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[1] TO SPILL OR NOT; THAT'S STILL THE QUESTION
With in-season forecast models churning out less-than- expected estimates of how many fall chinook have passed Columbia and Snake River dams, hydro managers have not yet called for ending spill earlier than the Aug. 31 cut-off date specified in the hydro BiOp.
Two weeks ago, when federal agencies turned down a proposal by Montana to cut spill, BPA head Steve Wright provided critics of current operations a glimmer of hope when he said the agency was still looking at the timing of the fish run to see if the spill program could end a couple of weeks early because most fish had already migrated past the dams. The summer spill program at four dams costs about $1 million a day in lost revenues.
When the computer model shows that 95 percent of the ESA-listed fish have passed the dams, BPA may call for a cessation of summer spill, said Scott Bettin, who represents the power agency at the weekly forum which managers hydro operations. He said that could happen before next Wednesday, when managers meet again to discuss the issue.
The University of Washington passage model, which predicted the run migrating relatively early for weeks now, re-adjusts its estimates as the season progresses, said NOAA Fisheries representative Paul Wagner.
"It appears, if we're not there," said Bettin, "we're really, really close."
At this week's TMT meeting, Bettin said about 94 percent of the ESA-listed Snake run had passed Ice Harbor Dam, where a modified spill program is in place to help less than 500 smolts a day passing the dam by late this week. About 1.4 million smolts were estimated to have migrated through the lower Snake already, with more than 90 percent transferred to barges before they reached Ice Harbor.
Bettin pointed out that the latest survival data from the investigation into spill problems at Ice Harbor shows only a 1 percent potential survival benefit from spill over other passage routes--a combination of dam bypass and turbine routes.
He said that that meant the potential benefit from spill was adding up to six more smolts from the spill effort that day, which cost BPA about $75,000 daily in lost power generation at the dam. Bettin questioned the benefits to fall chinook, since only about one adult returns for every 100 smolts that migrate to sea, and half of the adults are caught, anyway.
But state, federal and tribal managers were not ready to support an end to the spill effort. They were still working on decision criteria for ending spill, and said they should have guidelines ready by early this week.
An Aug. 12 memo from the Fish Pasage Center said run timing was now skewed early by the addition of a large hatchery component to the annual migration. "While the 95 percent passage date for run-at-large is likely past," the memo said, "wild subyearling fish, as measured by run timing prior to supplementation [hatchery fish], reach that point in mid-September."
Meanwhile, a proposal to end spill early that was initiated by Washington state's Power Council members died quickly last week, mired in details of how to split up potential savings between ratepayers and funding more cost-effective fish actions.
Washington memberTom Karier was clearly disappointed. He said that federal agencies were reluctant to offer any specific recommendations for an equitable sharing of benefits from cost savings by reducing spill this year.
"They failed to implement the Council's mainstem program this summer," Karier said. "This was a lost opportunity--the result is less for the fish and ratepayers both." -Bill Rudolph
[2] FEDS KNOCKED AFTER NIXING PROPOSAL TO CUT FLOW AND SPILL
The summer spill soap opera developed some new twists last week after federal agency executives turned down Montana's request to evaluate reductions to flow and spill operations this year. Though the agencies complained that the current state of the Biological Opinion gave them little flexibility to make changes, they were still reluctant to end the discussion, and left an option open for ending Columbia River spill early. By week's end, even the Northwest Power and Conservation Council was working on a recommendation to end expensive spill operations two weeks before the BiOp mandate of Aug. 31.
"We want to explore the issue of run timing and the court," BPA Administrator Steve Wright said, after representatives of both public and private utilities unloaded a barrage of criticism at the feds for not embracing the Montana proposal, which would likely save electric ratepayers $20 million or more a year by ending spill early. Other federal executives on the firing line included representatives from NOAA Fisheries, the U.S. Army Corps of Engineers, the federal Bureau of Reclamation, and the U.S. Fish and Wildlife Service.
"The frustrating aspect is that as absurd as summer spill looks to ratepayers, it appears that some of the federal agencies believe they tied their own hands in the BiOp," said Pat Reiten, CEO of PNGC Power. A federal court would "surely" realize the need to alter a wasteful measure that affects only five ESA-listed adult salmon, he said.
A recent analysis by Power Council staff, which Montana used in its presentation to the federal agency officials, concluded that ending all spill in August would reduce the number of returning ESA-listed Snake River fall chinook by five fish.
Most fish listed for protection under the Endangered Species Act--as well as non-listed fish--have already passed through the hydro system this year. Critics say the millions spent on late-August spill for helping salmon past the dams is a waste of money, a point also made in the Montana proposal.
At the Aug. 5 meeting of federal agency execs, Wright expressed disappointment that "some parties" (read: lower Columbia River tribes) didn't seem willing to discuss cost-effective hydro actions.
Wright said he reluctantly agreed with the others to nix Montana's proposal "because this decision, in my view, does not adequately consider the potential for cost-effective alternatives that could meet our responsibilities to fish while having a lesser negative impact on the regional economy."
Wright said summer spill's calculated biological benefits to endangered salmon appeared to be small, "even under the most optimistic assumptions, relative to the costs of summer spill that total in the tens of millions of dollars."
NOAA Fisheries Regional Administrator Bob Lohn agreed with Wright, that benefits for fish appeared to be small for expensive operations like late summer spill. But he cited the opinion of Justice Department attorneys, who cautioned against changing BiOp operations while the document is being revised on a federal judge's order. Lohn said changing operations was "the judge's decision to make."
BPA's Wright also found himself agreeing with Lohn, pointing out that the power agency's attorneys have advised "exercising caution" when adjusting BiOp measures during the federal court remand. "We don't want to lose control of hydro operations," Wright said.
Critics Fault Feds' Decision
But utility representatives were not impressed with the feds' reasons for turning down the Montana proposal. Steve Marshall, who represents Snohomish County PUD, said the proposal should have been presented before the judge who ordered the BiOp remand, rather than speculating whether he had jurisdiction over these potential changes. "There is no good reason why that has not been done."
He also disputed the notion that Montana's proposal did not include a sophisticated testing protocol to measure effects of spill, another reason the executives cited for nixing it. Marshall said the state's proposal to phase in testing was entirely adequate.
"What we really have now is a test of federal executive decision-making for this reason," Marshall said. "This decision-making process, which has gone on for months now, at its conclusion, where it looks like we're about ready to take no action again, is, in effect, a decision," he said. "It's a decision not to save the money, a decision to trade clear economic benefits for minimal fisheries benefits."
John Saven, of Northwest Requirements Utilities, whose members use about 20 percent of the federal system's power for pumping water for irrigation, said ending the entire summer spill program would lead to BPA rate reductions that would save his members $13.5 million per year.
Saven said August spill alone costs BPA about $38 million, on average. "And doing the math, unfortunately, that looks like about $7.6 million for each of the five ESA-listed fish," he said. "It looks like about $15,500 for the non-ESA-listed fish. Those fish are about 15 pounds apiece. That's about $1,000 a pound for fish that are probably going to be harvested at a rate of 50 percent anyway.
"Those are fairly compelling numbers," Saven said. "I propose, if they are correct, for those of you who are in positions of authority--here's an axiom: 'if something's broken, you fix it,' and I think this is broken."
Though his group has intervened on behalf of federal defendants in the BiOp lawsuit, Saven said they will probably file litigation "at some point in time if we lose the confidence that the federal family and states aren't behind us on this issue." He said the economics, though not the only consideration, are compelling in this situation.
Numbers Disputed
Several tribal representatives disputed the Montana analysis findings of puny biological benefits from summer spill. The tribal reps said 16,000 unlisted fall chinook from the Hanford Reach would be lost if spill ended Aug. 15. But the tribal review was admittedly "preliminary and unsophisticated," according to a spread sheet handed out two weeks ago by representatives of the Columbia River Inter-Tribal Fish Commission.
Andrew Englander from the Save Our Wild Salmon Coalition also spoke against Montana's proposal, reading from a letter sent to the federal agencies by American Rivers, the National Wildlife Federation and other environmental groups, along with some fishing organizations. Recent BPA and council analyses "have attempted to distort" the importance of summer spill for both listed and non-listed fish, the letter said.
But it was the comments from utilities that seemed to have the most effect. "They made a coherent argument," said Washington council member Tom Karier, who represented his state at the Aug. 5 meeting. "I didn't have the answers, and the feds didn't have the answers."
Karier and fellow council member Larry Cassidy began work on a full council proposal they hoped would be presented at this week's meeting in Butte, Montana. The proposal would call for ending summer spill this Aug. 15 and placing some of the savings in a fund to support more cost-effective fish actions. These could include predator control, hatchery improvements and water acquisitions, or investigating fish-friendlier turbine operations.
Karier said he was also calling on federal agencies to develop a quick experimental design that could monitor fish survival after spill is stopped.
"Spill is costing $1 million a day now," Karier said. "Funding these other actions would have far more benefits for fish and ratepayers." He said only 1 percent of the ESA-listed fall chinook may still be in the river by now, since most were barged, anyway.
Karier said he and Cassidy were also influenced by Wright's comments, which helped them get started on developing the new council position. "It's an opportunity we shouldn't lose," he said.
Meanwhile, BPA was still working the issue behind the scenes, quietly trying to develop a deal with the tribes to secure their support to end spill Aug. 15. BPA Vice President Greg Delwiche would not confirm that discussions were taking place, but he did say the agency approached the tribes earlier this summer about buying out part of their harvest. "It was a non-starter," Delwiche said.
However, several sources have told NW Fishletter it's likely that BPA may try to pay for a tribal fisheries enforcement program in return for the tribes' assent to an early end to the spill program this year. The Columbia River Inter-Tribal Fish Commission's $1.3 million enforcement program will not be funded this year under current budget projections for BPA's fish and wildlife program. -B. R.
[3] MONTANA'S CALL FOR CHANGES CLIMBS SHAKY POLICY LADDER
After Montana's request to evaluate flow and spill changes for summer hydro operations received a cool response at last month's Implementation Team meeting in Portland, Montana Gov. Judy Martz called for a meeting among federal executive as soon as possible to resolve the ongoing dispute. She said her state was "willing to provide an equitable and biologically defensible amount of water for important downstream fish needs," but that operational decisions in the hydro system "ripple across many policies and practices of my state and the region." Martz suggested that representatives of the states' governors attend, as well as tribal authorities from the basin.
It's been a while since the execs have gotten together. They met several times during the 2001 power crisis to plan operations, but have interacted little since then. The federal executive committee was officially created in the 1995 Biological Opinion as the final step in a decision-tree process that began at the Technical Management Team level.
Montana has been pushing for changes in hydro operations since last year, when it spearheaded amendments to the mainstem program adopted by the Power Council. But a straw poll conducted before the July 24 meeting indicated little support among regional fish managers for the state's proposal. Although most attendees supported continued discussion of the development of a long-term evaluation plan, they also supported continued BiOp operations.
Litchfield told IT members that Montana's request is part of the Power Council's mainstem recommendation plan and would stabilize summer reservoir releases, resulting in a drop in summer flows at McNary Dam of less than 5,000 cubic feet per second. He said the state called for reductions in spill at lower Columbia dams because such changes didn't significantly impact fish.
But Bob Heinith of the Columbia River Inter-Tribal Fish Commission said the tribes couldn't support reductions in spill, because it would have negative effects on 12 different salmon and steelhead stocks. Down the road, he said the tribes were looking for increases in flows and spill to help fish passage, though he supported more creativity to aid Montana's resident fish. But he said water is needed in August for fish, a position echoed by Howard Schaller, representative of the U.S. Fish and Wildlife Service , who said his agency was willing to look at Montana's reservoir options.
Schaller had irked some participants by saying he knew of no study that showed unemployment rates increased when power rates went up. A representative from Snohomish County PUD took issue with Schaller, noting that his county's business climate had suffered from the rate increases, and residential disconnects were way up as well.
BPA supported the possibility of implementing some of the requested spill reductions, as well as holding more regional discussion of Montana's request. In fact, the agency said if Montana had made its request earlier, BPA might have supported it, since it seemed that changes in operations would be revenue-neutral, as the reduction in power production from lower flows out of Montana reservoirs would be offset by savings from reduced spill in the lower Columbia.
John Palensky of NOAA Fisheries said he had spoken with Regional Administrator Bob Lohn about the issue, and the agency was trying to be attentive to Montana concerns. But NOAA Fisheries was not prepared to recommend going ahead with the proposal, for two reasons. First, reductions in flow and spill would have some negative impact on the species, Palensky said, but the size of those impacts is a subject of debate. Secondly, he said the agency is not prepared to exercise some of the flexibility that's written into the BiOp because of District Court Judge James Redden's directive to implement the BiOp while it's in remand. Flexibility is also reduced by decreasing and very low flows in the mainstem.
"It's encouraging to hear more willingness on everyone's part to explore," said Corps of Engineers representative Jim Athearn. "It's good to get discussion going. We have a new general, and he's very interested in hearing what the region has to say"
To date, Idaho has been the lone Northwest supporter of Montana's request to cut spill, despite the state's efforts to promote its proposal at the forums that govern hydro operations under the BiOp. Montana officials hoped for better luck pressing their case with other Northwest governors, who they hoped would will look beyond the fish issues to the broader economic implications of the proposal. After hours of debate July 23, both Oregon and Washington fisheries managers had voted along with federal agencies and tribes against Montana's request.
BPA has acknowledged that the proposed changes could save the agency money; however, the agency seemed reluctant to promote this view at the July 23 meeting to discuss the proposal. BPA reported in early July that the proposed spill regime could save the agency as much as $20 million to $27 million from power generation in the next fiscal year. But at the July 23 meeting, BPA spokeswoman Suzanne Cooper said Montana's proposal would be "revenue-neutral" this fiscal year; she did not mention that cost benefits would occur the following year.
Cooper's omission did not go unnoticed by Montana.
"I'm concerned that people may not be hearing the full story on operational changes that are proposed in the SOR [System Operational Request]," said John Hines, a Montana member of the Northwest Power and Conservation Council. "Bonneville appears to be looking at only foregone revenues from higher reservoir levels in August and not including additional revenues that will occur in October, when that additional water that was saved over the summer will be released."
Cooper said BPA would study Montana's proposal more closely.
"We hope the [Bonneville Power] Administration has the discretion to factor in the additional revenue that will come from those operations," Hines said.
Montana's proposal calls for drafting its reservoirs only 10 feet in most years for fish-related flow augmentation, instead of the 20 feet required by the current BiOp. The water saved could be used for future power production. Revenues from that additional power could reduce by about 1 percent the rate increase Bonneville plans in 2004 under its safety net cost recovery adjustment clause, Cooper told NW Fishletter.
Any decisions on changes to summer spill should be made within the context of the BiOp, Cooper said at the July 23 meeting, where she also broached the subject of reducing spill in 2003.
"I think we would support continuing to explore reductions in spill under a couple of scenarios," she said. "And we also believe that given what appears to be a somewhat early timing of the migration, there may be an opportunity for early cessation of spill this year."
According to estimates at the time by the University of Washington's Columbia Basin Research group, more than 95 percent of the Snake run will have passed Bonneville by Aug. 15.
Some Northwest utility groups have been pressuring congressional representatives and federal agencies to end spill early this year. But NOAA's Lohn was cautious, noting that the BiOp call for ending spill Aug. 31 is based on data that showed about 95 percent of ESA-listed chinook had passed through the hydro system by then. With this year's fall run migrating somewhat early, Lohn said it seems reasonable to end spill early. But whether the BiOp allows for that, he couldn't yet say.
"The legal people are looking at it," Lohn said. "There's no final answer yet." He added that even though late summer spill may be expensive and provide minimal biological benefits, the BiOp doesn't say to stop doing it when it's too expensive.
NOAA Fisheries is also mindful the current BiOp is being revised under court order, Lohn said. "The current BiOp is now in the hands of the judge, no longer in ours," Lohn said. He said NOAA Fisheries is reviewing Montana's proposal as it crafts the new BiOp: "We will be looking at the value of spill." -B. R.
[4] QUESTIONS RAISED OVER SALMON/PCB STUDY
A July 30 report that said farmed salmon contain five to 10 times as much PCBs as wild salmon has created a worldwide stir over health concerns. But now that more than 75 versions of the fish story have appeared, ranging from the New York Times to the BBC and even showing up on web-based news sites in Saudi Arabia, it seems likely the major media have been duped once again.
The report, conducted by a Washington DC-based consumer organization called the Environmental Working Group, sampled farmed fish from 10 US stores. It reported PCB levels ranged from 5 parts per billion in Chilean farmed fish to nearly 70 ppb in fish from Scotland, with most US and Canadian samples at around 25 ppb. But the EWG report failed to mention that two studies from the late 1990s found that wild salmon contained higher levels of PCBs than the farmed salmon EWG analyzed in last month's scary report, which was not peer-reviewed.
Polychlorinated biphenyls, a class of chemical compounds once used extensively as industrial coolants and in electrical transformers, are suspected of causing cancer in humans at some level. They were banned in 1976, but they remain throughout the environment.
Wild fish get PCBs through the food chain, since the contaminant is highly dispersed in the oceans, especially the northern hemisphere. Some species of salmon, like chinook, that feed at higher trophic levels than chum or sockeye because they eat other fish like herring instead of plankton and tiny shrimp, generally have higher levels of PCBs, since the contaminants typically concentrate by a factor of 10 from one trophic level to the next.
But farmed salmon, which spend their lives in pens, get PCBs from fish meal made from oily fish like herring. The contaminants tend to concentrate in fatty tissue.
However, a 1998 report issued by the Washington Department of Fish and Wildlife found levels of PCBs in Puget Sound chinook comparable to the highest found in farmed salmon in the EWG's report, levels around 74 parts per billion from 34 chinook caught in marine areas, and 49.1 parts per billion for 144 other chinook caught in rivers. Thirty-two coho salmon tested in marine areas averaged 35 ppb.
In another study, Swedish scientists reported in 1998 in the peer-reviewed journal Arctic that wild Copper River sockeye in Alaska contained PCBs at levels of nearly 700 parts per billion (measured by lipid concentration) while they were still in the ocean. The article said the salmon transported the contaminants to lakes where they spawned; the PCBs were then picked up in the diets of fresh water fish like grayling.
NOAA researcher John Stein said dividing the 700 ppb by a factor of 10 would approximate the "wet weight" measurement used in the other studies, which puts the Copper River fish close to Puget Sound chinook in terms of PCB levels.
The EWG researchers didn’t measure PCB levels of wild salmon themselves, but used data reported in an earlier pilot study sponsored by the David Suzuki Foundation, an environmental group based in Vancouver, BC. The pilot study sampled four wild fish and four farmed fish, and its results were published in the peer-reviewed journal Chemosphere in 2002 (Easton et al). The 12-pound wild chinook in that study had the highest level of PCBs of any of the wild fish tested, about 8.5 ppb. Samples from a chum and two sockeye, which feed at lower trophic levels, tested slightly lower. The Easton study found the farmed salmon had PCB levels that ranged from 20-72 ppb, which are in the same range as PCB levels found in the Puget Sound and Copper River salmon.
The environmental groups sponsoring these studies say that consumption of farmed salmon should be limited because of concerns over the PCBs. Their recommendations have been challenged by Prof. Charles Santerre, an associate professor in the Department of Foods and Nutrition at Purdue University and a spokesman for the Institute of Food Technologists.
In an open letter to Chemosphere after the Easton study was published, Santerre disputed the results on several fronts. He said the sample size was too small, and that the article was confusing and could keep people from eating salmon.
Santerre also pointed out that his own research has shown that farm-raised fish "generally are much lower in contaminants because they are fed a commercial feed rather than having to obtain their food in other manners."
Commenting on the EWG report, he pointed out that salmon species are low in harmful contaminants, "like mercury and PCBs, which are common in recreationally caught fish and some commercial fish."
Santerre said the EWG report "incorrectly uses a more conservative or lower allowable limit for PCBs in fish." He said the main risk from PCBs in the diets of pregnant or nursing women and young children is not from an increased risk of cancer, "but rather, that at higher levels, they may result in developmental delays in the young. While a person consuming farmed salmon weekly over a 70-year lifespan may slightly increase their risk of cancer, the heart-healthy benefits to maintaining a diet rich in long-chain omega-3 fatty acids far outweigh the risks," Santerre said.
"The EWG report also suggests that the consumption of farmed salmon is comparable to the consumption of beef, pork and poultry in the US," he said. "Per capita consumption of salmon is two pounds, while consumption of beef, pork and poultry is 191 pounds combined. Therefore, a person will receive more of their PCBs from foods other than farmed salmon." -B. R.
[5] NEW ASSESSMENT OF ESA STOCKS SHOWS REDUCED RISK OF EXTINCTION
An updated NOAA Fisheries analysis of fish stocks in the Columbia Basin shows that the health of nearly all stocks listed for protection under the Endangered Species Act improved in 2000 and 2001. Most fish runs increased in both years, mainly due to improved ocean conditions.
The analysis, which made its public debut July 30 at a meeting of the Columbia Basin Fish and Wildlife Authority in Portland, is NOAA Fisheries' first look at just how much the runs have improved since the agency implemented its 2000 Biological Opinion. The BiOp spells out 199 different actions needed to recover chinook, sockeye and steelhead stocks that have been listed under the ESA.
The new assessment shows that the number of spring chinook returning to many index streams in Idaho has significantly improved the fish's chances of recovery in the past three years. Only steelhead in Idaho and the upper Columbia River seem to have shown little improvement in the past two years.
The steelhead results are "likely to be an error," NOAA Fisheries Regional Administrator Bob Lohn said. This is because the results don't track from the large numbers of wild steelhead that have returned to the basin in the past few years, he said. The steelhead work will be re-done, Lohn added.
The new assessment, called the "lambda" analysis, estimates the rate of change needed to reduce a stock's extinction risk to only 5 percent over the next 100 years. Overall, the lambda analysis will be only one measure out of several metrics that his agency will use to complete the status update, Lohn said. NOAA will also look at population sizes, trends in population and underlying causes of decline as it develops a new jeopardy analysis while the current BiOp is being revised under court order.
The latest analysis shows less risk of extinction for Snake River spring and fall chinook, but it also shows Snake River steelhead aggregations going both ways.
The extinction risk of upper Columbia chinook also seems to be declining, but risk to upper Columbia steelhead may be increasing, according to the new assessment--which also noted that a future change in methodology should show better numbers for steelhead after new calculations are completed.
Lower Columbia chum salmon have improved enough to be at little risk of extinction. The analysis showed that no changes are needed in the chum salmon population size to reduce its risk of extinction.
The changes in status of the fish stocks may result in some stocks being removed from the ESA list by next year, when NOAA finishes re-writing the BiOp to address the concerns of an Oregon federal judge. Lohn said NOAA Fisheries is not simply amending the BiOp, but creating a new one. By the time the new BiOp is finished, he said the fish run data from 2002 and 2003 will also be included, which is likely to reduce extinction risks even further. Returns from those years have also benefited from improved ocean conditions. -B. R.
[6] BAKER LAKE SOCKEYE RETURN BREAKS OLD RECORD
Nearly 20,000 sockeye have returned this year to Baker Lake in the Skagit watershed, setting a modern record for returns.
Not long ago, the run was considered for listing under the Endangered Species Act. In 1985, it nearly bottomed out when only 99 fish returned.
"But within the past decade, we've had six of the ten best returns on record," said Cary Feldmann, PSE's manager of environmental strategies. Returns have averaged 3,000 fish a year since 1925, when Puget Sound Energy built the first of two dams on the Baker River.
Feldmann pointed to good ocean conditions for helping the run, but he said 20 years of fish recovery efforts by the utility, state, federal and tribal partners has been important as well.
The utility traps and hauls the juvenile fish past the dams. When they return, adult sockeye are trucked past both dams to the lake and released at self-contained spawning beaches engineered to mimic prime sockeye habitat, with water piped to flow through spawning gravel.
Sockeye from Baker Lake were planted in the Seattle area's Cedar River in the 1930's and eventually adapted to a river spawning routine. Over 200,000 of them returned to the Cedar this year. -B. R.
[7] CORRECTION
Washington council member Tom Karier was misquoted in NW Fishletter 165's story #1 on the power council spill analysis. Referring to possible mitigation for potential fish losses from reduced spill, he did not say "We've got to be sure we're not erring on the side of the fish," as reported, but "We've got to be sure we're not erring on the side against the fish." Karier said his point, "which admittedly could have been clearer, was simply to support the principle that reductions in summer spill have the potential to benefit ratepayers and fish but only if there is an appropriate amount of funding set aside for mitigating actual fish losses."
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Link/Document AnnexLINKS/DOCUMENTS FROM NW FISHLETTER 166:: Below are listed links and documents referred to in the text of NW Fishletter issue 166.
- PCBS in Farmed Salmon, Factory Methods, Unnatural Results, Environmental Working Group, 2003
- Spatial Trends in the Concentration of PolychlorinatedBiphenyls (PCBs) in Chinook (Oncorhynchus tshawytscha)and Coho Salmon (O. kisutch) in Puget Sound and Factors Affecting PCB Accumulation: Results from the Puget Sound Ambient Monitoring Program Sandra M. O'Neill, James E. West, and James C. Hoeman, WDFW,
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