29 March 2003
Mr. Michael Linnell Phone: 360-753-9884 Fax: 360-753-9466
Assistant State Director
USDA-APHIS-Wildlife Services
720 O'Leary St. NW
Olympia, WA 98502
Dear Mr. Linnell:
Re: Washington Wildlife Services' (WS) "Pre-Decisional Environmental Assessment: Piscivorous Bird Damage Management for the Protection of Juvenile Salmonids on the Mid-Columbia River."
Thank you for the opportunity to comment on this Pre- Decisional Environmental Assessment (EA). My comments about this EA for bird control at mid-Columbia dams are given below.
Thank you for your time and consideration.
Yours,
[Signature of Range D. Bayer]
Range D. Bayer
Enclosures:
Enclosure A. Copy of a preliminary court injunction by the
Honorable Walter S. Smith, Jr., U.S. District Judge, of the
Western District of Texas, Waco Division, U.S. District Court
(Civil Action No. W99CA335, filed 9 February 2000). This
copy was sent by Roger Woodruff (Washington/Alaska WS
Director) to Range Bayer along with Enclosure C. [See section A for a quotation from this enclosure.]
Enclosure B. Range Bayer's letter of 4 March 2002 to the Washington Director of WS.
Enclosure C. Roger Woodruff's (Director of Washington and Alaska WS) letter of 12 March 2002 to Range Bayer, which included Enclosure A.
Enclosure D. Roger Woodruff's (Director of Washington and Alaska WS) letter of 20 September 2002 to Range Bayer.
It appears that Washington Wildlife Services (WS) has put this EA out for public and agency review in violation of a preliminary federal court injunction (Enclosure A) against the WS.
On 4 March 2002, I wrote the Washington WS Director and asked general questions about Washington WS activities to protect juvenile salmonids in Washington (see Enclosure B). Roger Woodruff (WS' Director for Washington and Alaska) replied in Enclosure C that my general questions could not be answered because of a federal court injunction. He included a copy of the injunction that prohibits WS from giving information to identify Cooperators with WS (see Enclosure A). On p. 5 of this court injunction (see Enclosure A), it is written:
"Pursuant to FED. R. CIV. P. 65, Daniel Glickman, the United States Department of Agriculture, Wildlife Services, and Animal & Plant Health Inspection Service, including their officers, agents, servants, employees, and attorneys, are ENJOINED, RESTRAINED, and PROHIBITED from releasing to any third parties, individuals, groups, or agencies, including but not limited to animal rights groups such as API [Animal Protection Institute] or FG [Forest Guardians], or their agents or lawyers, directly or indirectly, any Private Information, which is any such information that allows the recipient of it to obtain or deduce the specific identity or personal identifying information of the farmers, ranchers, and other individuals and entities who have requested, executed Cooperative Agreements with, or otherwise allowed Wildlife Services to enter their property for any purpose (hereinafter "Cooperators"). Specific examples of Private Information are names, telephone numbers, street addresses, towns or cities, counties, acreage, map coordinates of Wildlife Services traps, or other unique identifying characteristics of the Cooperators that allow the recipient to ascertain the specific identity of Cooperators."
In reading through all of this injunction, I see no exception for an Environmental Assessment.
On 10 April 2002, I mailed Michael Linnell comments about WS' (2002) "Invitation for Public Involvement" about piscivorous bird damage in the mid-Columbia Basin. On p. 7 of my comments, I reported that Roger Woodruff had said that Washington WS could not give information about the identity of cooperators with WS, so WS' readers of my comments would be aware of this injunction, if they were not before.
On 8 September 2002, I mailed Roger Woodruff a draft of Bayer (2003) for review by WS. On 20 September 2002, Roger Woodruff replied (see Enclosure D) and again stated that WS could not provide information to the general public and management agencies that could identify Cooperators with WS.
On p. 21 of WS' Pre-decisional EA, it states that WS used information gathered from various agencies and the public in response to the WS' invitation for public involvement to prepare this EA, so my comments of April 2002 would also presumably have been included, and Woodruff mentions my comments in his September 2002 letter (see his third paragraph in Enclosure D), so Washington WS received my comments. On EA p. 106, Roger Woodruff is listed as a preparer/editor of this EA, and he and other preparers were aware of the injunction through WS internal communications or through reading public comments to WS (2002).
But this EA by WS does not mention the federal court injunction, and many times throughout the EA the Cooperators with WS for bird control are clearly identified as the Chelan, Douglas, and Grant County Public Utility Districts (e.g., p. 3-5, 17, 20, 31-51 of the EA). This is in clear violation of the federal injunction sent by Woodruff and used by him to not answer questions about WS' activities at Columbia Basin dams.
Woodruff said in his September 2002 letter that WS had to withhold information from management agencies because of this court injunction (see first paragraph of Enclosure D). However, his statement is not true because:
1) Woodruff provided a WS' "Annual Report for Migratory Birds Taken by Our [WS] Program in Washington and Alaska during Calendar Year 2001 under Permit Number MB69298-0" to Tami Tate Hall of the U.S. Fish and Wildlife Service (911 NE 11th Avenue, Portland, OR 97232). His report is dated 17 January 2002 and includes the number of birds of each species taken in each county in Washington. Woodruff's report clearly violates the court injunction because it gives the number of birds killed in each county, and information for counties is not supposed to be given out (see quote from the injunction in section A).
2) WS violated the court injunction in its April 2002 "Invitation for Public Comment" because it discusses WS' non-lethal and lethal control of fish-eating birds at mid-Columbia Basin dams and hatcheries (WS 2002). Although WS did not mention the Cooperator Public Utility Districts specifically, there are few dams in the mid-Columbia, so that readers of WS (2002) could deduce that WS' Cooperators were the Chelan, Douglas, and Grant County Public Utility Districts.
3) Appendix C of the EA also gives evidence that Washington WS violated the court injunction. Michael Linnell (Assistant Washington/Alaska WS Director) wrote the U.S. Fish and Wildlife Service on 1 March 2002 that Washington WS was conducting bird control on the mid-Columbia River between River Mile 395 and 417. In the U.S. Fish and Wildlife Service's response of 8 March 2002, WS' consultation with the U. S. Fish and Wildlife Service about WS' "piscivorous bird control activities at hydroelectric and hatchery facilities located on the Columbia River between river mile 395 and river mile 517" is acknowledged, and the U.S. Fish and Wildlife Service also mentions a 21 December 2001 Biological Assessment that discusses WS' bird control in the mid- Columbia. The court injunction precludes the WS from giving information to any third parties (including agencies) that could specifically identify Cooperators, and WS' giving information about control at dams between River Mile 395 and 517 is specific enough to identify the Chelan, Douglas, and Grant County Public Utility Districts as Cooperators with WS.
4) Wildlife Services is a part of Animal & Plant Health Inspection Service [APHIS] and the United States Department of Agriculture. All three entities are prohibited from giving information that could identify Cooperators with WS to agencies and individuals (see quotation in section A). Cooperative agreements between and funded by the Chelan and Douglas County Public Utility Districts with APHIS for bird control and unpublished information about this control were provided to the National Marine Fisheries Service by APHIS (National Marine Fisheries Service 2002:3-138 and 3-140). Specifically, 201-1,075 ring-billed gulls "between 1996 and 2001" were mentioned as being killed annually at Rock Island Dam, and a diagram of overhead wires to exclude bird predators at Rocky Reach dam is given (National Marine Fisheries Service 2002:3-140, 3-141). This bird control would have been carried out by WS, but this information that APHIS provided is prohibited in the court injunction (see quotation in section A).
Thus, Woodruff and APHIS/Wildlife Services violated the injunction by providing information that identified Cooperators with Washington WS to management agencies, while at the same time Woodruff stated that APHIS/WS could not legally provide information to citizens or management agencies, even when my questions were more general (see Enclosures B-D). This selective use of the court injunction to avoid questions along with the apparent illegality of this EA undermines the credibility of this EA because the Washington WS Director, Roger Woodruff, was one of its preparers and editors (p. 106 of the EA).
Many wildlife management professionals have recommended that animal damage control be conducted only if the economic loss or impact on the resource by predation is greater than the economic, biological, aesthetic, and/or social costs of conducting control (e.g., Berryman 1972:397, 399; McCabe and Kozicky 1972:393, Dolbeer et al. 1996:474). Economic cost effectiveness means that the financial cost of animal damage control is not great than the financial cost of predation. Some staff of WS (which was known as Animal Damage Control prior to 1998) have also recommended that before predator control is initiated an environmental as well as an economic cost effective analysis be conducted (Slate et al. 1992:57-59) and that wildlife management actions be used that are cost effective "not only with respect to economics, but to biological, physical, social, and legal parameters, as well" (Owens and Slate 1991:26).
I, too, believe that there are situations where animal damage control is justified, but none of WS' alternatives includes whether Washington WS' control is cost effective or not. WS notes on EA p. 10 and 61 that it is not possible to determine if WS' predator control at mid-Columbia dams or hatcheries is cost effective, but in this time of tight budgets and financial distress, it would be prudent for WS' programs to be cost effective. Otherwise, taxpayers or electric ratepayers to the Public Utility Districts included in this EA can justifiably wonder if their money is being wisely spent. The U.S. Army Corps of Engineers estimates the cost effectiveness of their programs, why not WS?
In this EA, WS' Preferred Alternative of actions, Alternative 1 (EA p. 27), does not include cost effectiveness, so WS' control programs can be conducted that cost more than the costs of predation. Alternative 1 is:
"Alternative 1, the Non-lethal Preferred Alternative and current program, incorporates all practical and effective non-lethal tools to reduce piscivorous bird usage of areas where juvenile salmonid smolt are unnaturally exposed and susceptible to predation, before any lethal tools are implemented."
Because cost effectiveness is essential, my choice of the alternatives that WS gives in this EA is a revised Alternative 1 (EA p. 27) with the deletion of the phrase "and current program" and the addition of one clause that I have boldfaced below:
"Alternative 1, the Non-lethal Preferred Alternative will be employed where the costs of bird control do not exceed the costs of bird predation and incorporates all practical and effective non-lethal tools to reduce piscivorous bird usage of areas where juvenile salmonid smolt are unnaturally exposed and susceptible to predation, before any lethal tools are implemented."
The phrase "and current program" is deleted because Washington WS' current bird control program in the mid-Columbia has not been shown to be cost effective. Further, Washington WS has not used all nonlethal tools (section H-2 below) and may have underutilized nonlethal wire grids (section G) before using lethal control in the mid-Columbia, so it is uncertain that Washington WS is actually following their Preferred Alternative.
As mentioned by Ruggerone (1986:741) and Steuber et al. (1995:Discussion), birds may be taking fish below mid-Columbia dams that were killed or injured during dam passage. Steuber et al. were staff of Animal Damage Control (which is now known as WS). Although WS in this EA frequently cites Ruggerone (1986) and Steuber et al. (1995), WS has not mentioned that Ruggerone and Steuber et al. wrote that birds may take fish killed or injured by dam passage. The National Marine Fisheries Service (2002:2-12) also notes that juvenile salmonids can be killed or injured by three of the dams included in this EA. Further, in an Oregon Department of Fish and Wildlife report, Schaeffer (1991:8) wrote:
"Of the juvenile salmonids consumed by predators, the proportion that would have died of other causes cannot be accurately estimated. Estimates of consumption probably include dead or moribund juvenile salmonids that were injured while passing dams or were not robust or healthy enough to survive."
The overall direct dam passage mortality rates at three of the mid-Columbia dams in this EA were estimated to be 3-4% for Wells Dam, 6-9% for Rocky Reach Dam, and 5-9% for Rock Island Dam (National Marine Fisheries Service 2002:2-15). At the two other dams included in this EA, most passage of juvenile salmonids has been by spillways since 1994, and recent mortality rates were 2-5% for the Priest Rapids Dam spillway and 11-12% for the Wanapum Dam spillway (EA p. 8). These estimates of direct dam mortality can be incomplete because not all mortality from dam passage is immediate (e.g., Cramer and Oligher 1964:254, Gloss and Wahl 1983:199, Mathur et al. 1996:Table 7, National Marine Fisheries Service 2002:2-51). For instance, National Marine Fisheries Service (2002:2-14) note that mortality immediately after passing through turbines averaged 5.5% but in studies with longer times between turbine passage and recovery mortality averaged 10.9%. Thus, some fish may appear to be alive in dam tailraces but be mortally injured (also see section F).
Fish that are killed or that are mortally injured during dam passage become available to predators/scavengers such as birds and fish such as northern pikeminnows and would be much easier to catch than healthy fish. Consequently, birds may take proportionately more dead or mortally injured fish than their frequency of occurrence. For example, northern pikeminnows took 2.2 times as many dead juvenile salmonids as their frequency of occurrence relative to live salmonids (Petersen et al. 1994:1201). Fish that are killed by dam passage may not float on the surface, and mortally injured fish may still struggle against birds, so it is not possible by simple observation to determine whether birds are taking healthy fish (also see section F).
In addition to Ruggerone (1986), Schaeffer (1991), and Steuber et al. (1995); I also pointed out that birds may be taking some fish that were killed or mortally injured from passage through dams in my April 2002 comments to WS (2002). Nevertheless, in this EA on p. 2, 9, and 10; WS does not mention that dam passage can kill fish. On EA p. 17, WS finally acknowledges that birds may be taking some juvenile salmonids killed by dam passage and writes:
"Although some [salmonid] smolt which are eaten may have been killed previously by hydroelectric dam passage, Martinson et al. (1999, 2000, 2001) recorded physical signs of attempted bird predation on hatchery and wild steelhead below hydroelectric dams, showing that piscivorous birds also feed upon those smolt which have survived dam passage."
However, the previous quotation is partially inaccurate. Martinson et al. is a series of papers about downstream migration of juvenile salmonids at Bonneville and John Day dams in the Columbia Basin. The most recent one is Martinson et al. (2003) that gives information since 1985 about the external appearance of juvenile salmonids (including descaling, injuries, disease, and marks attributed to attempted predation for salmonids) collected within bypasses at these two dams (Martinson et al. 2003:36-37, 53-54, 66-68). These collections are for fish that have passed a dam but before they have been released below these dams (Martinson et al. 2003:2, 4), so these fish have not had a chance to become available to birds below these two dams. Thus, Martinson et al. do not measure, as WS stated, the incidence of marks attributed to bird predation after passage at these two dams but to attempted bird predation before they reached these dams.
Unfortunately, Martinson et al. does not give the total percentage of juvenile salmonids that are partially descaled, injured, or have external signs of disease; they give the percentage with each type of injury or disease, but some fish may have more than one injury or disease. For example, at McNary Dam in 1997, U.S. Army Corps of Engineers (1998:99) found that 1.7% of juvenile salmonids that they sampled before they were released below the dam had multiple injuries/diseases, 1.6% had bird marks/wounds, and a total of 11.9% of juvenile salmonids were injured, descaled, or had external evidence of disease. At John Day and Bonneville dams, Martinson et al. (2003:36-37, 53-54, 66- 68) also found that many juveniles sampled at the end of the bypasses were partially descaled, injured, or had external signs of disease. For example, in 2002 at John Day Dam, Martinson et al. (2003:37) reported that 10.6% of juvenile clipped steelhead were partially descaled, a sum of 20.4% had signs of head, opercula, or body injury or hemorrhage and a sum of 8.2% had external signs of parasites or disease. Consequently, it is clear from the sampling of juvenile salmonids after dam passage but before they are released into the tailwaters below the dam where they become available to birds that many juvenile salmonids are injured or have external signs of parasites or disease (U.S. Army Corps of Engineers 1998, Martinson et al. 2003). Thus, juvenile salmonids below dams are not just stunned or disoriented as WS state in this EA on p. 2 and 10; many are injured or have external signs of disease. On EA p. 17, WS demonstrated a selective use of data in Martinson et al. (1999-2001) by not mentioning that many juvenile salmonids were injured just as they were about to be released below dams.
Many estimates of bird predation at a Columbia Basin dam or bypass are 2% or less (Ruggerone 1986:741, Espenson 1999, Searing et al. 2002 cited in EA p. 18, Bayer 2003:45) or 1-3% (Thompson in EA p. 18). Snelling et al. (1997) reported bird predation rates of 1-11% for radiotagged juvenile chinook, but it is not clear if the process of radiotagging increased the vulnerability of these fish to predation (Adams et al. 1998, Hockersmith et al. 1999:45, Bayer 2003:48), so that the rate of predation for radiotagged fish may have been higher than for fish without radiotags. Most of these estimates are less than the mortality from dam passage at the five dams included in this EA, so it is plausible that a portion (perhaps a significant portion) of the juvenile salmonids that birds took below dams may have been killed or mortally injured from dam passage.
On EA p. 10-11, WS wrote:
"... the economic damage which results from the predation of juvenile salmonids may be represented by the costs associated with the implementation of mitigation measures which are designed to improve the survival of juvenile salmonids at each PUD facility. As an example, GCPUD [Grant County Public Utility District] in 1999-2000 spent in excess of $6 million annually on operation and maintenance of fish passage facilities, fish production facilities, fish studies, enhancement and habitat protection studies, and capital improvements. To gain a better understanding of fish presence, abundance, and survival for relicensing Wanapum and Priest Rapids Dams, GCPUD spent over $9 million. During the low water flow year in Spring of 2001, the cost of spill at GCPUD was over $144 million (GCPUD 2003, letter to WS)."
On EA p. 61, WS also wrote:
"... the economic loss attributed to avian predation may be represented by the costs associated with the development and implementation of mitigation measures which improve the survival of those ESA-listed species past each Project. For example, the total fish related costs for GCPUD alone total more than $6 million annually."
These statements by Washington WS that the cost of bird predation can be estimated by the costs to the PUD's for salmon mitigation because of their dams are incorrect. Is the National Marine Fisheries Service (2002:Chapter 2) wrong to say that mid-Columbia dam passage kills some juvenile salmonids and this mortality from dam passage must be mitigated by the owners of the dams? Is bird predation responsible for the costs of providing fish passage facilities so that fish can get past the PUD's dams? Is bird predation responsible for the costs of mitigating for the dams by operating fish hatcheries and improving habitat? Is bird predation responsible for the costs of relicensing Wanapum and Priest Rapids Dams? Is bird predation responsible for the low water flow year in 2001?
"No" is the answer to these questions because bird predation is not responsible for all mortality of juvenile salmonids at these dams. As pointed out in National Marine Fisheries Service (2002:Chapter 2), passage through and around dams is responsible for substantial direct mortality, and it is the responsibility of the dam owners to mitigate for the dams.
The cost of bird predation is properly based on the value of juvenile salmonids taken by birds that were not killed or mortally injured from dam passage. WS acknowledges in this EA that it has no information to estimate the cost of bird predation, but blaming birds for low water flows and everything else related to salmon recovery at these dams in the mid-Columbia Basin is incorrect.
WS wrote on EA p. 43:
"Ruggerone (1986) estimated approximately 2% (4,770 [plus or minus] 565 fish/day) of all juveniles passing Wanapum Dam were consumed by gulls during a 25-day smolt migration period, most of which were healthy. Based on turbine mortality studies, some (17%) were probably killed or injured by the turbines."
Ruggerone (1986:741) did estimate that about 2% of all fish that he assumed to only be juvenile salmonids were taken by gulls at Wanapum Dam, but he did not state that most of the fish taken were healthy. He had no way to measure how many fish taken by gulls were healthy. For example, he (p. 741) wrote:
"Most foraging attempts of gulls were characterized by plunges 5-15 cm below the surface, suggesting [boldface added] that gulls may have been foraging on live fish rather than dead fish floating on the surface. Some of the salmonids captured by birds were observed struggling to escape from the birds. Additional studies are needed to accurately measure the proportion of healthy salmonids consumed by gulls."
Some dead juvenile salmonids may float on the surface of tranquil waters, but currents in dam tailraces are not tranquil, so dead fish would not necessarily float on the surface. Further, in my seven years of experience at juvenile salmon rearing ponds that are much more tranquil than dam tailraces, I recall that not all dead juvenile salmonids floated on the surface, many were found below the top of screens at the tail of the pond or on the pond bottom. Additionally, fish mortally injured from dam passage are alive and could still struggle with birds, although they would succumb from their injuries if not taken by birds. Thus, it is unclear what portion of juvenile salmonids taken by birds are healthy, which is what Ruggerone's last statement in the quotation above also indicates.
The way WS has worded and arranged the sentences quoted above may result in a reader mistakenly inferring from WS' last sentence that 17% of fish taken by gulls were "probably killed or injured by the turbines." However, WS did not give a source for this information; perhaps the source is Ruggerone (1986:740), who wrote:
"More recent estimates by McKenzie et al. (1984) indicated total dam project (dam and reservoir) mortality at 13% for salmonids passing each dam and reservoir above Wanapum Dam and 17% mortality for migrants passing Wanapum Dam and Priest Rapids Dam."
Ruggerone's 17% refers to the percentage of all juvenile salmonids that are killed by dams, not to the percentage of fish taken by birds that were killed by dams.
I have seen no data that anyone has determined what portion of fish taken by birds are healthy or have been killed or injured by dam passage.
On EA p. 64, WS writes about its use of wire grids to exclude flying birds:
"On the mid-Columbia River, WS has been requested to construct and actively maintain vast overhead wiring exclusion systems over a portion of the tailrace at each hydroelectric dam. These wiring systems consist of 3/64" stainless steel cable stretched from the one bank of the river to the other, or from the shore to the dam, depending on the availability of suitable anchor points. The average exclusion system at hydroelectric facilities comprises 21 to 30 wires spaced at 25 to 50 foot intervals, with wires spanning anywhere from 500 to 1,800 feet. Steuber et al. (1995) discussed and illustrated the placement and effectiveness of the overhead wire exclusion system. In general, wire grids have been one of the most effective deterrents available, particularly for gulls, when used in combination with hazing and limited lethal control."
Authors of Steuber et al. (1995) were staff of Animal Damage Control (which is now known as WS). The EA did not mention that Steuber et al. (1995) found that wires spaced at 15 m (49.2 ft) intervals were not as effective in keeping gulls out as those placed at 7.5 m (24.6 ft) intervals at Wells Dam, which is one of the dams included in this EA. The decreasing effectiveness of wires as they are spaced farther apart has also been found elsewhere (e.g., Gorenzel et al. 1994:E-12, Mott and Boyd 1995:178-179, Littauer et al. 1997). Accordingly, WS' wire grids at mid-Columbia dams may not be as effective as they could be because WS has placed some wires too far apart (i.e., 50 ft) or there may not be enough wires to cover the area.
Because WS' wires at the five mid-Columbia dams generally radiate from a point (e.g., see EA p. 35, 38, 40, 44, and 49), installing more wires or wires closer together may not be practical. But it would be useful for WS to explain in this EA why it is not possible to space wires more closely together or to add more wires to cover additional areas. As WS and others (e.g., Gorenzel et al. 1994:E- 12, Mott and Boyd 1995:178-179, Littauer et al. 1997) note, the use of overhead wires is one of the most effective bird control measures available, so if WS does follow a practice of using practical and effective nonlethal tools before lethal methods (EA p. 27), then the more effective use of wire grids, where possible, is essential.
H-1. INTRODUCTION. On p. 61 and 65 of the EA, WS discusses "Other Available Tools" about control methods that are said to be "available" but not "currently" in use for reducing bird predation in the mid-Columbia Basin.
Because of questions about the credibility of this EA, it is important for WS to accurately communicate what methods that WS has or has not used in the mid-Columbia Basin in the past 10 years to control fish-eating birds.
H-2. HYDROCANNONS. WS states on p. 27 of the EA that: "Alternative 1, the Non-lethal Preferred Alternative and current program, incorporates all practical and effective non-lethal tools to reduce piscivorous bird usage of areas where juvenile salmonid smolt are unnaturally exposed and susceptible to predation, before any lethal tools are implemented." However, WS acknowledges on EA p. 66 that it does not use nonlethal avian hydrocannons ("water cannons"), though they have been installed below several dams owned by the U.S. Army Corps of Engineers, and WS has already used lethal control at dams and hatcheries (EA p. 71-72).
At the outfall of the juvenile bypass for John Day dam, an avian hydrocannon was constructed in 1997 of two irrigation type impulse sprinklers that under favorable conditions swept a 135 ft (41.1 m) radius, but prevailing winds often reduced the reach to a 105 ft (32.0 m) radius (Jones et al. 1998:2, 7). It decreased the number of gulls within the reach of its spray, but many gulls fed beyond its reach (Jones et al. 1998:7-8, 1999:11, 13).
For the outfall of the new juvenile bypass for Power House 2 at Bonneville Dam in 1999, the combination of two hydrocannons that could spray water up to 155 ft (47.2 m) and wire lines eliminated gull predation (Brinckman 1999, Espenson 1999).
Below McNary Dam, the U.S. Army Corps of Engineers also installed a hydrocannon with a 5/8 inch nozzle in 2002 to discourage fish-eating birds (Call 2002).
Although hydrocannons may not be able to cover large areas, they were effective in reducing gull numbers at juvenile bypasses at Bonneville and John Day dams. If they were not effective, it seems doubtful that another would have been installed below McNary Dam in 2002.
On p. 66, of the EA, WS discounts the effectiveness of hydrocannons by stating:
"Under ideal conditions, the avian hydrocannon covers a small percentage of most juvenile bypass outfalls and gulls are occasionally observed feeding within the spray (Jones et al. 1998)."
WS' statement is incorrect because Jones et al. (1998:2, 7-8) only reported observations at one bypass outfall and noted that on six occasions early in their observations during the first year of hydrocannon operation that 1-2 gulls flew into the spray, but that no gulls later flew into the spray. Jones et al. (1998:7-8, 1999:11, 13) reported that after the initial trial period that the hydrocannon was effective within the area of its reach.
There may be situations where a hydrocannon can be used effectively at mid-Columbia dams where overhead wires are not feasible, so one wonders why WS has not tried using hydrocannons (which are nonlethal), if WS indeed tries nonlethal methods first. Hydrocannons have been found to be effective at some lower Columbia Basin dams, so why haven't they been tried at mid- Columbia dams?
H-3. EGG ADDLING. In discussing methods of WS' fish-eating bird control in the mid-Columbia Basin, WS states on p. 29 of the EA:
"Egg addling/removal and avicides have not been implemented, but may be in the future..."
However, this statement is contradicted by WS' statement on p. 68 that suggests that they have sometimes addled eggs:
"Although WS has not commonly used egg addling or destruction for the protection of juvenile salmonids, it could be a useful damage management tool ..."
WS' statement on p. 29 is erroneous because egg addling was used in the mid-Columbia to control ring-billed gull nesting at Cabin Island, which is about one mile upstream of Priest Rapids dam (which is included in this EA, see EA p. 48-51). At Cabin Island, the breeding population was estimated to be 7,000 ring- billed and 200 California gulls (York et al. 2000:216); ring- billed and California gulls are listed as fish-eating birds that WS controls in the mid-Columbia Basin on EA p. 75-77. Evidence that egg addling was used for gull management at Cabin Island includes:
1) Authors of Pochop et al. (1998) were listed as either staff of WS or of the National Wildlife Research Center that is now part of WS. In 1995 at Cabin Island, Pochop et al. (1998:411-412) randomly selected 319 ring-billed gull nests for testing of egg oiling and assigned 29 nests as control nests with no treatment, and they state:
"The minimum number of control nests needed for the statistical analysis were used because, in addition to collecting efficacy data on white mineral oil and corn oil, the authors were interested [in] minimizing the number of young reared on the island [boldface added]."
Pochop et al. (1998:412) go on to state:
"On May 5, 1995, the rest of the nests on the island [boldface added] were treated (estimated 2,900 nests with [at least] 1 egg) with either white mineral or corn oil. These nests were not used in the comparison of white mineral oil and corn oil hatching suppression but were treated to control the fecundity of ring-billed gulls on the island."
Egg oiling at all Cabin Island nests was also conducted in 1996 and 1997, as Pochop et al. (1998:412) write:
"On May 7, 1996 and May 6, 1997, the authors went to the island to conduct an initial oiling of all nests in the colony [boldface added] with corn oil. ... The authors returned on May 21, 1996, May 21, 1997, and June 9, 1997, to re-oil all nests and determine hatching success. ... Hatching suppression island-wide for eggs in 1995 (corn and white mineral oil) was 96%, in 1996 (corn oil only) was 99.7%, and in 1997 (corn oil only) was 99.6%. Hatching suppression island-wide for nests in 1995 (corn and white mineral oil) was 95%, in 1996 (corn oil only) was 99.5%, and in 1997 (corn oil only) was 99.3%."
In 1995, there were an average of 3.0 eggs per nest in Cabin Island nests that were part of the oiling test, and there were a total of about 3,248 nests that were oiled (Pochop et al. 1998:412); if the average for all 3,248 nests was 3.0 eggs per nest, then an estimated 9,744 eggs were oiled in 1995. In 1996 and 1997, the authors also oiled all eggs at the Cabin Island colony, but the number of eggs or nests was not reported (Pochop et al. 1998:412). Thus, several thousand eggs were oiled in 1995 and perhaps also in 1996- 1997.
2) authors of York et al. (2000) are the same authors in Pochop et al. (1998), with the addition of York who is also listed as being with the National Wildlife Research Center, which is now part of WS. York et al. (2000:216) collected 77 ring- billed and 22 California gulls in 1995 at Cabin Island to determine the percentage of fish in their diet that were assumed to be juvenile salmonids. York et al. (2000:220) write:
"Management actions at Cabin Island [boldface added] to disperse gull nesting greater distances from hatchery release points, as well as active gull hazing below Priest Rapids Dam, should continue so as to provide disoriented smolts an opportunity to recuperate and continue their migration."
Clearly, activities of Pochop et al. (1998) are management actions to control gulls, not only because that is what they state, but also because of the large number of nests that were involved. York et al.'s (2000) statement links this egg addling to the protection of juvenile salmonids. Yet, addled eggs are not included in WS' Tables "Number of Animals Taken and Control Methods Used" in Washington for fiscal years 1996-1997 (see http://www.aphis.usda.gov/ws/tblfrontpage.html). Further, WS does not mention this take in this EA (e.g., see Table 1 below that only includes lethal take at dams and hatcheries), and WS' contradictory statements on p. 29 and 68 that they have either not used egg addling or have not commonly used it seem misleading.
Did WS/National Wildlife Research Center personnel oil eggs of fish-eating birds in the mid-Columbia Basin during 1998-2002? How many eggs were oiled at Cabin Island or other mid-Columbia fish-eating bird colonies during 1995-2002? Why isn't the number of oiled eggs included with WS' take?
Who owns Cabin Island? Was WS requested to control gull nesting there by the landowner? This information is not given in Pochop et al. (1998), but is essential for this EA because egg addling at Cabin Island was a management action by WS/National Wildlife Research Center staff of piscivorous (fish-eating) birds in the mid-Columbia, which is the subject of this EA.
H-4. AVICIDE: DRC-1339. On p. 68 and 104 of the EA, WS discusses the chemical DRC-1339 that is used to lethally control gulls, but WS does not mention if this chemical has been used to control fish-eating birds in the mid-Columbia Basin. WS' Tables "Number of Animals Taken and Control Methods Used" in Washington for fiscal years 1996-2000 are available at http://www.aphis.usda.gov/ws/tblfrontpage.html. These data indicate that 4,500 ring-billed gulls, a species that WS has identified as a fish-eating bird on p. 75-77 of the EA, were taken by WS in Washington using DRC-1339 in fiscal year 1998. If this lethal take was in the mid-Columbia Basin, it should be included in the EA. If this take was not in the Columbia Basin, then it should still be mentioned, so that readers may not wonder if the WS has left out relevant information.
I-1. INTRODUCTION. EA p. 69-96 states Washington WS' view of the impact on fish-eating birds covered in this EA. One measure of the impact is the number of birds lethally taken during WS' control; a summary of this take only at hatcheries and dams is in Table 1. Other takes by WS, such as egg addling (section H-3) or by DRC- 1339, if this take was in the mid-Columbia Basin (section H-4), are not included in Table 1.
--------------------------------------------------------------------------TABLE 1. Sum of fish-eating birds lethally taken by WS during fiscal years 1997-2001 in the mid-Columbia Basin at the Wells, Rocky Reach, Rock Island, Wanapum, and Priest Rapids dams and at the Wells and Priest Rapids hatcheries that are all included in this EA. These dams and hatcheries are owned by the Chelan, Douglas, or Grant County Public Utility Districts, but the hatcheries are operated by the Washington Department of Fish and Wildlife (p. 31-51 of the EA). These sums are calculated from data on p. 71-72 of the WS' EA.
This Table does not include WS' lethal take of fish-eating birds by egg addling at nests of fish-eating birds in the mid-Columbia (section H-3) or by DRC-1339 if this take was in the mid-Columbia Basin (section H-4).
--------------------------------------------------------------------------
1997-2001 Lethal Take by
Wildlife Services at_______
5 Dams 2 Hatcheries Sum
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cormorant, double-crested 913 40 953
heron, black-crowned night- 27 423 450
heron, great blue 42 159 201
"duck, diving" 0 43 43
merganser, common 89 504 593
merganser, hooded 0 1 1
gull, California 4,200 285 4,485
gull, ring-billed 7,555 532 8,087
gull, herring 114 2 116
gull, unidentified 380 0 380
tern, Caspian 1,479 5 1,484
"kingfisher (all)" 3 15 18
TOTAL 14,802 2,009 16,811
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I-2. CHRISTMAS BIRD COUNTS. On p. 70 of the EA, the entirety of WS' explanation about how it calculated Christmas Bird Count (CBC) data in this EA is:
"The 100-year population trend analysis was derived from CBC survey year 1901 through 2001 in Washington State. The CBC index is derived from a winter count survey conducted by National Audubon Society volunteers in December and January, and is used primarily to monitor state, regional, and national population trends. Unlike the BBS [Breeding Bird Survey], large portions of the Columbia River are surveyed by the CBC. Winter weather patterns often affect bird migrations, sometimes accelerating, delaying, or disrupting movements, therefore these counts may vary from year to year."
This paragraph demonstrates a lack of understanding of CBC's and how to analyze them accurately. There is not just one CBC per winter for Washington as WS' comments above suggest. During the CBC time period during one winter, there can be as many CBC's in a state as there are volunteers to coordinate and conduct them. Each CBC is a circle with 15 mile diameter, and the number of birds reported in each CBC depends upon the number of observers, their observation effort, their skills in identifying and counting birds, and weather conditions conducive to counting birds as well as the actual number of birds present.
WS' analyses of 1901-2001 CBC's in this EA are invalid because CBC's conducted in 1901 are not comparable to those in 2001. In 1901 and even in the 1950's, optical equipment to see and count distant birds was not as available or as of high of quality as is available today, so observers in 1901 or the 1950's would have missed recording many birds that were present that observers today record. Further, there are more CBC circles per winter and more observers in Washington in 2001 than in 1901 or the 1950's, so if more birds are recorded in recent CBC's than in CBC's in 1901, the main reason may be differences in the number of CBC circles per winter and observation effort rather than real increases in the number of birds present.
WS' methods of summarizing CBC data for each year to create a yearly CBC "index" are not described in this EA; this is unacceptable because it is well known that CBC results can be distorted by inadequate data analyses. Apparently WS summed the number of a species seen during all CBC's in Washington for each winter and then compared the sums among years (e.g., see comments for specific bird species below); this procedure is inaccurate and not in accordance with accepted ways to analyze CBC data that have been widely discussed (e.g., see articles in p. 17-33 of Ralph and Scott 1981, Butcher and McCulloch 1990, Peterson 1995). For example:
1) the same CBC's should be analyzed each year or changes in the total number of birds may result from changes in the numbers or locations of CBC's each year rather changes in the numbers of birds from year to year
2) differences in observation effort among CBC's must be accounted for by standardizing some measure of observation effort (e.g., "party hours" or "party miles"). Otherwise, differences in numbers of birds between CBC's may result from differences in observation effort, not real differences in the number of birds.
3) severe weather during CBC's in one year can result in CBC's that are not comparable to CBC's in other years because fewer observers may participate, and they may be less able to count birds. For instance, Washington WS notes in WS (2001:13) that a severe storm in Washington in 1997 resulted in a reduced number of CBC volunteers; this could have led to a reduction in the number of birds counted.
Consequently, WS' statements in this EA that several species of birds have shown increasing population trends because sums of birds in CBC's now are higher than in the past (see following sections) are invalid because it is unclear if the number of CBC's each winter is the same and apparent increases in sums of birds may reflect increases in observation effort, rather than actual increases in the numbers of birds present.
I-3. CALIFORNIA GULL. On p. 73 of the EA, WS states that 1901-2001 CBC surveys show increasing trends for California gulls that peaked in 1971 (622) and 1986 (1,893). These data do not show an increasing trend--1971 was 32 years ago and 1986 was 17 years ago. WS (2001:15) gives CBC totals for California gulls of 229-759 for 1996-2000, so the CBC sums show a decreasing trend since 1986, though these analyses of sums are questionable (section I-2).
On p. 74, WS writes:
"According to the published literature, populations of California and ring-billed gulls are increasing throughout the state ..."
This statement is misleading because California gull and ring- billed gull nests have often not been counted separately (e.g., Collis et al. 2002:541), so it is not clear if California gull populations are increasing. While the sum of California plus ring-billed gulls has clearly increased that does not mean that California gull populations and also ring-billed gull populations have each increased throughout Washington as WS implies. WS needs to differentiate data specifically for California gulls from that specifically for ring-billed gulls or for pooled data for both species on EA p. 73-77 and not suggest that pooled data for California plus ring-billed gulls accurately portrays the population status of California gulls.
Based on the regional decline in California gulls in Breeding Bird Surveys (p. 73), the somewhat stable trend in Christmas Bird Counts, and the lack of data for numbers of nesting California gulls throughout Washington (p. 74), WS' statement that the California gull population trend is "increasing" on EA p. 76 is not supported by the available data. The population trend is either stable or decreasing, so the Magnitude of the Washington WS control program is "moderate" or "high" (see EA p. 58), not "low" as WS states on EA p. 76.
I-4. RING-BILLED GULL & DOUBLE-CRESTED CORMORANT. WS states that ring-billed gulls (EA p. 73) and double-crested cormorants (EA p. 77) are showing increasing population trends because Washington CBC counts of these species are now higher than they were for ring-billed gulls in 1953 and double-crested cormorants in 1956. However, these CBC analyses are invalid because these differences may reflect a recent increase in the numbers of CBC counts each winter or increased observation effort since the 1950's rather than increases in numbers of these birds (see section I-2).
I-5. CASPIAN TERN. On p. 81 of the EA, WS wrote:
"BBS [Breeding Bird Survey] data for Caspian terns in Washington recorded an increasing population trend of 12.8% (p<0.03) between 1980 and 2000. The BBS documented the highest concentrations of Caspian terns in the Columbia River estuary and south-central Washington (Sauer et al. 2001)."
However, the WS' source of this information is incorrect because the Caspian tern colonies in the Columbia River estuary are in Oregon, not Washington (Shuford and Craig 2002:21). WS cited Shuford and Craig (2002) on p. 82-83 of this EA, so WS should have seen this error.
As noted on p. 134 of this EA, the final draft of Shuford and Craig's (2002) status assessment of Caspian terns in North America to the U.S. Fish and Wildlife Service was published in August 2002, so it is puzzling why WS did not use it more. For Washington, the number of nesting Caspian terns declined from 2,907 breeding pairs in 1979 to 1,371-1,416 in 2000-2001 (calculated from Shuford and Craig 2002:21). For the Pacific Region, the number of breeding pairs increased from about 5,780 circa 1979 to about 13-14,000 pairs during 1999-2001 (Shuford and Craig 2002:23). Thus, WS' statement on p. 86 that the Caspian tern population trend is increasing is not true for Washington, so this qualifier should be added.
On p. 86 of the EA, it is written: "Based on the best information available, the magnitude of the WS program on Caspian terns is low." However, WS took 938 Caspian terns at dams and hatcheries included in this EA in fiscal year 2001 (Table 1); many of these may have been nonbreeders as the breeding population in Washington in 2001 was 2,832 terns (1,416 pairs) as calculated from Shuford and Craig (2002:21). In any case, 938 is relatively large compared to the number of Washington breeders, so WS' statement that the take of terns is "low" is questionable.
I-6. COMMON MERGANSER. WS wrote that Breeding Bird Survey data for common mergansers in Washington and the region did not show a population trend, and Washington CBC data are said to show an increase from 91 in 1959 to 4,238 in 2001 (EA p. 74). However, it is not stated if the CBC data are for the same CBC circles or if the number of circles and observation effort have increased between 1959 and 2001 (see section I-2), so it is not clear if the CBC increase between 1959 and 2001 is real or is an artifact of WS' data analyses. Accordingly, WS' statement that the common merganser population trend is increasing on EA p. 90 is not adequately supported by data for Washington or the region. Thus, WS' statement that the Magnitude of WS' control of common mergansers is "low" is questionable because the stable or uncertain population trend based on state and regional population trends indicate that the Magnitude is "moderate" or "uncertain" (see EA p. 58).
I-7. GREAT BLUE HERON. WS notes that Breeding Bird Survey data for Washington and the region did not show a population trend for great blue herons, and Washington CBC data are said to show an increase from 31 in 1939 to 1,878 in 2001 (EA p. 91). But it is doubtful that there were the same number of CBC's and observation effort in 1939 as in recent years, so WS' "increase" of great blue herons since 1939 is questionable. Further, using CBC data for great blue herons in this EA may be inappropriate because the number present in winter in eastern Washington may depend on the mildness of winter as in eastern Oregon (Gilligan et al. 1994:26- 27) rather than population abundance. WS also appears to have selectively chosen data because in WS (2001:19), the number of great blue herons counted during Washington CBC's was 2,238 and 2,131 in 1998 and 2000, respectively, so there were fewer (1,878) in 2001, and Washington CBC data for 1996-2000 suggest that great blue heron numbers appear approximately stable or uncertain.
On EA p. 92, it is stated that the Washington Department of Fish and Wildlife "cannot estimate [great blue heron] population size or trends based on available data."
On EA p. 93, the great blue heron population trend is listed as "stable." This overstates the status of herons in Washington or in the region, which would be more accurately classified as "uncertain, perhaps stable."
I-8. BLACK-CROWNED NIGHT-HERON. WS says that Breeding Bird Survey data for black-crowned night-herons in Washington showed a decreasing population trend and for the region showed an increasing trend (EA p. 94). Washington CBC data are said to show an increase from 1 in 1968 to 80 in 2001 (EA p. 94), but WS' analyses of CBC data are inadequate, and it is doubtful that there were the same number of CBC's and observation effort in 1968 as in recent years, so WS' "increase" may possibly be largely attributable to WS' choice of data analyses.
On EA p. 94, it is written that the Washington Department of Fish and Wildlife cannot determine population trends for these night-herons, and that the number of nesting pairs at Potholes Reservoir, Grant County, was between 1,000 and 1,500 in 1978 and 54 and 670 in 1991 and 1997, respectively, though these recent counts may be underestimates.
These data reflect uncertainty and perhaps a decline in night- heron numbers in Washington, so the statement on p. 95 of the EA that their population trend is "stable" is not supported by the available data. The status could be more accurately described as "uncertain."
I-9. CONCLUSION ABOUT WS' ANALYSES OF POPULATION TRENDS. In this EA, Washington WS consistently states that the population trends of impacted bird species in Washington or the region are increasing or stable, when the actual data are uncertain. WS has also given population trends for the entire U.S. from which a reader may infer that populations are increasing when state or regional trends are inconclusive or decreasing (e.g., see EA p. 77, 89, 91, 94), but, in determining the Magnitude of WS' impact, WS acknowledges that only trends in the state and region are relevant (EA p. 58). WS appears to be minimizing the Magnitude of the impact of its programs (see EA p. 58); if state or regional populations are stable or uncertain, then the Magnitude would be "moderate" or "uncertain" rather than WS' "low" or "stable," respectively.
To help readers of this Environmental Assessment make more informed comments, Washington WS could have done a better job of making their references accessible by giving Internet addresses (URL's) for many more of their references. This is especially important for publications by staff of WS about bird predators or predation in the mid-Columbia Basin that are directly relevant to this EA (i.e., Steuber et al. 1995, Pochop et al. 1998, 2001; and York et al. 2000) and also for National Marine Fisheries Service (2002), which is also about the mid-Columbia Basin. I was able to find and include the Internet addresses for many of the references below, many of which were also included in the EA, why not Washington WS?
This EA seems to be illegal (section A), has credibility problems (section B), does not include the cost effectiveness of WS' Preferred Alternative and current program (section C), ignores the plausibility of birds taking at least some fish that were killed or mortally injured from dam passage (section D), provides invalid estimates of the cost of bird predation (section E), inaccurately represents Ruggerone (1986)(section F), overlooks relevant material (e.g., egg oiling in section H-3), shows that some practical and effective nonlethal methods were not used (hydrocannons in section H-2) or may have been underutilized (wire grids in section G), and minimizes the impact of WS' control (section I).
I wonder about what else has been left out or is inaccurate that I have missed.
Adams, N. S., D. W. Rondorf, S. D. Evans, J. E. Kelly, and R. W. Perry. 1998. Effects of surgically and gastrically implanted radio transmitters on swimming performance and predator avoidance of juvenile chinook (Oncorhynchus tshawytscha). Can. J. Fish. Aquat. Sci. 55:781-787.
Bayer, R. D. 2003. Review: bird predation of juvenile salmonids and management of birds near 14 Columbia Basin dams. Yaquina Studies in Natural History No. 10. (This is at: http://www.orednet.org/~rbayer/salmon/gullprd.htm, all lower case letters)
Berryman, J. H. 1972. The principles of predator control. J. Wildlife Mgmt. 36:395-400.
Brinckman, J. 1999. Water cannons chase seagulls. P. B1 in May 23 Oregonian (newspaper). Portland, Oregon.
Butcher, G. S. and C. E. McCulloch. 1990. Influence of observer effort on the number of individual birds recorded on Christmas Bird Counts. U.S. Dept. of Interior, Fish and Wildlife Service, Biological Report 90(1):120-129.
Call, C. L. 2002. McNary salmon ladders improved: millions spent on fish passage, including upgrade on juvenile pipeline. In Feb. 17 East Oregonian. (This is at: http://www.eonow.com/news/stories/2002/feb/17.shtml)
Collis, K., D. D. Roby, D. P. Craig, S. Adamany, and J. Y. Adkins. 2002. Colony size and diet composition of piscivorous waterbirds on the lower Columbia River: implications for losses of juvenile salmonids to avian predation. Trans. Am. Fish. Soc. 131:537-550.
Cramer, F. K. and R. C. Oligher. 1964. Passing fish through hydraulic turbines. Trans. Am. Fish. Soc. 93:243-259.
Dolbeer, R. A., N. R. Holler, and D. W. Hawthorne. 1996. Identification and control of wildlife damage. P. 474-506 in T. A. Bookhout (ed.), Research and management techniques for wildlife and habitats. Wildlife Society. Bethseda, Maryland.
Espenson, B. 1999. Bonneville outfall 'cannons' firing. #3 in 7 May 1999 Columbia Basin Bulletin No. 42.
Gilligan, J., M. Smith, D. Rogers, and A. Contreras (editors). 1994. Birds of Oregon: status and distribution. Cinclus Publications, McMinnville, Oregon.
Gloss, S. P. and J. R. Wahl. 1983. Mortality of juvenile salmonids passing through Ossberger crossflow turbines at small-scale hydroelectric sites. Trans. Am. Fish. Soc. 112:194-200.
Gorenzel, W. P., F. S. Conte, and T. P. Salmon. 1994. Bird damage at aquaculture facilities. P. E5-E18 in Prevention and Control of Wildlife Damage Handbook, 3rd edition. Cooperative Extension Service, Institute of Agriculture and Natural Resources, University of Nebraska--Lincoln. (This is at: http://deal.unl.edu/icwdm/handbook/handbook/allPDF/bird_e5.pdf)
Grant County Public Utility District (GCPUD). 2003. Letter from GCPUD to WS discussing the PUD's technical review of the EA, January 10, 2003. (Not seen-this citation is verbatim from EA p. 119.)
Hockersmith, E. E., S. G. Smith, W. D. Muir, B. P. Sandford, J. G. Williams, and J. R. Skalski. 1999. Survival estimates for the passage of juvenile salmonids through Snake River dams and reservoirs, 1997. Annual Report to Bonneville Power Administration, BPA Report DOE/BP-10891-7, Contract DE-AI79-93BP10891, Project 93-29-00. (This is at http://www.efw.bpa.gov/Environment/EW/EWP/DOCS/REPORTS/DOWNSTRM/D10891-7.pdf)
Jones, S. T., G. M. Starke, and R. J. Stansell. 1998. Predation by gulls and effectiveness of predation control measures at Bonneville, The Dalles, and John Day dams in 1997. U.S. Army Corps of Engineers, CENWP-CO-SRF, Bonneville Dam, Cascade Locks, OR 97014.
Jones, S. T., G. M. Starke, and R. J. Stansell. 1999. Predation by gulls and effectiveness of predation control measures at Bonneville, The Dalles, and John Day dams. U.S. Army Corps of Engineers, CENWP-CO-SRF, Bonneville Dam, Cascade Locks, OR 97014.
Littauer, G. A., J. F. Glahn, D. S. Reinhold, and M. W. Brunson. 1997. Control of bird predation at aquaculture facilities: strategies and cost estimates. Southern Regional Aquaculture Center (SRAC) Publication No. 402. (All authors except Brunson are with Wildlife Services. This is at: http://srac.tamu.edu/402fs.pdf)
Martinson, R. D., J. W. Kamps, G. M. Kovalchuk, and D. Ballinger. 1999. Monitoring of downstream salmon and steelhead at federal hydroelectric facilities--1998. 1998 Annual Report to Bonneville Power Administration, Contract DE-AI79-85BP20733, Project 84-014, DOE/BP-20733-13. (This is at: http://www.efw.bpa.gov/Environment/EW/EWP/DOCS/REPORTS/DOWNSTRM/D20733-13.pdf)
Martinson, R. D., J. W. Kamps, G. M. Kovalchuk, and D. Ballinger. 2000. Monitoring of downstream salmon and steelhead at federal hydroelectric facilities--1999. 1999 Annual Report to Bonneville Power Administration, Contract 1998FG02117, Project 198712700, DOE/BP-20117-3. (This is at: http://www.efw.bpa.gov/Environment/EW/EWP/DOCS/REPORTS/DOWNSTRM/D02117-3.pdf)
Martinson, R. D., J. W. Kamps, G. M. Kovalchuk, and D. Ballinger. 2001. Monitoring of downstream salmon and steelhead at federal hydroelectric facilities--2000. 2000 Annual Report to Bonneville Power Administration, Contract 1998FG02117, Project 198712700, DOE/BP-20117-4. (This is at: http://www.efw.bpa.gov/Environment/EW/EWP/DOCS/REPORTS/DOWNSTRM/D02117-4.pdf)
Martinson, R. D., J. W. Kamps, G. M. Kovalchuk, D. Ballinger. 2003. Monitoring of downstream salmon and steelhead at federal hydroelectric facilities--2002. 2002 Annual Report to Bonneville Power Administration, Project 1987-127-01 (98-FG-02117), BPA Report DOE/BP-00003992-2. (This is at: http://www.efw.bpa.gov/Environment/EW/EWP/DOCS/REPORTS/DOWNSTRM/D00003992-2.pdf)
Mathur, D., P. G. Heisey, E. T. Euston, J. R. Skalski, and S. Hays. 1996. Turbine passage survival estimation for chinook salmon smolts (Oncorhynchus tshawytscha) at a large dam on the Columbia River. Can. J. Fish. Aquat. Sci. 53:542-549.
McCabe, R. A. and E. L. Kozicky. 1972. A position on predator management. J. Wildlife Management 36:382-394.
McKenzie, D., D. Weitkamp, T. Schadt, D. Carlile, and D. Chapman. 1984. 1982 systems mortality study. Battelle, Pacific Northwest Laboratories, Richland, Washington. (Not seen--cited in Ruggerone 1986:740.)
Mott, D. F. and F. L. Boyd. 1995. A review of techniques for preventing cormorant depredations at aquaculture facilities in the Southeastern United States. Colonial Waterbirds 18 (Special Publ.1):176-180.
National Marine Fisheries Service. 2002. Anadromous Fish Agreements and Habitat Conservation Plans: Final Environmental Impact Statement for the Wells, Rocky Reach, and Rock Island Hydroelectric Projects. Volume I. U.S. Department of Commerce National Oceanic and Atmospheric Administration, National Marine Fisheries Service. (This is at: http://www.chelanpud.org/rr_relicense/existing/hcp)
Owens, R. D. and D. Slate. 1991. Economics and effectiveness of control methods: fact and fiction. Proceedings Eastern Wildlife Damage Control Conference 5:24-27. (This is at: http://wildlifedamage.unl.edu/handbook/Chapters/pdf/fech5.pdf)
Petersen, J. H., D. M. Gadomski, and T. P. Poe. 1994. Differential predation by northern squawfish (Ptychocheilus oregonensis) on live and dead juvenile salmonids in the Bonneville Dam tailrace (Columbia River). Can. J. Fish. Aquat. Sci. 51:1197-1204.
Peterson, A. 1995. Erroneous party-hour data and a proposed method of correcting observer effort in Christmas Bird Counts. Journal of Field Ornithology 66:385-390.
Pochop, P. A., J. L. Cummings, C. A. Yoder, and J. E. Steuber. 1998. Comparison of white mineral oil and corn oil to reduce hatchability in ring-billed gull eggs. Proceedings Vertebrate Pest Conference 18:411-413. (This is at: http://www.aphis.usda.gov/ws/nwrc/is/98pubs/98-78.pdf)
Pochop, P. A., J. L. Cummings, and R. M. Engeman. 2001. Field evaluation of a visual barrier to discourage gull nesting. Pacific Conservation Biology 7:143-145. (This is at: http://www.aphis.usda.gov/ws/nwrc/is/01pubs/01-64.pdf)
Ralph, C. J. and J. M. Scott (editors). 1981. Estimating numbers of terrestrial birds. Studies in Avian Biology No. 6.
Ruggerone, G. T. 1986. Consumption of migrating juvenile salmonids by gulls foraging below a Columbia River dam. Trans. Am. Fish. Soc. 115:736-742.
Sauer, J. R., J. E. Hines, and J. Fallon. 2001. The North American Breeding Bird Survey, results and analysis 1966-2000. Version 2001.2. U.S. Geological Survey, Patuxent Wildlife Research Center. Laurel, Maryland. (Not seen, this is cited in EA p. 81 and on p. 132 is said to be at http://www.mbr-pwrc.usgs.gov/bbs/bbs.htmbut only the 1995 version and data through 1997 were available at this web site on 3/29/2003)
Schaeffer, L. 1991. Predation study: salmon hatchery smolts and survival. A study in response to [Oregon] House Bill 2735, Section 7. Oregon Dept. of Fish and Wildlife. (This is SH167.S17.S331 at Oregon State University Libraries.)
Searing, G., M. Demarchi, K. Truman, and M. Bentley. 2002. Predation of chinook salmon smolts by Caspian terns and other birds on the Columbia River from Rock Island Dam through Hanford Reach. Final report prepared for Public Utility District No. 2 of Grant County by LGL Limited, Sydney, British Columbia. (Not seen, this is cited in EA p. 18.)
Shuford, W. D. and D. P. Craig. 2002. Status assessment and conservation recommendations for the Caspian tern (Sterna caspia) in North America. U.S. Dept. of Interior, Fish and Wildlife Service. Portland, Oregon. (This is still available on 3/29/2003 in the "Hot Topics" at: http://migratorybirds.pacific.fws.gov/what's_new.htm)
Slate, D., R. Owens, G. Connolly, and G. Simmons. 1992. Decision making for wildlife damage management. Trans. North Am. Wildlife and Natural Resources Conference 57:51-62.
Snelling, J. C., S. A. Mattson, and C. B. Schreck. 1997. Estimates of avian predation on juvenile chinook salmon between Bonneville and John Day dams. P. 35 (Abstract only) in Oregon Chapter of American Fisheries Society 33rd Annual Meeting, 12-14 February 1997. (This is at SH3.A441 at Oregon State University Libraries.)
Steuber, J. E., M. E. Pitzler, and J. G. Oldenburg. 1995. Protecting juvenile salmonids from gull predation using wire exclusion below hydroelectric dams. Proceedings of the Great Plains Wildlife Damage Control Workshop 12:38-41. (This is at: http://deal.unl.edu/icwdm/handbook/Chapters/pdf/12gpsteuber.pdf)
United States Army Corps of Engineers. 1998. Juvenile fish transportation program: 1997 annual report. United States Army Corps of Engineers, Walla Walla District.
Wildlife Services (WS). 2001. Final Environmental Assessment and Finding of No Significant Impact for alternative strategies for the management of damage caused by migratory birds in the State of Washington. U.S. Dept. of Agriculture, Animal and Plant Health Inspection Service, Wildlife Services. (This and other Environmental Assessments are at: http://www.aphis.usda.gov/ws/eafrontpage.html)
Wildlife Services (WS). 2002. Invitation for public involvement [until 15 April 2002]: piscivorous bird damage management for the protection of salmonids in the mid-Columbia River Basin. U.S. Dept. of Agriculture, Animal and Plant Health Inspection Service, Wildlife Services, 7209 O'Leary St. NW, Olympia, Washington; 27 March 2002. (Comments were to be used in preparing an Environmental Assessment.)
York, D. L., J. L. Cummings, J. E. Steuber, P. A. Pochop, and C. A. Yoder. 2000. Importance of migrating salmon smolt in Ring-billed (Larus delawarensis) and California Gull (L. californicus) diets near Priest Rapids Dam, Washington. Western North Am. Naturalist 60:216-220. (This is at: http://www.aphis.usda.gov/ws/nwrc/is/00pubs/00-89.pdf)
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Email comments to Range D. Bayer, rbayer@orednet.org, Home Page, P. O. Box 1467, Newport, Oregon 97365 USA. (Range [Richard] Bayer is an independent biologist; he is not a consultant nor is he employed by or a volunteer to do biology work or research for a governmental agency, educational institution, or nongovernmental group)