,000 people live in Grant County)," said Puget, "Grant faces little risk of power outages this summer or next winter for its own customers." With the whole West coast facing a power crisis, FERC should not leave the spill decision up to the PUD, said the IOU.

Comments from tribes, NMFS, Washington and Alaska state fish agencies, and environmental groups take issue with the conclusion from FERC's environmental assessment of the no-spill option. Of all the fish agencies, NMFS was the only one that supported the swap, but nothing beyond that.

WDFW said the spill swap appeared to be a moot issue, because BPA's reliability and cost concerns were reduced. As for fish survival, the agency said FERC had low-balled turbine fish mortality at 4 percent while NMFS said a spill exchange would kill 7 percent more fish.

With more than half of healthy upriver fall chinook passing Priest Rapids Dam--an unlisted stock that contributes to both sport and commercial harvesters--WDFW said increased mortality from juvenile passage "could require curtailment or closure of coastal fisheries in both US and Canadian water in future years."

NMFS said the FERC assessment was too optimistic in its analysis of juvenile survival and pegged an additional 13 percent mortality from the no-spill option. "Despite the exigencies of low snowmelt, high prices and other factors contributing to this year's power situation, NMFS does not believe the evidence establishes a need in the region to support such impacts on anadromous species, especially those vital to healthy tribal fisheries," the feds concluded.

Tribal comments, submitted by the Columbia River Inter-Tribal Fish Commission, took issue with the FERC staff alternative on several fronts. The tribes said FERC's environmental analyses are flawed and do not comply with the agency's obligations as Trustee to affected salmon stocks and tribal treaty fishing rights.

In its June 1 order, FERC argued that its responsibilities under the Federal Power Act "do not require the Commission to afford Tribes greater rights than they would otherwise have under the FPA." Earlier tribal comment asserted that FERC's trust responsibility prohibited the federal agency from balancing tribal interests and any other public interests, but the feds said they were not persuaded that the public interest in providing for more power reliability was "outweighed by a need to prevent any potential impacts to any fish species."

As for the reliability issue, several entities commented that FERC's analysis was wrong.

"FERC's analysis of the Western energy situation is wholly inadequate and fails to consider changed conditions," said the environmental group American Rivers, which also said that the feds failed to adequately consider the new information that shows an improved situation. "FERC's analysis provides no evidence of the need for additional generation beyond general statements that more power is needed," said the group. "Such unsupported assertions do not justify eliminating a critical environmental protection measure." -B. R.


The National Marine Fisheries Service wants 350,000 acre-feet from behind Idaho Power's Brownlee Reservoir by the end of July, to aid spring and summer migrating salmon and steelhead. But Idaho Power says it opposes NMFS's request, and it seems FERC may also be leaning in Idaho Power's direction.

In a May 30 letter to FERC, NMFS not only said it was terminating ESA consultations on the existing license for the Hells Canyon complex, but also directed the commission to "act under its authority to timely require Idaho Power to operate its Hells Canyon complex in coordination with federal efforts to improve the anticipated poor survival conditions for ESA-listed juvenile salmon and steelhead migrants this spring and summer."

Measures that would help the fish include "timely release of water stored in Brownlee Reservoir and pass-through of waters released from upstream federal reservoirs," NMFS' letter said. "We advise that IPC release at least 350,000 acre-feet of water stored at its Brownlee project prior to July 31.

Idaho Power indicated it will resist NMFS' directive. "What this indicates is that the NMFS position has proven itself to be one that would require operation of Hells Canyon in the interest of fish, not energy needs," said IPC spokesman Jeff Beaman. "We strongly believe the migration issues...are problems of the federal government's making," related to federal projects on the Snake River, he added. NMFS "should focus on those rather than looking upstream for water."

NMFS' directive apparently was not too well-received at FERC, either. Mark Robinson, director of FERC's office of energy projects, last Thursday sent letters to both Idaho Power and NMFS, responding to NMFS' directive. Commission staff is reviewing NMFS' request, Robinson told both NMFS and Idaho Power, but needs additional information to assist in that review.

Robinson asked Idaho Power for information on how the IOU proposes to operate Hells Canyon this summer, including "projected flow releases and the extent to which this operation will meet the target flows recommended by NMFS."

In addition, Robinson wants to know "the effect of the recommended releases on reservoir levels and any associated effects on recreation, irrigation and other water uses, and on the amount and value of the project's power generation," as well as "quantitative information" on how the proposed releases would affect Idaho Power's ability to meet customers' power needs during the current year "and an estimate of any additional costs to meet those needs." And if the utility does not intend to release the water per NMFS' request, "provide a detailed explanation of your position."

Robinson's June 7 letter to NMFS assistant regional administrator Brian Brown asked for a bit more information. "Your letter does not provide scientific support for the relief requested, or an explanation of why it is necessary and appropriate for the listed species," Robinson wrote.

Therefore, he asked NMFS to provide the scientific basis for its conclusion that the proposed water release is needed, including "analysis of what action is necessary to avoid jeopardizing the continued existence of any listed species or adverse modification to critical habitat of such species."

FERC also requested "a description of the specific goals that NMFS seeks to achieve through the recommended action," as well as a "detailed response" to FERC's February 1999 biological assessment of the Hells Canyon project, which concluded that ongoing operations do not adversely affect the listed species. In addition, FERC wants NMFS' analysis of the economic and power generation impacts of the releases, "including any analysis" of their impact on the West's summer energy situation, and any NMFS analysis "showing whether the desired resource results could be achieved at lower cost or at a lesser reduction in generation."

Robinson also asked for evidence that "any ongoing harm" to listed species or habitat can be attributed to the Hells Canyon operations, "as opposed to resulting from current drought conditions or actions at other hydropower facilities in the Columbia and Snake River Basins."

Robinson also wanted to know what arrangements NMFS has made with other federal agencies to protect listed species in the Snake River this summer.

In addition, he took NMFS to task for terminating consultation on ESA issues, calling the agency's actions directly contrary to the suggestions of an interagency task force on hydro relicensing. "It is my understanding that negotiations regarding Hells Canyon have been fruitful and, at least from Commission staff's perspective, have not been concluded," Robinson says.

Idaho Power has been conducting what the utility calls an informal collaborative process for its Hells Canyon relicensing. Four environmental groups, including American Rivers and Idaho Rivers United, recently withdrew from the process, citing Idaho Power's decision to withhold information about ongoing studies on the dam's impacts on salmon.

Craig Jones, Idaho Power's Hells Canyon relicensing manager, said the company decided to wait until its studies were complete, rather than release information piecemeal, to avoid an "incomplete snapshot" of the data. "We can't release partial or incomplete information that can be taken out of context and used in another forum," he told NW Fishletter. "We want to make good decisions with good credible science behind them." -Jude Noland


Several recent articles in scholarly journals have given new life to old disagreements regarding the effects of hatcheries and dams that biologists have been arguing about for years. Authors include past participants in the now defunct PATH process, in which regional biologists spent years wrestling with the key uncertainties of salmon recovery strategies.

Charles Petrosky (IDFG), Howard Schaller (USFW), and Phaedra Budy (now at Utah State University) authored an article in the Canadian Journal of Fisheries and Aquatic Science (58: 1196-1207 (2001)) that examines freshwater productivity of young Snake River spring chinook and takes issue with NMFS' new BiOp.

The authors say that compared to the decline of Snake River stocks after the hydro system was completed, the freshwater spawning and rearing (FSR) life stage showed no significant decline. Other factors that occurred while fish numbers decreased, included poorer ocean conditions and "possible hatchery effects."

The authors note that improvements at only the FSR stage are unlikely to sufficiently offset negative impacts from these other factors to ensure recovery of the spring chinook stocks.

They took a parting shot at the new hydro BiOp in their discussion section, noting that "... federal agencies have indicated that hydrosystem impacts may be compensated though off-site mitigation measures, which might improve habitat or change hatchery practices. Based on this premise, some federal agencies believe that dam removal will therefore be unnecessary." They argue that life cycle rates would have to increase nearly threefold to offset hydro impacts--indicating to them an unlikely scenario for recovery.

Hatcheries On The Hot Seat

A paper by NMFS scientists Phil Levin, Rich Zabel and John Williams has made waves over its suggestion that hatchery programs have had a negative effect on wild stocks. Published in The Proceedings of the Royal Society of London, their paper, titled The road to extinction is paved with good intentions: negative association of fish hatcheries with threatened salmon, looks at a 25-year time series of Snake River spring chinook returns and finds a strong negative relationship between the "massive" hatchery effort and wild stocks, "particularly during years of poor ocean conditions."

The authors cautioned that recent climate models predicting a warmer ocean could be devastating for wild fish stocks. "If such models are accurate," the authors say, "the increased mortality of wild salmon associated with high densities of hatchery fish that we observed in years of poor ocean conditions may become more prevalent."

As for using hatcheries to rebuild wild populations, a strategy the region is about to embrace, they say the possibility of negative impacts should be considered.

Doubts Over Data

In Petrosky et al, the authors cited evidence that the Snake stocks were less productive than downriver stocks. But another recent article takes issue with that notion. Consultant Rich Hinrichsen, another PATH participant, published a paper in the same Canadian journal that looks at some of the data used in the PATH analysis and has found that small subsets of information, sometimes even single observations, have a huge influence on results that estimate fish passage survival and the effectiveness of barging fish.

In the upriver/downriver comparison, Hinrichsen found data that showed a large increase in productivity of fish from the Middle Fork of the John Day River in 1968 (the only downriver stock to show such an increase) had the effect of pointing to increased passage mortality for the Snake stocks after more dams were built.

Hinrichsen said expanding numbers of returning fish from index counts of four redds in the Middle Fork and making other assumptions about year-class strength makes the data questionable. "This is not to say that these observations are erroneous," Hinrichsen said, "but that any errors they contain can have a large effect on influences about passage mortality." He pointed to another report (Lindsay, 1986) that cited the use of rotenone in the Middle Fork, a treatment special to that part of the river alone.

In that ODFW report, R.B. Lindsay said "stock-recruitment relationships for the Middle fork do not display the same trends as other streams in the John Day Basin...," and he went on to say that the data fit neither Ricker or Beverton-Holt models. His report cited water quality problems in the region associated with a nearby town and lumber mill, along with a diversion dam that was not removed until 1976. The ODFW report also cited several years from the 1960s to 1980s when chemicals were used to kill predators in various stretches of the Middle Fork, which could have temporarily boosted survival. It raised other questions of methodology as well--the timing of surveys, the small numbers of index redds, and the variability of the index redds and total redds in the Middle Fork. -Bill Rudolph


Little is known about Pacific lamprey, but biologists agree about one thing: there are fewer of them these days. A 1995 BPA-funded study indicated their populations were in steep decline throughout western rivers, but some harvest is still allowed. Tribes catch them for ceremonial and subsistence purposes, and a small commercial catch is allowed as well--the fish are used as bait for sports fishers and as cadavers for school dissection classes. With each lamprey weighing nearly one pound, the average annual harvest is 29,000 pounds.
Courtesy NOAA 

Part of the lamprey's problem has to do with low fecundity; each female lays only 100 to 500 eggs. With juveniles rearing in fresh water for six or seven years, they are exceptionally susceptible to reduced survival where habitat may be degraded. After they go to sea, poor ocean conditions can also have a negative effect, reducing the numbers of returning spawners.

In this way, they are similar to other troubled Northwest species like spring chinook, coho, cutthroat trout and steelhead. But unlike those ESA-protected stocks, no one has filed a petition to study the lamprey's status. Fish agencies have not sought their protection beyond placing them on Oregon's protected species list, although the fish management plan that has governed harvest on the Columbia prohibited commercial fishing for lamprey above Bonneville Dam.

An ODFW natural production program staff study speculates that more of the Columbia Basin population may be relocating into lower basins like the Willamette River. However, the incidental nature of lamprey data has kept biologists in the dark about its real status or abundance. Given that, ODFW staff still recommended a harvest ranging from 17,300 to 14,400 pounds at the falls on the Willamette. The F&W Commission gave the nod to the lesser amount.

"If you are a species in trouble, you better not be on the protected species list because you're a target," said Jim Myron, Conservation Director of Oregon Trout. Myron said there was no biological justification for what the Commission did.

"The lack of information on lamprey is truly stunning, and we could literally be mining what remains of the lamprey," said ODFW Commissioner John Esler.

Three conservation groups, the Native Fish Society, Trout Unlimited, and Oregon Trout agreed with Esler. They proposed a policy that called for harvest only by Native American tribes for ceremonial and subsistence use. Tribal fishermen testified that they wanted to harvest lamprey at Willamette Falls for commercial purposes as well.

The Commission decided to allow a commercial and personal use harvest from June 16 to July 31 on Saturdays through Tuesdays. The Commission thought it would be a sound conservation strategy to provide the lamprey with three non-harvest days a week to give them time to climb the falls unmolested. -Bill Bakke

Note: Bill Bakke is executive director of the Native Fish Society.

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