IEAB Independent Economic 

Analysis Board

Kenneth L. Casavant, Chair 

Roger Mann, Vice-Chair 

Joel R. Hamilton 

Daniel D. Huppert 

Noelwah R. Netusil 

Lon L. Peters 

Susan S. Hanna 

Hans Radtke 

 

Scoping for Feasibility of Columbia 

River Mainstem Passage CostEffectiveness Analysis 

Independent Economic Analysis Board 

Task 85 Report 

November 2004 

 Document IEAB 2004 - 2
IEAB Juvenile Passage Cost-Effectiveness page ES-1 

Executive Summary 

The Independent Economic Analysis Board (IEAB) has been asked to review current 

information about Columbia River mainstem bypass spill and alternative juvenile passage 

strategies to determine if the information base can support a formal cost-effectiveness 

analysis (CEA) of any passage options, and if so, how the information can be 

characterized to represent the range of opinions about the effectiveness and costs of 

bypass spill and passage alternatives. 

For purposes of this analysis the IEAB defines a cost-effective scenario as one that 

reduces net costs (power revenue losses plus costs of passage actions) and increases 

juvenile survival relative to the status quo scenario. Therefore, our scoping is concerned 

with quantitative information about power revenues, passage costs and juvenile survival. 

In early 2004, Bonneville Power Agency (BPA) and the U.S. Army Corps of Engineers 

(USACE), the “Action Agencies” proposed to modify bypass spill operations at the 

Federal Columbia River Power System (FCRPS) dams while providing “offsets” to 

compensate for the reduced juvenile survival caused by the reduced bypass spill. The 

scope of the review includes analysis, comments, and response to comments in relation to 

the “Preliminary Proposal for FCRPS Summer Juvenile Bypass Spill Operations” (BPA 

and USACE, 2004a) released March 30, and the “Amended Proposal for FCRPS Summer 

Juvenile Bypass Operations” (BPA and USACE 2004b), released June 8. We also 

describe the proposed revised BiOp as provided by the Amendment to the 2004/2004-

2008 Implementation Plan, (USDC 2004c).1 For the purposes of this paper, the status quo 

for spill requirements is defined by NOAA Fisheries’ 2000 Biological Opinion for 

FCRPS Operations.

Our descriptions of the proposals and comments include text related to cost-effectiveness 

taken verbatim from the documents. This body of information provides a current and 

detailed information base that reveals the range of opinions about the cost-effectiveness 

of summer spill as compared to other actions to increase salmon and steelhead runs. 

Our review finds that 

• Conclusive and complete CEA of the modified spill proposals and offsets is 

currently not feasible because of a large amount of uncertainty regarding their 

survival effects, because survival effects of some offsets have not been estimated, 

and because some offsets were not well-defined. Still, we are able to provide 

some CEA that reflects the range of uncertainty. 

• Our review highlights areas of uncertainty most important to the feasibility and 

cost-effectiveness of actions intended to improve juvenile survival. These are: 

 

1

 On July 28, Judge Redden in the District Court of Oregon ruled in favor of a motion for a preliminary 

injunction to stop implementation of a modified summer spill proposal. As of September, bypass spill in 

2004 conformed to the 2000 BiOp. 
IEAB Juvenile Passage Cost Effectiveness page ES-2 

passage timing, smolt-to-adult survival rates, effects of spill on pool survival, 

delayed mortality of transported juveniles, and water quality factors (primarily 

temperature and dissolved gas). 

• More advance planning might increase the acceptability of a spill reduction/offset 

package. It is difficult to propose offsetting actions for a migration season that 

will begin within months, because most actions take time to implement. Some of 

the most promising offsets, Removable Spillway Wiers (RSWs) for example, 

could not be considered for the 2004 migration season. 

• Some stakeholders might have been more supportive if more time had been 

allowed for comments, and if stakeholder proposals had been more directly 

included in the modified proposals. 

• Some offsets were criticized because stakeholders felt they should be regarded as 

BiOp actions. There needs to be a clear distinction between actions included in 

the BiOp baseline, and actions above and beyond the BiOP. 

If it can be assumed that the Action Agencies’ proposals and analysis are correct, then a 

number of cost-effectiveness implications follow. 

• The Preliminary Proposal suggests that reduced bypass spill and proposed offsets 

would be cost-effective for Hanford Reach fall run chinook stocks. However, the 

package is not shown to be cost-effective for other non-listed stocks or for the 

ESA-listed Snake River fall run stock because quantified survival losses are larger 

than quantified survival increases from offsets. 

• The Amended Proposal includes actions intended to fully compensate for reduced 

survival of ESA-listed Snake River wild stocks. The key action is increased 

outflow from Brownlee Reservoir. For this ESA-listed stock, the Amended 

Proposal judges this action to be adequate for offsetting reduced spill. Survival 

benefits from augmenting the pikeminnow program are shown, but because of an 

issue involving BiOp requirements, the pikeminnow program augmentation is not 

counted as an offset. 

• The Amended Proposal suggests that reduced bypass spill and proposed offsets 

would be cost-effective for the Snake River fall chinook wild and hatchery stocks, 

for the Hanford Reach natural stock, and for all non-listed stocks (including 

Hanford Reach) taken as a group. The cost of all proposed offsets ($10 million 

annually) is forecast to be less than the increased revenue from reduced bypass 

spill ($33 to $44 million annually). 

• The pikeminnow program augmentation is not counted as an offset. However, an 

analysis is presented in an appendix to the Amended Proposal (BPA and USACE 

2004d) showing that, for most non-listed stocks, the amount of survival increase 

from pikeminnow program augmentation is less than the survival reduction from 
IEAB Juvenile Passage Cost Effectiveness page ES-3 

reduced spill. For these stocks, survival benefits from other offsets (habitat 

improvements for natural fish and hatchery actions) are not quantified. Therefore, 

for these non-listed stocks, the analysis provided by the Amended Proposal does 

not show that proposed offsets can increase survival enough to compensate for 

reduced spill, even if the pikeminnow augmentation program is counted as an 

offset. 

• The Amendment to the 2004/2004-2008 Implementation Plan for the FCRPS 

Biological Opinion Remand (the Revised BiOp) issued in June 2004 proposed 

relatively small changes to the Amended Proposal. At Ice Harbor and John Day, 

BiOp spill would end on August 25 instead of August 21. NOAA Fisheries 

(USDC 2004) finds that survival increases for Snake River fall chinook salmon 

from increased Brownlee releases are adequate to offset survival reductions from 

reduced bypass spill. Based on this opinion and likely power benefits and costs, 

the Action Agencies argued that this change is likely to be a cost-effective change 

for management of the Snake River fall chinook stocks. Again, increased net 

survival and cost-effectiveness were not demonstrated for the majority of the 

affected Columbia River stocks 

There is substantial controversy about many factors affecting the cost effectiveness of 

mainstem actions. 

• Tribal interests, environmental groups and fish and wildlife agencies raised many 

issues with the biological analysis used to support the Preliminary Proposal. 

Taken at face value, the juvenile survival issues raised by the comments imply 

much uncertainty regarding the cost-effectiveness of the Preliminary Proposal. An 

alternative analysis provided by CRITFC suggests negative effects on ESA-listed 

adults about 10 to 15 times as large as the Action Agencies’ analysis. An analysis 

provided by the Fish Passage Center (FPC) suggests negative effects about 10 to 

20 times as large. 

• Most controversy is associated with juvenile survival and smolt-to-adult returns. 

Some important areas of controversy involve passage timing, smolt-to-adult 

survival rates, effects of spill on pool survival, delayed mortality of transported 

juveniles, and water quality factors, primarily temperature and dissolved gas. 

• There is much less debate about changes in power production and revenue savings 

from bypass spill reductions, and about the costs of the offsets. 

Table ES-1 shows the range of estimated effects on adult fish based on analysis provided 

by the Action Agencies and selected commenters. Alternative estimates were selected 

because they represent different opinions, not because the opinions have any more or less 

scientific merit.2

 Table ES-1 reveals the range of impacts suggested by the Preliminary 

Proposal and comments, and it shows that, for some stocks, estimated survival benefits of 

offsets were not large enough to compensate for losses from spill reduction. 

 

2

 The IEAB is not qualified to evaluate biological information and arguments. 
IEAB Juvenile Passage Cost Effectiveness page ES-4 

Table ES-1. 

Estimated Change in Adult Returns Under Preliminary Proposal. 

Action Agencies’ Estimates, and Alternative Estimates 

Change in Number of Adults Caused by Action 

Losses from Preliminary Spill 

Proposal 1.

Gains from Hanford 

Reach AntiStranding 2.

Gains from 

Pikeminnow 

Augmentation 3.

Net Effect of All 

Actions 

 Agencies FPC CRITFC Agencies WDFW Agencies Alternate Agencies FPC 

ESA-listed Snake 

River Fall Chinook -2 to -20 -46 to 

-192 

-28 to 

-180 0 0 1 to 11 0 -1 to -10 -46 to 

-192 

Non-listed Hanford 

Reach Fall 

Chinook 

-885 to 

-7,080 

3,916 to 

80,662 

218 to 

4,481 

Other Non-listed 

Chinook 

-690 to 

-5,520 0 0 

250 to 

8,000 0 2,591 to 

76,062 

1. For Agency analysis, the range in adults affected is caused by a range of smolt-to-adult survival rates (SARs) of 0.5 to 

4.0 percent. For FPC, the range is caused by a range of SARs and passage timing. For the CRITFC analysis, the range 

is caused by a range in pool survival and passage timing. 

2. For Agency analysis, the range in adults affected is caused by a range of smolt-to-adult survival rates of 0.2 to 4.0 

percent. Only half of the biological benefit is assigned to the preliminary proposal. Alternate analysis is based on 

comment by State, Federal and Tribal agencies that SAR should be 0.2%, not 4%. 

3. For Agency analysis, the range in adults affected is caused by a range of increase in pikeminnow catch of 5% to 11%, 

and Smolt-to-Adult survival rates of 0.2 to 4.0 percent. The Alternate viewpoint is that additional Pikeminnow funding 

would have an imperceptible effect on juvenile survival. 

• In the comments provided for the Preliminary Proposal, many alternative offsets 

were proposed for reduced spill, and some data on effectiveness and costs were 

provided. For Columbia River stocks, many of these offsets might be reasonable 

and cost-effective alternatives to bypass spill. Quite possibly, some of these may 

be cost-effective alternatives to the offset actions proposed by the Action 

Agencies. 

• In the Preliminary Proposal and comments to it, there was no analysis of any 

offset or combination of offsets that would compensate for reduced spill impacts 

on ESA-listed Snake River wild stocks (see first row and last two columns of 

Table ES-1). The Amended Proposal includes increased outflow from Brownlee 

Reservoir, but it is not clear that this offset would have the intended benefits, and 

because of water temperature effects, could actually be counterproductive. 

The IEAB is unable to make an unambiguous statement about cost-effectiveness of spill 

reductions because 1) some of the necessary biological information has not been 

provided, and 2) where information is disputed, we are not qualified to judge and resolve 

the disputes. To obtain more definitive results, new information about some of the offsets 

is required, and judgements regarding the disputed information are required. The IEAB’s 

role simply does not include such judgements. 

Clearly, there is a need for a process that can include offsets such as RSWs that can only 

be implemented in the long run. The 2004 process for proposing spill reductions and 

offsets was simply too short to consider all forms of potential offsets. A long-term 
IEAB Juvenile Passage Cost Effectiveness page ES-5 

process would also be better able to involve stakeholders, conduct the necessary research, 

resolve key issues, and recommend changes in a fully inclusive and scientific way. The 

Council should continue to encourage research and processes that might reduce the 

biological uncertainties, evaluate alternatives to spill, and identify cost-effective 

outcomes.
IEAB Juvenile Passage Cost-Effectiveness page 1 

1. Introduction 

Section §4(h)(6)(C) of the Northwest Power Act requires that the Council “will utilize, 

where equally effective alternative means of achieving the same sound biological 

objective exist, the alternative with the minimum economic cost.” Section 

§4(h)(10)(D)(vi) states that “in making its recommendations to BPA, the Council shall 

determine whether the projects employ cost-effective measures to achieve program 

objectives.”3

Since the energy crisis of 2000-01 and the ensuing BPA financial difficulties, increasing 

attention has been paid to the cost-effectiveness of fish and wildlife mitigation programs. 

In particular, the cost-effectiveness of spill for juvenile passage has come under increased 

scrutiny. The Council’s 2003 Mainstem Amendments to the Columbia River Basin Fish 

and Wildlife Program call for “a rigorous evaluation of the biological effectiveness and 

cost of spillway passage.” The stated goal of the evaluation would be to “determine if it 

is possible to achieve the same, or greater, levels of survival and biological benefit to 

migrating fish as currently achieved while reducing the amount of water spilled, thus 

decreasing the adverse impact on the region’s power supply.”4

Partially in response to this Council objective, the Independent Economic Analysis Board 

(IEAB) undertook Task 79 - Preliminary Analysis of Mainstem Program Cost 

Effectiveness. The IEAB’s analysis illustrated how certain alternative mainstem actions, 

all having the objective of improving juvenile survival, could be compared in terms of 

cost effectiveness. The IEAB analysis showed that there are likely to be alternative 

actions that are far more cost effective than summer spill in improving juvenile survival. 

The work under Task 79 was highly constrained by design. The analysis only considered 

one scenario of reduced juvenile bypass spill, that being cessation of bypass spill at Ice 

Harbor in August. This scenario was judged to be relatively uncontroversial in that, in 

comparison to the entire Columbia basin, there are relatively few stocks in the Snake 

River, the out-migration of most stocks is done before August, and a large amount of data 

are available about passage survival. All non-spill actions considered in the preliminary 

analysis involved passage improvements at Snake River facilities, or passage 

improvements at Lower Columbia facilities that would benefit all Columbia basin stocks. 

No spill modifications were considered that could be detrimental to Columbia River 

stocks. 

The purpose of this report is to investigate the potential and limitations for formal, 

quantitative cost effectiveness analysis (CEA) of mainstem Columbia River spill actions 

using currently available data. In particular, our purposes are 

 

3

 Northwest Power Act, 94 Stat. 2710, as amended by Pub. L. 104-206 §5124(h)(6)(C) 

§512(4)(h)(10)(D)(vi) September 30, 1996 110 Stat. 3005 

4

 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program, NPCC Council 

Document 2003-11. Page 19. 
IEAB Juvenile Passage Cost Effectiveness page 2- 

• To investigate the feasibility of expanding the scope of cost-effectiveness analysis 

to mainstem Columbia River spill actions, including spill and offsetting actions; 

• To identify specific information issues that must be resolved before defensible 

quantitative analysis can be provided. 

The analysis is conducted using information generated by the 2004 proposals for bypass 

spill modification. Specifically, we review the Preliminary and Amended Proposals, 

background documents, comments, and the Action Agencies’ response to comments. We 

summarize these documents, identify issues, and characterize uncertainty associated with 

potential cost effectiveness analysis as applied to juvenile passage in the entire Columbia 

system. The IEAB defines cost-effective, for purposes of this review, as achieving the 

same, or greater, levels of survival while increasing net financial returns (revenues minus 

costs) to the power system. 

2. Summary of the Preliminary and Amended Proposals 

and Revised BiOP 

2.1 Proposed Changes to Mainstem Bypass Spill 

The Preliminary Proposal, released March 30, 2004 by Bonneville Power Agency (BPA) 

and the U.S. Army Corps of Engineers (USACE; together, the Action Agencies) 

proposed to change bypass spill for three years (2004 to 2006, BPA, USACE, 2004a) and 

provide mitigation in the form of “offsets.” August bypass spill at Ice Harbor, John Day, 

The Dalles, and Bonneville would have ceased. In July, bypass spill at the Dalles and 

John Day would not have changed. Proposed changes to operations at Ice Harbor and 

Bonneville in July are shown in Table 1. 

The June 8 Amended Proposal, incorporating many comments as discussed in the next 

section, proposed a one-year reduction in summer spill operations and would have 

provided mitigation using offsets. Presumably, some spill reduction would have 

continued in future years and offsets for 2005 and 2006 were discussed. July bypass spill 

at The Dalles and John Day would not change from the Biop. At the other two facilities, 

tests of alternative spill regimes would be conducted. For 2004, as compared to the 

Preliminary Proposal, less spill reduction was proposed for Ice Harbor and John Day. At 

Ice Harbor and John Day, bypass spill would cease on August 21 instead of July 31. 

The Amendment to the 2004/2004-2008 Implementation Plan for the FCRPS Biological 

Opinion Remand (the Revised BiOp), released June 23, 2004, made relatively small 

changes to the Amended Proposal. At Ice Harbor and John Day, BiOp Spill would have 

ended on August 25 instead of August 21. 

Changes in spill proposed by the Preliminary and Amended Proposals and the Revised 

BiOp are shown in Table 1. Offsets are discussed in Section 2.3. 
IEAB Juvenile Passage Cost Effectiveness page 3- 

Table 1. 

Summary of Bypass Spill Under 2000 BiOp, the Preliminary Proposal, the Amended Proposal, 

and the Revised BiOp1. 

Ice Harbor John Day 

BiOp 2. Preliminary 

Proposal 

Amended 

Proposal 

Revised 

BiOp 

BiOp Preliminary 

Proposal 

Amended 

Proposal 

Revised 

BiOp 

July 45 kcfs 

day, 120% 

TDG night 

Test 3 45 

kcfs to 

7/15, no 

spill 7/16 to 

7/31 

Test 3

45 kcfs to 

7/15; 

BiOp 

7/16-31 

Test 3

45 kcfs 

to 7/15; 

BiOp 

7/16-31 

30% of 

flow, 24 

hours 

BiOp BiOp BiOp 

August Same as 

July 

No spill BiOp 

through 

8/21; 

no spill 

8/22-31 

BiOp 

through 

8/25; 

no spill 

8/26-31 

Same as 

July 

No spill BiOp 

through 

8/21; 

no spill 

8/22-31 

BiOp 

through 

8/25; 

no spill 

8/26-31 

The Dalles Bonneville 

BiOp Preliminary 

Proposal 

Amended 

Proposal 

Revised 

BiOp 

BiOp Preliminary 

Proposal 

Amended 

Proposal 

Revised 

BiOp 

July 40% of 

flow, 24 

hours 

BiOp BiOp BiOp 75 kcfs 

day, 120 

TDG night 

Test 3

50 kcfs, 24 

hrs 

Test 3

50 kcfs/ 24 

hrs 

Test 3

50 kcfs/ 24 

hrs 

August Same as 

July 

No spill No spill No spill Same as 

July 

No spill No spill No spill 

1. Preliminary Proposal is for 3 years. Amended Proposal is for 2004. 

2. kcfs = thousand cubis feet per second. TDG = total dissolved gas. 120% is a percent of saturation. 

BiOp means NOAA Fisheries’ 2000 Biological Opinion for FCRPS Operations. This is the existing, 

status quo condition for bypass spill.

3. The Ice Harbor test would alternate BiOp spill with 45 kcfs spill, 24 hours. The Bonneville test is the 

same, but with 50 kcfs instead of 45.

Source: Preliminary Proposal (2004a), Amended Proposal (2004b), and Amendment to the 2004/2004-2008 

Implementation Plan, 2004c
IEAB Juvenile Passage Cost Effectiveness page 4- 

2.2 Action Agencies’ Estimates of Juvenile Survival Reductions 

with Reduced Spill 

The Proposals recognized that, without offsets, survival of fall run Chinook salmon 

juveniles and upper Columbia summer chinook would be reduced by the proposal. Table 

2 provides the Action Agencies’ estimate of additional losses of juvenile salmon caused 

by reduced bypass spill in the Preliminary Proposal. Results of three different analyses 

are shown in Table 2:,two different analyses of the preliminary proposal spill levels 

presented in the Amended Proposal, and the analysis in Appendix A of the Amended 

Proposal. The two additional analyses were provided to respond to numerous comments 

about the original SIMPAS analysis (see section 3.0 below). “These estimates reflect 

impacts of our March 30 spill curtailment proposal – which will be greater than those 

estimated for the lower level of spill curtailment we are now proposing.” (BPA and 

USACE, 2004b) 

The Revised BiOp presented estimates of impacts to Snake River fall run chinook salmon 

from reduced spill and offsets. Ranges were provided that depended on the assumed 

smolt-to-adult ratio (SAR). Reduced spill was expected to reduce adult escapement by 1 

to 37 fish.
IEAB Juvenile Passage Cost Effectiveness page 5- 

Table 2. 

Survival Reductions Caused by Reduced Spill in Preliminary Proposal, Change from Biop 

Spill, for Affected Runs 

Preliminary Proposal 

Spill Levels, Modified 

Analysis 

Amended Proposal 

Appendix A 1.

Number 

Juveniles 

Agency 

Estimate 

Number 

Juveniles 

NOAA 

Approach 

Number 

of Juveiles 

Decline in 

% Survival 

ESA-listed Runs 

 Fall Chinook Bright, Wild Snake River 143-193 143-943 900 0.50% 

TOTAL LISTED 143-193 143-193 900 0.50% 

Runs Not Listed 

 Fall Chinook, Upriver Bright 

 Priest Rapids & Ringold Springs Hatcheries 

72,000 to 

172,000 

25,000 to 

174,000 72,000 1.70% 

 Hanford Reach Natural 

177,000 to 

423,000 

61,000 to 

425,000 177,000 1.70% 

 Yakima River & Marion Drain 

5,000 to 

10,000 

5,000 to 

19,000 5,000 1.60% 

 Fall Chinook, Snake River Bright 

 Unlisted Lyons Ferry Hatchery 

1,000 to 

2,000 

1,000 to 

8,000 1,000 0.50% 

 Unlisted Nez Perce & Big Canyon 

 Hatcheries 

1,000 to 

1,000 

300 to 2,000 

1,000 0.50% 

 Fall Chinook, Mid-Columbia Bright 

 Deschutes River 

10,000 to 

24,000 

8,000 to 

23,000 10,000 2.20% 

 Klickitat River 

13,000 to 

32,000 

10,000 to 

32,000 13,000 1.00% 

 Umatilla River 

5,000 to 

14,000 

4,000 to 

11,000 5,000 4.50% 

 Little White Salmon River 

7,000 to 

16,000 

5,000 to 

16,000 7,000 1.00% 

 Upper Columbia Summer Chinook 

18,000 to 

43,000 

10,000 to 

32,000 18,000 1.70% 

TOTAL UNLISTED 

308,100 to 

737,700 

130,000 to 

742,000 315,000 1.60% 

1. BPA and USACE. 2004e 
IEAB Juvenile Passage Cost Effectiveness page 6- 

2.3 Proposed Offsets and their Effects 

2.3.1 Preliminary Proposal Offsets 

The Preliminary Proposal included “offsets” proposed as compensatory increases in fish 

abundance or survival to match or exceed fish losses from curtailed spill. The offsets 

proposed were: 

• Northern pikeminnow management program augmentation, and 

• Hanford Reach anti-stranding operations 

The augmentation of the northern pikeminnow management program would have 

included focused removals of this predatory fish from Bonneville, The Dalles, and John 

Day forebays and tailrace boat-restricted zones as well as a general increase in the reward 

structure of the sport-reward fishery to provide systemwide enhancement and benefit to 

all affected stocks. 

The Hanford Reach anti-stranding operations would have obligated BPA to maintain 

certain outflows from the federal projects upstream of Priest Rapids Dam so that Priest 

Rapids could provide adequate, sustained flows to the Hanford Reach immediately 

downstream. BPA would deliver Grant PUD amounts of energy to mitigate generation 

losses that Grant would incur from operating Priest Rapids to limit hourly and daily flow 

fluctuations. 

The total change in survival to adults from reduced bypass spill and offsets was estimated 

by the Action Agencies. This analysis suggests that the two offsets would not entirely 

compensate for losses to ESA-listed Snake River Fall Chinook caused by the Preliminary 

Spill Proposal, losses to non-listed Hanford Reach Fall Chinook would be fully 

compensated by the Hanford Reach Anti-Stranding program, but pikeminnow 

augmentation might not increase survival of other non-listed Chinook enough to 

compensate for spill reductions. 

Therefore, other actions “were also under consideration as possible offsets.”These were 

• Council Fish and Wildlife Program enhancement (exact actions not specified) 

• Additional flow augmentation from Dworshak Reservoir 

• Tribal harvest enforcement funding 

• Additional or improved artificial production 

• Avian predation research 

• Additional water acquisitions 

• Habitat protection/enhancement 

• Commercial harvest reductions (non-tribal), as available 

• Additional removable spillway weirs (RSWs) 
IEAB Juvenile Passage Cost Effectiveness page 7- 

The Preliminary Proposal requested “comments on which of these might be feasible and 

beneficial as summer spill offsets to fill the remaining gap.” 

2.3.2. Amended Proposal Offsets 

The Amended Proposal provided an expanded set of offsets, and a substantial amount of 

additional modeling and analysis was presented relative to the Preliminary Proposal. The 

Amended Proposal states that “with full consideration of the inherent risks and 

uncertainties involved in any analysis of summer spill impacts, we have determined that 

the package we are proposing will fully offset the impacts of the 2004 proposed operation 

on ESA-listed fish.” The actions proposed for the ESA-listed Snake River Fall Chinook 

are duplicated in Table 3. 

Table 3. 

Offsets Proposed for ESA-Listed Fall Chinook in the Amended Proposal 

2004 2005-2006 

Brownlee flows in July Additional water in Lower Snake 

 Fish passage technologies 

 Harvest reductions 

The most important offset was additional flow to be provided from storage in Idaho 

Power Company’s (IPC) Brownlee Reservoir on the Snake River. BPA negotiated a oneyear agreement with IPC that gave BPA the option to increase water releases from 

Brownlee by 100,000 acre-feet in July. The one-year option agreement provided for BPA 

to pay IPC $1 million for the right to call upon an additional release of 100 kaf from 

Brownlee Reservoir between July 7 and 28, with weekly release volumes of at least 33 

kaf (a flow increase of 2.4 kcfs.) This call option had to be exercised by June 23, and 

when exercised, BPA was to pay IPC an additional $3 million, for a total cost of $4 

million. 

A long-term effort to accelerate installation of RSWs and other technologies would have 

enhanced spill reductions without adverse affects on passage. WDFW recommended 

expedited installation of RSWs or surface bypass at McNary and Little Goose Dams, 

followed by John Day and Lower Monumental Dams, and The Dalles Dam. The Action 

Agencies agreed that surface bypass methods have the potential to provide for lower spill 

volumes than the current operation, with similar or better projected survival. The Action 

Agencies are moving ahead on an expedited schedule to install an RSW at Ice Harbor 

Dam on the Snake River. The Dalles Dam is a high priority in the lower river, where the 

Action Agencies have been planning to install a forebay juvenile guidance device. The 

next Snake River priority identified is Lower Monumental Dam. 

The Amended Proposal states that commercial harvest reduction could be used as a 

supplemental offset only if juvenile stage offsets prove to be insufficient. The Action 

Agencies discussed this concept with Oregon and Washington resource agencies, as well 

as representatives of commercial fishing interests. The proposal would address potential 
IEAB Juvenile Passage Cost Effectiveness page 8- 

impacts to juvenile fish by targeting part of the commercial fishery on hatchery fall 

chinook, thereby reducing harvest of naturally produced fish. The Action Agencies 

proposed a three-stage approach to determine the viability of a selective commercial 

fishery and its potential as an offset to spill reductions. Under this approach, non-tribal 

commercial fisheries might be able to reduce their impact on listed and non-listed 

naturally produced fall run fish without reducing total harvest. 

The Action Agencies anticipated benefits to ESA-listed Snake River fall chinook as a 

result of the recent increase in the northern pikeminnow removal program; however, 

because of an issue regarding the level of the pikeminnow program required by the BiOp, 

the Amended Proposal does not claim any additional benefits for these listed fish from 

this action. 

For non-listed fish, proposed offsets are shown in Table 4. 

Table 4 

Summary of Offsets for Non-listed Natural and Hatchery Fish in the Amended Proposal 

2004 Future year(s) 

Brownlee flows in July Additional water in Lower Snake 

Hanford Reach anti-stranding Hanford Reach anti-stranding 

Pikeminnow control Pikeminnow control 

Lyons Ferry hatchery actions Lyons Ferry hatchery actions 

Habitat improvements for natural fish Habitat improvements for natural fish 

Hatchery actions for other fish Hatchery actions for other fish 

 Harvest reductions 

 RSWs & other fish passage technologies 

Most of these actions have already been discussed in Section 2.3.1. 

At the suggestion of WDFW, BPA funded an action to rear 200,000 subyearling fall 

chinook at the Lyon’s Ferry hatchery to the yearling stage. The suggested offset would 

have released these juveniles at a larger size in 2005. This was expected to increase the 

survival rate of these fish and their subsequent return rates as adults. 

Habitat improvements were proposed to complement the benefits expected from hatchery 

offsets and also provide benefits to affected non-listed naturally spawning populations in 

the Deschutes, Umatilla and Okanogan river basins. The States and tribes recommended 

a number of specific habitat improvements to benefit listed and non-listed fish. The 

Action Agencies would have established a habitat fund in the amount of $2 million in 

2004 to fund habitat projects targeted at benefits to naturally spawning fish affected by 

summer spill reductions. Habitat enhancements would be funded beginning in 2005. 

Survival benefits are not quantified.

By providing additional funding for hatchery actions for specific stocks, the Amended 

Proposal claimed to address diversity in individual river basins. A hatchery fund in the 
IEAB Juvenile Passage Cost Effectiveness page 9- 

amount of $2 million was to be established in 2004 to increase production at specific 

hatcheries, targeting stocks that are affected by the summer spill reductions. BPA funds 

would be allocated first and primarily to fish affected by the summer spill reductions (i.e., 

fall and summer chinook salmon) in subbasins not benefited by other offsets. Survival 

benefits were not quantified. 

The estimated net effect of reduced spill and offsets on non-listed stocks is shown in 

Table 5. 

Table 5. 

Estimated Net Effect of Reduced Spill and Offsets on Non-listed Stocks in 

the Amended Proposal (Total juvenile losses) 

Action Estimated Impact 1

Proposed summer spill operation -130,000 to -742,000 

Hanford Reach anti-stranding +1,094,870 to +1,287,981 

Pikeminnow control +39,252 to +84,549 

Lyons Ferry actions +200,000 

Total Offsets +1,334,122 to +1,572,530 

1. Impacts estimated using “NOAA Parameters,” as described in the text. Estimated total 

run size for non-listed fall chinook is 50 million juveniles (smolts) 

The NOAA survival analysis (USDC, 2004b) for Snake River fall run chinook juveniles 

showed that increased Brownlee flows would increase survival by 730 to 950 fish. 

Reduced spill would reduce survival by 140 to 940 fish, so net survival would increase by 

10 to 590 fish, depending on conditions. 

The Amended Proposal Appendix C (BPA and USACE 2004d) showed estimates of 

benefits of northern Pikeminnow Management Program Augmentation by stock. Table 6 

shows results. For every stock, estimated survival increases from pikeminnow program 

augmentation are less than the survival reductions in Table 2. 

2.3.2. Revised Biop Offsets

The Revised BiOp included increased Brownlee releases of 100,000 AF in July to 

mitigate for impacts to Snake River fall chinook. For Snake River ESA-listed fall 

chinook, this offset was deemed enough to mitigate for the impacts from reduced spill.

Increased control of northern pikeminnow was proposed, but because of an issue 

involving the level of the pikeminnow program required by the BiOp, survival benefits of 

the pikeminnow program were not counted. The Action Agencies’ analysis showed that 

escapement increases from Brownlee flow augmentation alone would be greater than or 

equal to the escapement reduction from reduced spill. 
IEAB Juvenile Passage Cost Effectiveness page 10- 

Table 6. 

Change in Survival of Individual Stocks from Northern Pikeminnow Management Program 

Augmentation 

Percent Change in 

Survival 

Change in Smolts 

Surviving to Bonneville 

Increase in Pikeminnow exploitation rate>>

5% Exp. 

Rate 

Increase 

11% Exp. 

Rate 

Increase 

5% Exp. 

Rate 

Increase 

11% Exp. 

Rate 

Increase 

ESA-listed Runs 

 Fall Chinook Bright, Wild Snake River 0.16% 0.36% 308 678 

Runs Not Listed 

 Fall Chinook, Upriver Bright 

 Priest Rapids and Ringold Springs 

Hatcheries 0.18% 0.40% 7,613 16,338 

 Hanford Reach Natural 0.18% 0.40% 18,659 40,045 

 Yakima River and Marion Drain 0.18% 0.40% 527 1,132 

 Fall Chinook, Snake River Bright 

 Lyons Ferry Hatchery 0.16% 0.36% 381 840 

 Nez Perce Tribal Hatchery 0.16% 0.36% 97 214 

Oxbow and Umatilla Hatchery Releases at 

Hells Canyon 0.16% 0.36% 

105 231 

 Fall Chinook, Mid-Columbia Bright 

 Deschutes River 0.33% 0.72% 1,355 2,955 

 Klickitat River 0.33% 0.72% 4,400 9,598 

 Umatilla River 0.33% 0.72% 380 829 

 Little White Salmon River 0.33% 0.72% 2,200 4,799 

 Upper Columbia Summer Chinook 1. 0.18% 0.40% 3,843 8,246 

 

1. Includes Dryden Ponds, Charlton Pond, Turtle Rock and Similkameen 

Source: BPA and USACE 2004d

2.4 Increase in Power Revenues and Cost of Offsets 

Increases in power revenues and costs of offsets for the Preliminary and Amended 

Proposals are shown in Table 7 below. For the Preliminary Proposal, gross power 

revenues would have been increased by an average of $47 million per year, or $141 

million over three years. After deducting the incremental costs of “offsets”, the 

Preliminary Proposal was expected to provide a net revenue of about $40 million per year 

for three years. This net revenue included additional expenditure of $10 million for the 

fish and wildlife program over 3 years, plus $6 to $15 million of other, unspecified 

offsets. 
IEAB Juvenile Passage Cost Effectiveness page 11- 

Table 7. 

Revenue from Reduced Bypass Spill, Annual Average Costs of Offsets, and Net Revenue, 

Million Dollars per Year 

Action Preliminary Proposal (Million 

$/Yr over 3 years) 

Amended Proposal 

(Million $ in 2004 only) 

Revenue from Additional Generation 

from Reduced Bypass Spill $47 $33-$44 

Enhanced Pikeminnow Program -$1 to -$3 -$1.5 

Hanford Reach Anti-Stranding -$0.1 -$0.1 

Council Fish and Wildlife Program 

Enhancement 

-$3.33 -$3.3 

Placeholder for Other Offsets -$2 to -$5 

Brownlee flows in July -$4.0 

Lyons Ferry hatchery actions -$0.1 

Habitat improvements -$2.0 

Hatchery production increases -$2.0 

Total Cost of Offsets -$6.4 to -$11.4 -$13.0 

Net Revenue $40.6 to $35.6 $20 to $31 

3.0 Information from Comments Received on the 

Preliminary Proposal 

This section discusses some of the quantitative information provided in comments on the 

preliminary proposal. The Action Agencies received 246 comments consisting of 

hundreds of pages regarding the Preliminary Proposal (BPA, USACE, 2004b). In general, 

commenters had strong opinions about the merits of the proposal. Power and water users, 

and representatives of local industries were overwhelmingly in favor of the proposal. In 

general, these groups felt that spill does not improve survival enough to justify its costs, 

and the analysis of survival improvements from the offsets was conservative. 

Tribal interests, environmental groups and fish and wildlife agencies were 

overwhelmingly opposed to the Preliminary Proposal. These groups generally felt that the 

survival losses from spill reductions were understated and the survival increases from 

offsets were highly uncertain or overstated. A variety of comments related to legal and 

baseline issues are not discussed here in detail. However, it should be noted that these 

stakeholders felt that the offsets should not be counted entirely as mitigation for reduced 

spill because part of the expense would restore the level of effort to previous levels 

(pikeminow augmentation) or the action was already required under the status quo 

(Hanford Reach). 

The sections below summarize comments that provide or suggest quantitative 

information that could contribute to a range of cost effectiveness analyses. 
IEAB Juvenile Passage Cost Effectiveness page 12- 

The information included in this section is analyzed because it is different from or adds to 

the Action Agencies’ information. Information that is redundant to that of the Action 

Agencies is not included, as it is already represented in that analysis. 

3.1 Juvenile Survival Reductions from Reduced Bypass Spill 

The Confederated Tribes of the Colville Indian Reservation (Colville Tribes) found that 

“1) the analysis conducted by the federal government and BPA fails to sufficiently 

account for impacts to upper Columbia summer/fall Chinook. . . the upper Columbia 

summer/fall Chinook sub-yearlings are the last fish to migrate through the federal 

hydropower system each summer, and thus, are subject to the highest impacts. . . 

predation may increase with elimination or reduction of spill as spill increases 

velocity in tailraces that disperses predators away from bypass outfalls and below 

turbines where smolts are most vulnerable to predation.”5

 

CRITFC had the following critiques of BPA’s SIMPAS application. 

• Failure to include a life-history approach 

• Lack of an integrated ecosystem and cumulative affects approach. For example, 

water quality, disease, and flows are not considered in the analysis. 

• Failure to evaluate adult fallback loss (upstream-migrating adults spilled over 

dams) from spill curtailment. CRITFC analysis using fallback rates in 2001 

operations under no spill indicates that 11,852 adults could be lost under the 

federal spill curtailment proposal. (The IEAB did not find the information needed 

to back up this estimate in CRITFC’s Attachment E). 

• Failure to consider selection against critical stock genetic make-up and 

biodiversity. The later migrating Hanford Reach juvenile fall chinook contribute 

disproportionately to older, larger age classes. 

• The BPA analysis predicts greater smolt-to-adult survival from multiple screen 

bypass, when empirical information indicates the opposite. 

• The BPA analysis shows a positive response to transportation when empirical 

evidence indicates that many more adults return from juvenile salmon that are left 

in-river than are transported. 

• The BPA analysis assumes static and unrealistic operational conditions 

throughout all of the proposed spill curtailment period. The BPA analysis only 

used average year flows.6

CRITFC provided an alternative SIMPAS analysis. Paraphrasing, the modifications to 

SIMPAS relative to the Action Agencies’ analysis are: 

 

5

 Collville Tribes page 2 

6

 CRITFC page 4 to 5 
IEAB Juvenile Passage Cost Effectiveness page 13- 

At Bonneville, operation of the sluiceway without 50 kcfs spill is too risky to 

implement. We used the TDA summer sluiceway survival of 95% when spill was 

not provided at Bonneville as opposed to 98% used by BPA regardless of spill 

level. At McNary, BPA appears to have used a 97% survival estimate. 2003 data 

indicated that survival from both radio tagged fish and Pit-Tag fish was 89-90%. 

BPA assumed a nighttime spill cap of 125 kcfs while we used a value of 140 kcfs. 

BPA used a 1% change in pool survival at Ice Harbor and John Day and 0.5% at 

The Dalles and Bonneville. We used both the BPA pool mortality values and a 

4% increase in pool mortality at the same four projects to better understand the 

range of impacts that could occur.7

Under these assumptions, survival from Ice Harbor to Bonneville under the BiOp was 

estimated to be 34.6%. Survival under the preliminary proposal was estimated to be 

24.6% or 27.8%, depending on whether the 4% or 1% pool mortality is used, 

respectively. In addition “BPA used an average value for run timing; we employed a 

range to better estimate the impacts to an early or late migration. A range of 25% to 8% 

of the Snake River migrants would still be above Bonneville and below McNary after 

August 1.” 8

 Using an SAR of 0.2, CRITFC estimated the range of impacts on Snake 

River adult fish as shown in Table 8. 

Table 8. 

CRITFC Analysis of Potential Impact of Reduced Spill on Snake River Fall 

Chinook

Number of Adults Percent of the Run 

First percentage rate in parentheses (4% or 1%) is the increase in pool 

mortalitywith spill reduction. The second rate (25% or 8%) is the share of 

Snake River migrants still above Bonneville and below McNary after August 1

 High Impact 

(4% and 

25%) 

Low Impact 

(1% and 8%) 

High Impact 

(4% and 

25%) 

Low Impact 

(1% and 8%) 

Total ESU 720 114 7.3% 1.2% 

Total ESA 180 28 10.7% 1.9% 

The CRITFC analysis indicated a much higher impact to Snake River ESA-listed stocks 

than the Action Agencies analysis, which showed a range of impacts of 2 to 20 adults. 

The impacts to ESA-listed fish in Table 8 are about 10 times greater than the Agency’s 

estimates. The CRITFC comments go on to say that “If we applied a SAR of 0.1 for all in 

river fish and used a delayed mortality of 0.2 and an SAR of 0.015 for transported fish we 

could expect a reduction in basin adult fall chinook of 118,171 to 17,725.”9

The State, Federal and Tribal Agencies (Joint Technical Staff 2004) found that “the best 

available biological data indicate that the elimination of summer spill increases the risk to 

the affected salmon, steelhead, sturgeon and lamprey populations, and the offset 

 

7

 CRITFC, page 6 

8

 CRITFC, page 6 to 7 

9

 CRITFC, page 8 
IEAB Juvenile Passage Cost Effectiveness page 14- 

measures in the Proposal are insufficient for mitigating the biological impacts of 

reductions in spill. The reliance on transportation of fall chinook migrants . . . needs to be 

reconsidered. Analysis of the available data on PIT tagged transported and in-river 

migrating fall chinook indicates that transportation is not benefiting fall chinook survival 

to adult. The impact estimates using SIMPAS ignore uncertainty in passage parameters, 

impacts on adults that fall back over dams, environmental conditions, and biological 

demographics.”10

3.2 Juvenile Survival Improvements from Offsets 

3.2.1 Northern pikeminnow management program augmentation 

The Colville tribes stated that “the proposed offset measures are weak, poorly developed, 

and are deficient in addressing the true impact . . . An increase of 1-2% in the northern 

pikeminnow “Heavy Up” action is not substantial enough to realize any detectable 

reductions in predation on upper Columbia stocks”.11

3.2.2 Hanford reach anti-stranding operations 

The State, Federal and Tribal Agencies (Joint Technical Staff 2004) found that benefits of 

the current anti-stranding program were overestimated. Given the demographic 

parameters on egg-to-fry and fry-to-smolt survival rates, an SAR = 0.2% resulted in a 

predicted number of spawning adults similar to empirical observations. However, using 

an SAR = 4.0% results in an estimated average of 862,438 spawning adults, an 18-fold 

increase over the empirical average. The Preliminary Proposal uses a 4% SAR in its 

estimate of anti-stranding benefits. If the true SAR is 0.2%, then the survival benefit of 

anti-stranding would be overstated by 18-fold.12 

3.3 Alternative Offsets Proposed 

Washington Department of Fish and Game (WDFG) provided a detailed set of alternative 

offsets which they “believe have a realistic probability of providing survival benefits 

commensurate with the loss in survival due to reduction of spill.”13 These proposed 

offsets are summarized below. WDFG provided some quantitative information about 

expected survival increases. Tables 9 and 10 provide a summary. 

 

10 Joint Technical Staff Page 1 to 3 

11 Colville Tribes page 2 and 4 

12 Joint Technical Staff page 4 

13 WDFG Page 1 
IEAB Juvenile Passage Cost Effectiveness page 15- 

Table 9. 

WDFW proposed package to offset effects of potential reduction of summer spill at several 

Columbia River federal dams 

Offset 

Estimated 

Cost, 

Million $ 

Description 

Overwinter 

Acclimation $1.5 Retrofit two existing acclimation ponds (Carlton and Dryden) 

Ringold Hatchery 

Enhancement $7.65

Modification of current trap facility, new incubation building, 8 additional 

concrete raceways, new abatement pond, 20 standard concrete raceways, fix river 

pump system, replace outlet structure, rebuild main intake box, new feed storage 

building, other mods. 

Chandler Bypass 

Reach Unknown

Terminate (or subordinate to a higher instream flow) hydroelectric power 

production at the Chandler Power Plant (CPP). Increase bypass flow from 600 to 

1,400 cfs mid-October to April 

Dole-Beebe 

Acclimation Pond $1.0 Provide a half-acre pond, or several smaller ponds, plus pump and additional 

water rights on the Dole-Beebe property near Chelan, WA. 

Northern 

Pikeminnow 

Removal

$0.504 

Restore registration stations to 2003 level. “Heavy-Up” Northern Pikeminnow 

Sport Reward Fishery. More dam angling and site-specific removal. Contract out 

commercial fishers and purchase gear. 

Snake River 

flow/temperature 

supplementation 

$4/yr just 

for 

Brownlee 

Draft Dworshak to 1500’ elevation by Sep. 15. Provide 100kaf additional water 

in July from Brownlee 

Hanford Reach 

flow stabilization Unknown Provide more seasonal sideboards on flow fluctuations through the Hanford 

Reach. 

Expedited 

installation of 

RSWs/surface 

bypass 

Unknown McNary Dam and Little Goose Dam (2006), John Day Dam and Lower 

Monumental (2007), and Dalles Dam (2008). 

Big Valley Ranch 

Wildlife Area well 

conversion and 

side channel 

enhancement 

$0.306 Sacrifice the Rockview screen and irrigation ditch, with restoration of this to 

historic side channel and riparian habitat. 

Steigerwald 

Lake/Gibbons 

Creek Restoration 

$3.463 Reconnect the former Steigerwald Lake bed and wetlands to the Columbia R., 

and restore unobstructed fish passage into Gibbons Creek. 
IEAB Juvenile Passage Cost Effectiveness page 16- 

Table 10. 

WDFW Proposed Offsets: Runs Benefited and Quantitative Information 

Offset Runs Benefitted Quantitative Information 

Overwinter 

Acclimation 

Upper Columbia River 

summer Chinook 

CWT analysis of the 1994 and 1995 brood 

Wenatchee River summer chinook indicated a 160% and 266% 

increase in smolt-to-adult (SAR) survival for fish over 

wintered on river water in the Wenatchee and 

Similkameen versus well water at a central hatchery facility 

(Eastbank Fish Hatchery). A similar study on Methow River 

summer chinook resulted in an 83% increase in SAR. 

Ringold Hatchery 

Enhancement 

Upriver Bright (URB) fall 

Chinook smolts, 

spring chinook smolts 

summer steelhead 

500,000 spring Chinook smolts, thus returning the production 

to 1 million. Other runs not quantified 

Chandler Bypass 

Reach Yakima River fall chinook. 

Current production in the bypass reach is 100 to 200 redds. 

Redd surveys will enumerate total redds formed and estimate 

fry production to quantify project prior to and subsequent to 

implementation. 

Dole-Beebe 

Acclimation Pond

Upper Columbia River 

summer chinoo Improve SAR from current, which is about 0.2% 

Northern 

Pikeminnow 

Removal

All anadromous salmonids Slight increase in adult returns on the order of 0.5%-1.0%. 

Snake River 

flow/temperature 

supplementation 

Snake River fall Chinook Should correlate into a 1% increase in survival for juveniles 

Hanford Reach 

flow stabilization Hanford Reach fall chinook should substantially improve the juvenile rearing survival for 

fall Chinook within the Hanford Reach. 

Expedited 

installation of 

RSWs/surface 

bypass 

All anadromous species Over a period of years, benefits could conceivably equal or 

exceed spill reduction for all species 

Big Valley Ranch 

Wildlife Area well 

conversion and 

side channel 

enhancement 

Methow River summer 

steelhead (ESA listed), 

spring Chinook 

(ESA listed) and to a lesser 

degree summer Chinook 

Probability of success is high 

Steigerwald 

Lake/Gibbons 

Creek Restoration 

Chinook salmon (rearing), 

steelhead (spawning, 

rearing), coho 

salmon (spawning, rearing) 

and cutthroat trout 

This offset mitigation has a high certainty of success. 

The total cost of these offsets for 3 years, just for those estimated, is $26.4 million, about 

the same as the cost of offsets in the Preliminary Proposal ($19.2 to $34.2 million; see 

Table 7), but less than the expected revenue from spill reductions (about $140 million). 

Annual costs for some of the other offsets, especially those that require large volumes of 

water, might be relatively large. For the Chandler Bypass, 800 cfs for 6 months would 

require almost 290,000 AF of water. If this water is assumed to cost $50 per AF the 

annual cost would be $14.5 million. The additional cost of the RSWs is not clear, but 

they would also have the added benefit of being long-lived structures. 
IEAB Juvenile Passage Cost Effectiveness page 17- 

The Colville Tribes proposed that “the Action Agencies fund the following actions 

should you decide to proceed with your proposal for reduced spill.”14 These actions are 

shown in Table 11 below. The cost of these offsets would be $3.64 million over three 

years, a small fraction of the expected revenue from spill reductions (about $140 million). 

We might infer that the Colvilles believe these actions would be sufficient to compensate 

them for impacts to upriver stocks from Table 2 which they utilize. 

Table 11. 

Colville Tribe Proposed Offsets 

Offset 

Total Cost 

over 3 years Description 

Construct the Omak 

Acclimation Pond. $665,000 Develop a new summer/fall Chinook acclimation pond on the 

Okanogan River near the city of Omak 

Modify the Tonasket 

Acclimation Pond. $250,000 

This acclimation pond would disperse existing summer/fall 

Chinook production to make greater use of natural spawning 

habitat and improve production from over escaped spawning 

habitat in the upper Okanogan basin. 

Operate and Maintain the 

Bonaparte, Omak and 

Tonasket Acclimation 

Ponds. 

$675,000 

These acclimation ponds would disperse existing summer/fall 

Chinook production to make greater use of natural spawning 

habitat and improve production from over escaped spawning 

habitat in the upper Okanogan basin. 

Purchase and operate a 

“gravel gurdy” $129,000 

The gravel gurdy would be operated and evaluated in selected 

river reaches to remove sediments from spawning gravels and 

evaluated 

Initiate a Habitat 

Protection and 

Improvement Program for 

the Okanogan River. 

$950,000 

A phased and programmatic habitat protection and improvement 

effort in the Okanogan River. 

Initiate an Enhanced 

Tribal Enforcement 

Program. $825,000 

$825,000 

Target the mainstem Columbia River above and below Chief 

Joseph Dam, and the Okanogan River mainstem. 

Evaluate Effects of 

Summer Spill Experiment $150,000 

Evaluate potential effects of the reduced spill on the Colville 

Tribes’ trust resources by PIT tagging natural-origin summer/fall 

Chinook emigrating from the Okanogan River and 

experimentation 

The Pacific Northwest Generator’s Cooperative “supports offsets that maintain the 

federal agencies stated commitment to cost effective mitigation. Because we are not 

convinced that additional offsets are needed, spending $2 - $5 million on them per the 

proposal seems unwarranted. However, if the federal agencies feel compelled to select 

additional offsets they should be based on their ability to achieve the greatest biological 

benefit for the least cost. The following are additional offsets that could provide further 

mitigation:”15

The additional offsets favored by PNGC were: 

• Commercial harvest reductions 

 

14 Colville Tribes page 5 

15 PNGC page 3 
IEAB Juvenile Passage Cost Effectiveness page 18- 

• Avian predation research; and 

• Smallmouth bass management 

4.0 Information from Comments Received on the 

Amended Proposal 

A review of comments on the Amended proposal found little additional information that 

could be useful for cost-effectiveness analysis. Some commenters (such as WDFW) 

found that the amended proposal addressed their concerns about the preliminary proposal. 

Others found that the offsets in the amended proposal do not compensate for the effects 

of reduced spill. 

Potentially, the increased releases from Brownlee could be counter-productive (Coutant, 

2004). Dworshak reservoir is operated in summer to release cold water to compensate for 

the warm Snake River flows. In this view, increasing the warm flows from Brownlee 

would increase mortality, rather than enhance survival. The IEAB has not yet obtained an 

avaluation from a range of experts of the merits of this opinion. 

5.0 IEAB Analysis 

The Action Agencies’ analysis suggested that the Preliminary Proposal represents a costeffective change for all species taken as a group, for all non-listed species taken as a 

group, and for the Hanford Reach natural stock. For the ESA-listed Snake River Fall 

Chinook, and for other non-listed runs (not Hanford Reach), numbers of fish were not 

shown to be increased or even maintained, so it is not clear that the Preliminary Proposal 

would be cost-effective. 

For the Amended Proposal, the Action Agencies’ analysis indicated a cost-effective 

change for all species taken as a group, for all non-listed species taken as a group, for the 

ESA-listed Snake River fall chinook, for the Hanford Reach natural stock, and for the 

Lyons Ferry hatchery stock. However, analysis was not provided to show that the 

aggregate population of eight non-listed stocks would be increased, or that numbers of 

each of the eight stocks would be increased. These eight stocks are all of the Columbia 

River stocks except for the Hanford Reach natural. 

Brownlee flows would have an appreciable benefit only for Snake River stocks, Hanford 

Reach anti-stranding would benefit only that stock, and Lyons Ferry hatchery actions 

would benefit only that stock, so the only quantified benefit for all other stocks is from 

pikeminnow augmentation. For every stock, estimated survival increases from 

pikeminnow program augmentation (Table 6) are less than the survival reductions from 

reduced bypass spill in Table 2. Benefits of hatchery and habitat actions are not 

quantified. Therefore, based only on an analysis provided by the Action Agencies, we 

cannot conclude that the Amended Proposal is cost-effective for most of the affected 
IEAB Juvenile Passage Cost Effectiveness page 19- 

Columba River stocks. More quantitative analysis of offsets is needed to address survival 

of most of the Columbia River stocks. 

Section 3.3 shows a number of offsets proposed by commenters that could be used for the 

non-listed Columbia River stocks. Also, some offsets considered by the Action Agencies 

in the Preliminary Proposal were not included in the Amended Proposal for 2004 because 

they could not be developed in time. Additional quantitative analysis could be focused on 

the ability of these offsets to provide survival benefits for the Columbia River stocks. 

Removable spillway wiers (RSWs) could not be included in the offsets proposed for 2004 

because of the implementation time required. Also, it is not clear that RSWs will increase 

juvenile survival. Ongoing studies of the RSW at Lower Granite dam may clarify 

whether or not survival can be increased. If not, then RSWs may become a revenue 

mechanism viewed as being survival neutral, or increased revenues might be used as 

funding for other types of fish and wildlife actions. 

6.0 Where to from Here 

The IEAB is unable to make a conclusive statement about cost-effectiveness of spill 

reductions for two reasons. First, some of the necessary biological information has not 

been provided. For some stocks and some offsets, the offsets are not clearly defined or 

quantitative estimates of effectiveness have not been proposed. Second, most of the 

quantitative information that has been provided is disputed. For our purposes, the range 

of credible biological information needs to be narrowed. To obtain more definitive 

results, judgements regarding the biological arguments are required, but the IEAB’s role 

simply does not include such judgements. If the IEAB was directed to use a more narrow 

range of biological parameters, then a less ambiguous statement regarding costeffectiveness of mainstem spill actions might be possible. 

There is a need for a process that can consider offsets that can only be implemented in the 

long run. Some of the best potential offsets: RSWs, for example, could not be evaluated 

within the short time frame of the spill reduction proposal. The 2004 process for 

proposing spill reductions and offsets was simply too short to consider all forms of 

potential offsets. A long-term process would also be better able to involve stakeholders, 

conduct the necessary research, resolve key issues, and recommend changes in a fully 

inclusive and scientific way. 

The Council should continue to encourage research and processes that might reduce the 

biological uncertainties, evaluate alternatives to spill, and identify cost-effective 

outcomes. The 2004 mainstem spill proposals and the comments received clearly show 

what the issues are, and they suggest the types of studies needed to resolve them.
IEAB Juvenile Passage Cost-Effectiveness page 1 

7.0 References 

BPA and USACE. 2004a. Preliminary Proposal for FCRPS Summer Juvenile Bypass 

Spill Operations. March 30. 

BPA and USACE. 2004b. Amended Proposal for FCRPS Summer Juvenile Bypass 

Operations. June 8. 

BPA and USACE. 2004c Amendment to the 2004/2004-2008 Implementation Plan for 

the FCRPS Biological Opinion Remand. June 

BPA and USACE. 2004d. Amended Proposal for FCRPS Summer Juvenile Bypass 

Operations. Appendix C. Northern Pikeminnow Management Program Augmentation 

Analysis of Benefits to Specific Stocks. June 8. 

BPA and USACE. 2004e. Amended Proposal for FCRPS Summer Juvenile Bypass 

Operations. Appendix A. Additional Information on the Updated Impacts Analysis For 

the Proposed Summer Spill Reductions 

Columbia River Inter-Tribal Fish Commission. 2004. Comments. April 7. 

Confederated Tribes of the Colville Indian Reservation (Colville Tribes) 2004. Re: 

Comments on the Preliminary Proposal for Federal Columbia River Power System 

Summer Juvenile Bypass Spill Operations. April 19. 

Coutant, Chuck, 2004. Comments provided on second draft of IEAB’s “Scoping for 

Feasibility of Columbia River Mainstem Passage Cost-Effectiveness Analysis.” July 

2004. 

Fish Passage Center. 2004. To: Rob Lothrop, CRITFC, Bill Tweit, WDFG. From: 

Michelle DeHart. RE: Transportation of Fall Chinook Smolts and Related Fall Chinook 

Migration and Tag Data Concerning Summer Spill for Fish Passage. April 6. 

Independent Economic Analysis Board. 2004. Juvenile Passage Cost Effectiveness 

Analysis for the Columbia River Basin: Description and Preliminary Analysis. Draft for 

Review. January. 

Northwest Power and Conservation Council. 2003. “Mainstem Amendments to the 

Columbia River Basin Fish and Wildlife Program.” NPCC Document 2003-11. 

Pacific Northwest Generating Cooperative. 2004. Re: Comments on Federal Summer 

Spill Proposal. April 7. 
IEAB Juvenile Passage Cost Effectiveness page 2

State, Federal and Tribal Fishery Agencies Joint Technical Staff. 2004. Comments. April 

9. 

U.S. Department of Commerce. NOAA Fisheries Northwest Region. 2004. Findings 

Regarding Adequacy of the Federal Columbia River Power System Action Agencies’ 

2004 Annual Implementation Plan. July 1. 

U.S. Department of Commerce. NOAA Fisheries Northwest Region. 2004b. MEMO 

FOR: Hydro files FROM: FCRPS Branch staff SUBJECT: Analysis of Summer Spill 

Impacts on Listed Wild SR Fall Chinook Salmon Compared to Brownlee Flow 

Augmentation Offset for Summer Spill Proposal. June 8. 

Washington, State of, Department of Fish and Wildlife. 2004. Proposed package to offset 

effects of potential reduction of summer spill at several Columbia River federal dams. 

March 29. 

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