SAPPI, Inc.
FERC Project Nos. 2942-005; 2931-002;
2941-002; 2932-003; and 2897-003.

Pursuant to the notice issued by the Federal Energy Regulatory Commission (FERC or the Commission) on September 20, 2001 soliciting comments on the Draft Environmental Impact Statement (FERC/DEIS - 0139D), Presumpscot River, Maine (DEIS), intervenors Friends of Sebago Lake ("FOSL") and the Maine Council of the Atlantic Salmon Federation ("MCASF") herein offer these comments on the DEIS. These written comments are intended to supplement oral comments presented by FOSL and MCASF members at the October 25, 2001 DEIS public hearing in Windham, Maine.

I. Introduction.

By Commission Staff's own admission, its license recommendation in the Presumpscot River DEIS will result in the continued extirpation of anadromous Atlantic salmon from their native habitat in the Presumpscot River from Ammoncongin Falls (Cumberland Mills) to the river's source at Sebago Lake.

According to the DEIS, Staff's licensing recommendation results in part from their calculation that selective dam removal on the Presumpscot River will only produce an anadromous Atlantic salmon run of 102 adults or less; and that in Staff's view this Atlantic salmon population is not sufficiently large to justify the dam removals required to achieve it.

Intervenors FOSL and MCASF strongly disagree with this conclusion for several reasons:

1. Staff's projected Atlantic salmon population size is not correct because it is based on a flawed quantitative analysis.

2. Staff's quantitative estimate of Atlantic salmon habitat that would be made available with selective dam removal is not correct.

3. Staff's selected maximum adult Atlantic salmon return rate is incorrect and far lower than what has been documented in wild Atlantic salmon populations in Maine and elsewhere.

4. Staff fails to specify what number of Atlantic salmon would be "enough" to justify dam removal; fails to cite any of the evidence or policy guidance it used to develop this unstated number; and Staff's decision that its estimate of 30-102 salmon is not "enough" to justify selective dam removal is arbitrary and without any basis in fact, policy or law.

FOSL and MCASF believe a more accurate and objective analysis would show that potential Atlantic salmon returns to the Presumpscot River with selective dam removal are much higher than those predicted in the DEIS.

Because Commission Staff rejected dam removal on the basis it would not produce "enough" Atlantic salmon, Staff's rationale rests entirely on the accuracy of the quantitative Atlantic salmon population projection in the DEIS.

If Staff's Atlantic salmon population projection of 30-100 adults in the DEIS is not valid then Staff's stated rationale for rejecting dam removal is not valid.

There is significant evidence to show that Staff's Atlantic salmon population projection is not valid.

In part one of our comments, we analyze in detail the key assumptions and factual bases used by Commission Staff to support their quantitative population projection for Atlantic salmon. Our analysis shows the DEIS grossly underestimates the Atlantic salmon population potential of the Presumpscot River with selective dam removal.

In part two of our comments, we analyze the ramifications of Staff's view of what constitutes "enough" Atlantic salmon to justify dam removal and how Staff's recommendation to allow the continued extirpation of Atlantic salmon from their native habitat in the Presumpscot River above Ammoncongin Falls violates state and federal policies, fisheries restoration goals and objectives, and fails to satisfy the Commission's legal responsibilities under the Federal Power Act.

II. General Comments on the DEIS.

A. Comments on DEIS Section 4.3.2.4, "Unavoidable Adverse Effects."

In the DEIS at page 127, Commission Staff write:

"Continued operation of the projects, with all the proposed enhancement measures would enhance fish populations in the Presumpscot River basin."

This statement is false. It fails to mention Staff's own conclusion that retention of all five dams will result in the continued extirpation of anadromous Atlantic salmon from all of their historic habitat in the Presumpscot River above the Saccarappa Falls dam.

To be accurate, the Final EIS should explicitly state that an "Unavoidable Adverse Effect" of relicensing all five dams is the continued extirpation of anadromous Atlantic salmon from all of their historic habitat in the Presumpscot River above Saccarappa Falls; and the Commission recognizes this outcome is entirely due to their license recommendation.

B. Comments on DEIS Section 4.3.2.3, "Cumulative Effects."

Commission Staff devote less than three pages of a 256 page DEIS to an analysis of the cumulative effects of five hydroelectric dams which impound more than half of the Presumpscot River.

In this section, Commission Staff write, "the construction of dams within the Presumpscot River basin, along with other factors such as water pollution and overfishing has eliminated anadromous species from most of the Presumpscot River Basin where they once occurred." (DEIS at page 126)

This statement is wrong. There is no historic evidence that overfishing caused the elimination of anadromous fish species from the Presumpscot River above Saccarappa Falls. There is no historic evidence that water pollution in the Presumpscot caused the elimination of anadromous fish species from the river above Saccarappa Falls.

Every single historic record available -- dating back to the 1700s -- unequivocably attributes the extirpation of the Presumpscot's anadromous fish population above Saccarappa Falls to one singular cause: the construction of dams.

2) The second error in the "cumulative effects analysis" is the lack of any analysis of the cumulative effects of the five dams on anadromous Atlantic salmon in the Presumpscot River.

As recognized by Commission Staff in other portions of the DEIS, the impoundments of the Saccarappa, Little Falls, Mallison Falls, Gambo Falls and Dundee Falls dams have inundated and destroyed virtually all of the historic Atlantic salmon habitat in the section of the Presumpscot River affected by these dams.

This destruction is so complete that Commission Staff conclude in the DEIS that the provision of fish passage at these would be ineffectual in restoring anadromous Atlantic salmon to the project areas due to the continuous chain of impoundments they have created. In the DEIS, Commission Staff do not even bother to calculate the potential Atlantic salmon production in the project areas with all five dams in place because that production number is zero.

For Commission Staff to discharge their responsibility under NEPA to accurately characterize the cumulative effect of these five dams on anadromous Atlantic salmon, section 4.3.2.3 of the EIS must be revised to explicitly state that:

a) The five dams in this proceeding have destroyed all of the historic Atlantic salmon habitat in the Presumpscot River from Saccarappa Falls in Westbrook to the upper limit of the Dundee Falls dam impoundment in Gorham.

b) The continued existence of these five dams and their impoundments will cause the continued extirpation of anadromous Atlantic salmon from their historic habitat in the Presumpscot River above Saccarappa Falls.

C. Lack of Analysis of Power and Non-Power Benefits.

The DEIS fails to conduct any meaningful analysis of the trade-offs of various public benefits, power and non-power, under the various licensing options. The DEIS makes no attempt to calculate the value of potential economic and social benefits arising from restoration of a significant portion of the Presumpscot River to its free-flowing condition under the selective dam removal option. The DEIS makes no attempt to calculate the economic benefit of restoration of anadromous Atlantic salmon to their native home in the Presumpscot above Ammoncongin Falls; or the lost value to the public resulting from the continued extirpation of Atlantic salmon from the river above Ammoncongin Falls.

When specifically asked about this omission by citizens at the Oct. 25 DEIS public hearing in Windham, Maine, FERC staff member James Haimes stated the Commission would only analyze the value of non-power benefits if there were "hard numbers" available. Mr. Haimes cited no official Commission regulation or policy in support of his statement. Mr. Haimes made no representation that Commission Staff in the DEIS attempted to locate studies or other data that might provide "hard numbers" for the various non-power public benefits pertaining to this proceeding, including recreational angling, canoeing, kayaking, Atlantic salmon fishing, wildlife observation, tourism or economic development; nor did Mr. Haimes make any representation that Commission Staff would attempt to locate and use such data when directly requested to do so by citizens at the October 25, 2001 DEIS public hearing.

Mr. Haimes' characterization of Commission policy is directly contradicted by recent Commission proceedings on the Kennebec and Penobscot Rivers in Maine. In both the Kennebec Basin FEIS (FERC FEIS-0097) and the Lower Penobscot River Basin FEIS (FERC FEIS--0082), Commission Staff discuss at length the value of various non-power public benefits that might accrue or be impacted by various license options studied in this multi-dam proceedings, even when there are no "hard numbers" available for certain uses. In the Kennebec Basin FEIS, Commission Staff devoted considerable analysis to the various non-power recreational benefits that would accrue from removal of the Edwards Dam (see FERC FEIS--0097, p. 4-167 to 4-176); as well as the economic value of whitewater boating activities in the upper Kennebec River basin.

In the Lower Penobscot River Basin FEIS, Commission Staff devoted considerable discussion to the economic and recreational value of Atlantic salmon angling on that river and potential impacts to that value from various licensing options. At pp. 3-55 through 3-61 of the Lower Penobscot River Basin FEIS, Commission Staff discuss in detail the economic value of various recreational uses the lower Penobscot River, ie.:

"We estimate Atlantic salmon anglers fishing the Penobscot River spent $1.65 million on travel and fishing related expenses in 1994. Anglers from outside of Maine accounted for $165,000 of the spending, which represents an infusion to the Maine economy. We estimate the consumer surplus value of Atlantic salmon fishing to anglers was $775,000 in 1994." (FERC FEIS -0082 at p. 3-59).

"Atlantic salmon fishing on the Penobscot River is a cottage industry in the Bangor/Orono area. Four licensed guide services specializing in Atlantic salmon guiding operate out of the Bangor area, and there are four active clubs of salmon anglers in the vicinity of the Veazie Dam." (FERC FEIS-0082 at p. 3-58).

"We estimate people canoeing and kayaking in the project area spent $15,000 in Maine on travel and boating related expenses in 1994 ... We estimate the consumer surplus value of canoeing and kayaking to boaters was $22,000 in 1994." (FERC FEIS-0082 at p. 3-60).

There is no reason why Commission Staff cannot and have not conducted a similar analysis of the economic value of various non-power uses on the Presumpscot River except that Staff have simply chosen not to do so. While Mr. Haimes of FERC stated at the Oct. 25 DEIS public hearing that FERC needs "hard numbers" to conduct such an analysis, the DEIS is completely silent on whether Commission Staff in this proceeding have made any attempt or intend to make any attempt to locate "hard numbers" on the potential value of various non-power uses that would accrue from restoration of the Presumpscot River.

On this topic, the DEIS exhibits an obvious and incomprehensible double standard:

a) The DEIS carefully calculates and documents the financial cost to the license applicant for fish passage, but fails to make any estimate of the value of the public benefits that would accrue from such fish passage.

b) The DEIS calculates the financial cost to the applicant for dam removal and lost value of power accruing from dam removal, but fails to make any estimate of the value of myriad public benefits that would accrue from dam removal.

c) While the DEIS carefully calculates the "lost" financial value to the applicant from dam removal, the DEIS refuses to estimate the lost value to the public from retention of all five dams and the loss of the free-flowing river from Saccarappa Falls to Dundee Falls.

d) While the DEIS carefully calculates the "lost" financial value to the applicant from dam removal, the DEIS refuses to estimate the lost value to the public from the continued extirpation of Atlantic salmon from the Presumpscot River above Ammoncongin Falls; and the lost economic and cultural value to the towns of Westbrook, Windham and Gorham from not having anadromous Atlantic salmon in the Presumpscot River living adjacent to their downtowns and neighborhoods.

e) While the DEIS carefully calculates the "lost" financial value to the applicant from dam removal, the DEIS refuses to estimate the value to the public resulting from the development of highly utilized recreational fishery for salmonids of greater magnitude than the wildly successful recreational fishery in the Eel Weir Reach of the Presumpscot River in Standish, which is now one of the most highly utilized inland fisheries in the entire State of Maine.

Staff's willful failure to conduct any analysis of the value of non-power benefits accruing from dam removal is especially egregious in this proceeding because of the minuscule amount of electrical power produced by the dams proposed for removal and the direct proximity of the Presumpscot River to Maine's largest city, Maine's largest metropolitan area and Maine's largest population concentration.

D. Temperature considerations for resident salmonids.

At page 115 in the DEIS, Staff dismiss the benefits of dam removal for resident salmonid species, claiming without evidence that "marginal" water temperature conditions would preclude the reach from being suitable habitat under dam removal conditions.

Staff cite no evidence in the DEIS to support this conclusion nor do they cite evidence to rebut Dr. Michael Dadswell's citations on this topic as provided to the Commission in June 2001. Dr. Dadswell wrote:

"Because the Presumpscot River flows out of Sebago Lake, the summer temperature regime of the river is controlled by the surface, water temperature of the lake. Surface temperatures in the lake and river usually reach peak levels of 25C during July and August (Davies et al 1978; Woodard and Curran 1997). Brook trout are the most temperature sensitive of the coldwater fishes in the Presumpscot (Scott and Crossman 1973; Coutant 1977), but brook trout are native to the river and have been tolerating these summer water temperatures since populations have occurred there. MDIFW has been stocking brook trout in the Eel Weir Bypass since the late 1980's knowing the species is capable of surviving the higher temperature period using behavioural strategies (Brautigam 1997). The preferred temperature for brook trout is usually exceeded every year in many larger streams and lake surface waters during summer in Maine and southern Canada, where the species is native, but brook trout use behavioural strategies to avoid or tolerate the higher temperature period (Everhart 1966; Scott and Crossman 1973; Gibson 1978). The summer water temperature regime of the Presumpscot is well within the temperature regime tolerated by Atlantic salmon and brown trout (Gibson 1966, 1978; Scott and Crossman 1973), and both species are native and/or naturalized in the Presumscot River. MDIFW annually stocks both species to obtain the maximum benefits for the coldwater fishery in the Presumpscot River (Brautigam 1997). Both Atlantic salmon and brown trout have experimental, upper tolerance limits of water temperature in excess of 27C (Garside 1973; Raleigh et al 1986). Under natural conditions Atlantic salmon juveniles and adults will tolerate river water temperatures over 29C (Huntsman 1942) and in many excellent Atlantic salmon streams in New Brunswick (Miramichi R.) and Quebec (Ste.-Marguerite River) summer temperature maxima normally attain 25-26C (Gibson 1966; Good et al 2001)."

Staff also fail to rebut the historic evidence presented by intervenors (Kendall, 1935) demonstrating that prior to the complete damming of the Presumpscot River in the early 20th century, the river hosted a healthy population of wild salmonids, including the Presumpscot "Jumper." Kendall wrote of the river immediately prior to the construction of the Dundee dam in the early 20th century:

"In the Presumpscot River the resident salmon appeared to subsist largely upon the aquatic stages of various insects such as caddis fly larvae, stonefly and mayfly nymphs, alder fly larvae and nymphs ... Adult stoneflies (locally called 'millflies') were excellent bait for the so-called 'jumpers' of the Presumpscot .... Small salmon resided in the river year-round. Until the new dam was built at the head of the river and the water diverted by a canal these smaller salmon, known as 'Jumpers' were found in the upper part of the river wherever there were waterfalls or rapids. After this the fish were still inhabiting the river below the dam at North Gorham."

Since the DEIS concludes at p. 115 that the dams on the Presumpscot have not significantly increased water temperatures over pre-dam conditions (ie. by concluding that dam removal would not lower river temperatures), there is no rational explanation for their conclusion that with dam removal the Presumpscot's water temperatures would be too warm for salmonids. The historical record clearly shows these fish were abundant in the Presumpscot River until dams eliminated their last remnant, free-flowing habitats in what is now the Dundee Dam impoundment. The DEIS identifies no causal factor for its purported increase in river water temperatures compared to documented conditions in the early 20th century when the river had abundant wild, resident salmonids.

III. Analysis of Staff's Quantitative Assessment Regarding Atlantic Salmon.

In the DEIS, Staff conducts a quantitative assessment of the potential adult Atlantic salmon population expected to occur under each licensing option. This assessment method uses the formula:

RH x SP x ARR = Adult Atlantic salmon production

where:

RH = Atlantic salmon rearing habitat, as expressed in 100 square meter habitat units.
SP = Atlantic salmon smolts produced per 100 square meter habitat unit.
SRR = Percentage of outmigrating Atlantic salmon smolts expected to return to the river as spawning adults.

The accuracy of the calculation used in the DEIS depends on the accuracy of the input values of the three parameters: habitat quantity, smolt production per habitat unit, and percentage of smolts that return as spawning adults.

Below we discuss specific flaws in Staff's quantitative assessment.

A. THE DEIS GROSSLY UNDERESTIMATES THE QUANTITY OF ATLANTIC SALMON PRODUCTION HABITAT THAT WOULD EXIST UNDER THE DAM REMOVAL ALTERNATIVE.

The DEIS estimates the quantity of Atlantic salmon production habitat that would be available with removal of the Little Falls, Mallison Falls and Saccarappa Falls dams by calculating the surface area of the river and subtracting from it those portions of the river containing substrate types that appear to be unsuitable as Atlantic salmon rearing habitat.

In its analysis, the DEIS makes numerous errors that result in a significant underestimate of the Atlantic salmon rearing habitat after dam removal. In summary, these errors are as follows:

1. The DEIS arbitarily concludes that sand-dominated substrates cannot be used by Atlantic salmon as rearing habitat.
2. The DEIS arbitrarily concludes that areas with aquatic vegetation rooted in sand cannot be used by Atlantic salmon as rearing habitat.
3. The DEIS includes in its Atlantic salmon habitat calculation impoundment areas that would be out of the river channel (ie. would be dry land) after dam removal.
4. The DEIS concludes that all areas now containing silt or fine sand substrates will continue to do so after dam removal and that none of these areas will be scoured down to hard substrate suitable for Atlantic salmon.
5. The DEIS arbitrarily excludes 75 percent of the surface area of the Little River drainage as Atlantic salmon production habitat.
6. The DEIS fails to use or reference in its analysis the detailed substrate studies conducted by Northern Ecological Associates (NEA) for intervenors American Rivers and Friends of the Presumpscot River, which use a methodology far superior to that used by the Louis Berger Group.


These errors are discussed in detail below.

1. The DEIS concludes that river areas with sand-dominated substrate cannot be used by juvenile Atlantic salmon as rearing habitat. The DEIS cites no scientific literature or evidence to support this conclusion. In fact, the DEIS cites a scientific literature source (Stanley and Trial, 1995) which states that Atlantic salmon juveniles are able to use sand-dominated substrates as rearing habitat. The DEIS' disqualification of sand-dominated substrate as Atlantic salmon rearing habitat is arbitrary and directly contradicted by literature sources cited in the DEIS. This error in the DEIS results in a significant underestimate of Atlantic salmon rearing habitat in the project areas after dam removal.

2. The DEIS fails to acknowledge that many of the substrate areas identified as "sand" or "sand/silt" in the Louis Berger Group Report actually consist of aquatic vegetation rooted in sand or silt, according to field notes made by Louis Berger Group personnel during their substrate analysis of the project impoundments. These field notes are included as an appendix to the Louis Berger Group Report. The DEIS cites no scientific literature or evidence to support its conclusion that areas with rooted aquatic vegetation cannot be used as rearing habitat by Atlantic salmon. As such, the disqualification of these areas as Atlantic salmon habitat is arbitrary and unsupported by any evidence cited in the DEIS.

The DIES' unsupported conclusion that river bottom areas containing aquatic vegetation rooted in sand or silt provide no habitat for salmonids is a critical assumption in the quantitative analysis because the Louis Berger Group's field notes indicate that much of the sand/silt substrate areas of the Mallison and Little Falls impoundments support rooted aquatic vegetation.

If areas with aquatic vegetation are classified as suitable for juvenile Atlantic salmon, the amount of suitable juvenile salmonid habitat in the Mallison and Little Falls impoundments under free-flowing conditions would increase dramatically over the report's estimates, and would approach 100 percent suitable, since most of the "sand/silt" habitat in these river reaches contains beds of aquatic vegetation, according the field notes in the Louis Berger Group Report.

This error in the DEIS results in a significant underestimate of Atlantic salmon rearing habitat in the project areas after dam removal.


3. In its quantitative Atlantic salmon habitat calculations, the DEIS includes substrate samples from impoundment areas that according to HEC modelling would be dewatered after dam removal. The substrate type in these areas is not relevant to the analysis since, regardless of substrate type, these areas would be out of the water and not available to Atlantic salmon after dam removal.

Because the DEIS uses these sample sites to estimate the proportion of fine and hard substrate areas in the river after dam removal, and the near shore areas of the impoundments are dominated by fine sediments, this error results in an underestimate of the amount of river areas that would be dominated by hard substrates after dam removal.

4. In its quantitative habitat analysis, the DEIS arbitrarily assumes for the purpose of its analysis that no scouring of fine sediments will occur in the former dam impoundments; and therefore no areas now dominated by fine sediments would be scoured down to hard substrate.

This assumption is nonsensical since at numerous locations in the Louis Berger Group dam removal report, the Berger Group describes the near certainty of fine sediment scouring and transport after dam removal, for example:

"The suspended solids concentration may increase for a short time during and after dam removal as sediment from the respective impoundment could erode and be transported downstream." (Berger Group Report at p. xi)

"The impact from eroding sentiment under the three alternatives is considered minor. Fine-grained sediment predominate only in the lower half of the Saccarappa impoundment, although precise volumes were not estimated. Removal of the dams would likely result in some erosion of the bottom sediment over time. Eroded sediment would initially be trapped in the Cumberland Mills impoundment." (Berger Group Report at p. xi)

"Impoundments often accumulate sediments due to reduced flow velocities." (Berger Group Report at p. 27)

"The initial removal may result in some flushing of softer sediments downstream, although the amount of accumulated sediments, based on our field observations, may not be significant. There could be a short-term increase in turbidity, but this would likely subside after a relatively short period of time." (Berger Group Report at p. 40)

"The removal of the three dams would likely mobilize only a limited amount of fine grained sediment (silt/clay). The volume of such sediment is minimal in the Little Falls and Mallison Falls impoundments. In the Saccarappa impoundment, fine grained sediment is found primarily in the lower half of the reach. The available volumes appear to be small but would need to be investigated in more detail for a quantitative determination. Furthermore, sediments mobilized by the removal of the Saccarappa dam would be trapped by the Cumberland Mills impoundment to a large extent, at least initially." (Berger Group Report at p. 41)

In spite of these repeated statements about the near certainty of fine sediment scouring and transport after dam removal, the Berger Group Report assumes in its Atlantic salmon habitat analysis that there will be NO scouring and transport of fine sediments from the former impoundments after dam removal:

"We assumed that the substrate after dam removal would at least INITIALLY be the same as that observed under existing conditions. Since salmon prefer harder substrates for rearing, we estimated the length of river that would INITIALLY have hard substrate if the dams were removed." (Berger Group Report at p. 44, emphasis added)

In this passage, the Louis Berger Group Report authors admit the certainty of scouring and removal of fine sediments from the riverbed after dam removal, but then state that for the purposes of their salmon habitat analysis they will "pretend" that this scouring will not occur.

This assumption completely ignores the temporal scope of the dam removal analysis the Berger Group was hired by the Commission to conduct. According to Scoping Document 2, the Commission did not intend to study only those effects of dam removal that would occur immediately after dam removal. As quoted extensively above, the Berger Group predicts that fine sediment scouring and transport in the Presumpscot River bed may continue to occur over several months or years. The Berger Group also acknowledges that such scouring would result in the removal of fine sediment from the riverbed and the reversion of soft substrate areas to hard substrate suitable for Atlantic salmon; and that this scouring could result in a net increase in hard substrate compared to pre-dam removal conditions.

At p. 44, the Berger Group Report authors state that because it would be difficult to calculate the EXACT amount of fine sediment scouring that would occur after dam removal, they assume for the purpose of calculation Atlantic salmon habitat that NO fine sediment scouring will occur. This is analogous to saying that because it is difficult to calculate the exact number of linear feet of rapids or riffles that would be created by dam removal, it is assumed that NO rapids or riffles would be created.

The Berger Group authors are incorrect in stating it is difficult or impossible to predict the magnitude of fine sediment scouring that would occur after dam removal.

HEC modelling at eleven sites in the Saccarappa, Little Falls and Mallison Falls impoundments shows that with dam removal, river velocities would exceed one foot per second at nine of eleven sites at median June flows (50 percent exceedence).

Standard estimates of the ability of various river flow velocities to suspend and transport particles of a given size and mass could be used to calculate the likelihood of fine sediment erosion and transport at the flow velocities predicted by the HEC modelling data.

The DEIS could also use existing flow and substrate data from other Maine rivers to determine the likelihood of fine sediment scouring and retention under similar conditions as predicted by the HEC modeling. For example, DEIS authors could use recent substrate and velocity data gathered by the Maine Dept. of Marine Resources on the restored reach of the Kennebec River. DMR data shows that the restored reach of the Kennebec, in areas with similar flow velocities as those predicted for the Presumpscot, has reverted to a hard substrate dominated by gravel, cobble and/or boulder with minor amounts of sand. In the Kennebec, areas with flow velocities of one foot per second or more are practically devoid of silt and sand is either absent or a minor component of the substrate. Numerous sites along that river show that current velocities are high enough to transport large quantities of sand or silt out of the river channel and into adjacent shorelines, flood plains or to other locations downriver.

Even a cursory review of the HEC data shows that with dam removal much of the river from Gambo Falls to Saccarappa Falls would have current velocities far too high to allow fine sediments to remain in place.

The expressed purpose of the Berger Group Report's substrate analysis was to estimate the quantity of Atlantic salmon habitat that would be made available by dam removal. To make this estimate, the Berger Group assumed that all areas of hard substrate would be Atlantic salmon rearing habitat and that areas of fine sediment would not be salmon habitat. This methodology dictates that if any areas now containing fine sediment are likely to be scoured to due to increased current velocity, these areas become Atlantic salmon habitat.

For the Berger Group to assume that no scouring of fine sediment areas will occur with dam removal is contrary to the laws of physics as well as the HEC model's predictions of current velocities after dam removal. As the Berger Group states in its report, fine sediment scouring occurs as the result of increased current velocities and the HEC modelling data clearly shows substantial increases in current velocity with dam removal.

While it may not be possible to predict the exact number of square yards of fine sediment areas that will be scoured with dam removal, there is no justification or evidentiary support to assume that no scouring will occur and all of the fine sediment areas identified by the Berger Group's field studies will remain in place.

Louis Berger Group Report authors explicitly state that their quantitative estimate of Atlantic salmon production is dependent on a dam removal scenario they admit will not occur (ie. zero erosion and transport of fine sediments from the impoundments).

This error in the DEIS results in a significant underestimate of Atlantic salmon rearing habitat in the project areas after dam removal.

5. The most egregious error in the DEIS' estimates of Atlantic salmon habitat in the Little River drainage. Without any credible evidence or scientific support, the DEIS declares that only 25 percent (10 stream miles) of the Little River and its tributaries contain suitable Atlantic salmon habitat. The sole justification given for this conclusion is a single paraphrase from Dube (1983) regarding potential competition between warmwater fish species and Atlantic salmon juveniles in the Little River drainage (DEIS at 105-106).

The DEIS uses this one paraphrase of Dube to completely dismiss 75 percent of the Little River drainage as Atlantic salmon habitat. This conclusion is arbitrary and incorrect for a number of reasons:

a) If Staff believes the presence of warmwater species in Atlantic salmon habitat makes that habitat useless, then Staff must conclude that the entire Presumpscot River drainage is devoid of Atlantic salmon habitat since warmwater species in varying numbers exist throughout the drainage. However, Staff's discussion of Atlantic salmon habitat in the main-stem Presumpscot makes no mention whatsoever of negative impacts from warmwater species; nor does Staff completely dismiss all of the potential salmon habitat in the main-stem Presumpscot due to the presence of warmwater fish species.

b) Taken literally, this "warmwater fish species" hypothesis forwarded by Staff regarding the Little River means that there is no suitable juvenile Atlantic salmon habitat anywhere in the entire State of Maine, since nearly all of the state's Atlantic salmon rivers contain populations of other fish species which compete for food and space with juvenile Atlantic salmon.

c) Staff's complete dismissal of 75 percent of the Little River drainage as Atlantic salmon rearing habitat is directly contradicted by Staff's physical description of the Little River at page 105 in the DEIS:

"Although the lower approximately one mile of the [Little River] is currently backwatered by the Saccarappa impoundment, with primarily a sand/silt substrate, the Little River upstream of the back-watered area is free flowing and appears to offer salmonid habitat, with a substrate of gravel/cobble/boulder and sequences of riffles, runs and pools."

The above statement in the DEIS refers to the EXACT SAME HABITAT that Staff declares unusable for Atlantic salmon juveniles based on Dube (1983). Essentially, Staff says the Little River does offer salmon habitat in one sentence and then says it doesn't offer salmon habitat in the next sentence.

d) Even if one accepts Staff's premise that warmwater fish species may limit the use of otherwise good habitat by juvenile Atlantic salmon, Staff offers absolutely no explanation as it how it concluded that EXACTLY 75 percent of the Little River drainage is rendered useless for Atlantic salmon due to this single hypothetical factor. Staff cites absolutely no field work or studies which show what percentage of the Little River drainage contains large populations of warmwater fish; and cites no studies or evidence to show that 75 percent of the Little River drainage is dominated by warmwater fish species.

e) The DEIS fails to note that the single source cited by Staff to support its "warmwater fish" hypothesis does not state that the presence of warmwater fish in salmon habitat completely prevents any use of that habitat by juvenile Atlantic salmon. Despite this, the DEIS declares as fact that the presence of warmwater fish in Atlantic salmon habitat completely eliminates the ability of any juvenile Atlantic salmon to survive in the habitat whatsoever.

Staff provide no credible evidence to support either the qualitative or quantitative aspects of their decision to declare that 75 percent of the Little River drainage is unsuitable Atlantic salmon rearing habitat. The scientific rationale for the "warmwater fish" hypothesis forwarded on the Little River is without any foundation and is directly contradicted by Staff's conclusions regarding Atlantic salmon habitat at other points in the DEIS. Staff's specific quantitative estimate of salmon habitat rendered unusable in the Little River has no factual foundation whatsoever. It is obvious that the Louis Berger Group simply made up this 75 percent figure out of thin air.

Staff cites no evidence showing what portion, if any, of the Little River lacks the physical attributes of Atlantic salmon rearing habitat, ie. depth, substrate, temperature. For this reason, Staff have no factual basis to dismiss ANY of the drainage as potential Atlantic salmon habitat, let alone 75 percent of it.

The Atlantic salmon habitat figures provided in the DEIS for the Little River are incorrect and should be recalculated. The use of a more appropriate estimate, ie. 75 percent of the drainage being suitable for Atlantic salmon, would increase the number of Atlantic salmon habitat units in the drainage from the 981 units to nearly 3,000 units; would increase smolt production in the drainage from 2,943 to nearly 9,000; and triple the potential adult production in the Little River drainage (using Staff's return rate values), ie. from 15-44 adults to 45-132 adults.

This adjustment alone would nearly double Staff's estimate of the total potential Atlantic salmon run to the entire Presumpscot River: from 34-102 adults to 64-190 adults.

B. THE DEIS INCORRECTLY AND ARBITRARILY ASSIGNS A MAXIMUM ADULT SALMON RETURN RATE OF 1.5 PERCENT.

In its calculations of potential adult Atlantic salmon returns, the DEIS assigns a minimum-maximum range of adult salmon return rates that could potentially occur in the Presumpscot River over a 30-40 year license term. Staff's use of a minimum-maximum range is appropriate and preferable to a single return rate since actual adult return rates in the species' range can vary widely over time in one salmon population and between various river populations during the same time period. Data provided by Baum (1997) and Dadswell (this proceeding) illustrate the wide temporal and geographic variance in adult return rates across the species' North American and worldwide range.

Despite abundant evidence to the contrary, the DEIS assigns a maximum adult return rate of 1.5 percent for the Presumpscot River, citing to Baum (1997). However, the "maximum" return rate value chosen by Commission Staff is not even close to the maximum observed return rate cited by Baum in this work. Baum provides data showing adult return rates far higher than 1.5 percent, such as a 3 percent return rate in Cove Brook, a tributary of the Penobscot River; and a return rate of 15 percent in Maine's Sheepscot River. Regarding adult Atlantic salmon return rates observed in Maine, Baum wrote:

"The most thorough information on this subject was collected in the 1950s in the Sheepscot River and Cove Brook (a tributary of the Penobscot River), when biologists estimated that wild smolt survival ranged from 3 percent (in Cove Brook, Meister 1962) to 15 percent (in the Sheepscot River); USFWS 1960)."

The DEIS' assignment of 1.5 percent as the MAXIMUM return rate for the Presumpscot River is incorrect and arbitrary for numerous reasons.

1. This assignment is directly contradicted by the same literature source cited by the DEIS, ie. Baum (1997). According to this source, the MAXIMUM adult return rate observed in Maine to date is 15 percent, not 1.5 percent.

2. The selection of 1.5 percent is arbitrary since Staff offers no explanation or justification why it did not use the much higher observed return rates cited in Baum (1997) as a maximum return rate its population projection on the Presumpscot River.

3. The DEIS fails to utilize or consider the applicability of documented return rates in other Atlantic salmon rivers as provided by Dadswell (this proceeding); nor does the DEIS provide any explanation or scientific basis for its rejection of other documented return rates higher than its selected value of 1.5 percent.

Staff is correct in using past observed adult salmon return rates as a tool to estimate a potential range of return rates that may be occur on the Presumpscot River in the future. However, this approach obliges Staff to use upon the maximum return rates observed in the past in Maine and elsewhere as the basis for its analysis. The correct use of the data in Baum (1997) requires that Staff assignment of 15 percent as the MAXIMUM return rate for the Presumpscot, since this is figure is the maximum observed return rate provided in the scientific literature cited by Staff as its source.

This error in the DEIS results in a significant underestimate of Atlantic salmon production potential in the project areas after dam removal.

C. CORRECT USE OF THE MAXIMUM RETURN RATE DATA CITED BY STAFF IN BAUM (1997) RESULTS IN A MUCH HIGHER ADULT SALMON POPULATION THAN PROJECTED IN THE DEIS.

Use of the 15 percent maximum observed return rate in Maine cited by Baum (1997) produces a 10-fold increase in the potential Atlantic salmon population compared to the figures now in the DEIS. This factor alone causes the potential Atlantic salmon population estimated in the DEIS to increase to over 1,000 Atlantic salmon adults.

The selection of a numeric value to represent a maximum adult return rate plays an enormous role in determining the potential Atlantic salmon population that could be restored via dam removal.

Neither Commission Staff or the most competent Atlantic salmon biologists have the ability to accurately predict Atlantic salmon return rates in the Presumpscot River over the next 30-40 years. Nor does Staff have sufficient information to predict adult return rates specific to the Presumpscot River drainage, since no river specific return rate data exists for the Presumpscot.

For these reasons, Staff has taken the correct and appropriate steps of:

a) utilizing a range of potential return rates for its analysis.
b) utilizing actual return rates documented in the past on other Atlantic salmon rivers.

Staff is correct in not selecting an "average" or "median" return rate as a benchmark for its analysis. As stated by Baum (1997), gaining an accurate estimate of adult return rates in a river is challenging because of the difficulty in capturing and counting ALL outmigrating smolts and ALL returning adults in a river in a given year. And as further illustrated in Baum (1997), direct studies of adult return rates in Maine are relatively few, have only been done on a handful of rivers, and all were done in a period when Atlantic salmon populations had already sharply declined due to habitat degradation, commercial fishing, dilution of native stocks with hatchery-reared fish and other human factors. Most of the adult return rate studies conducted in Maine have been done over a relatively short time frame, preventing the detection of long-term trends.

The most reliable inference which can be drawn from the return rate studies cited in Baum (1997) and Dadswell (this proceeding) is that adult return rates in Maine and in other portions of the species' range are highly variable and can vary by several orders of magnitude.

For these reasons, we support Staff's use of a minimum-maximum range. However for Staff's analysis to be credible and transparent it must assign as a maximum value the actual maximum adult return rate provided in the literature cited by Staff. The 15 percent return rate cited in Baum (1997) is the appropriate MAXIMUM since it is the highest return rate cited in the literature source chosen by Commission Staff.

The sole basis of Staff's rejection of dam removal is that a population of 30-102 salmon is not "big enough" to justify dam removal. Use of the 15 percent maximum return rate at Table 22 on page 107 in the DEIS results in a potential Presumpscot River Atlantic salmon population of 1,024 adults. The DEIS does not assess the public benefits of a population of this size; nor does the DEIS analyze the lost value of a Atlantic salmon population of this size if the selective dam removal alternative is rejected in favor of retaining all the dams.

PART TWO:

I. Overview of Staff's qualitative conclusions regarding anadromous Atlantic salmon.

Staff's Atlantic salmon analysis in the DEIS consists of two discrete components. First is a quantitative assessment of the potential Atlantic salmon population that would be possible with selective dam removal. The second component consists of an extremely vague conclusion regarding what constitutes "enough" Atlantic salmon to justify the measures necessary to restore the species to its home in the Presumpscot River.

In the DEIS, Commission staff make the following qualitative conclusions regarding Atlantic salmon:

a) Anadromous Atlantic salmon are indigenous to the Presumpscot River, including those portions of the river in the project areas.
b) Anadromous Atlantic salmon have been completely extirpated from the project areas, due to the lack of any fish passage at any of the project dams for more than a century.
c) The project dam impoundments provide no spawning or rearing habitat for anadromous Atlantic salmon.
d) Suitable habitat for anadromous Atlantic salmon would exist if the Little Falls, Mallison Falls and Saccarrappa Falls dams were removed and their impoundments were restored to a free-flowing, riverine condition.

We agree with these conclusions made by Commission Staff and the factual evidence upon which they are based.

Commission Staff rejects removal of any of the five dams in this proceeding despite its findings in the DEIS that:

a) Decommissioning of the Little Falls, Mallison Falls and Saccarrappa Falls dams would restore free-flowing habitat sufficient to support a population of wild anadromous Atlantic salmon in the project areas.

b) Retention of these dam impoundments would effectively prevent the restoration of a wild anadromous Atlantic salmon population of any size to the project areas.

Our key concerns about Staff's conclusions in this regard are as follows:

A. THE DEIS DOES NOT STATE WHAT NUMBER OF ATLANTIC SALMON COMMISSION STAFF BELIEVE WOULD BE "ENOUGH" TO JUSTIFY DAM REMOVAL, YET STAFF REJECTS DAM REMOVAL DUE ITS INABILITY TO ACHIEVE THIS UNSTATED QUANTITY OF ATLANTIC SALMON.

Based on its quantitative habitat assessment, Staff estimates removal of the three dams would produce 30-100 adult Atlantic salmon to the project areas each year. Staff conclude this number of adult salmon is not large enough to justify the dam removals required to restore this number of Atlantic salmon.

The DEIS provides no information or discussion on what Staff considers "enough" salmon to justify dam removal or how Staff arrived at their conclusion that 30-100 salmon is not "enough."

This argument implies Commission Staff have arrived at a specific threshold number of Atlantic salmon that would be sufficient to justify dam removal. This number is never mentioned or discussed in the DEIS, even though Staff's conclusion regarding Atlantic salmon appears to be wholly based upon it.

If Commission Staff believe there is some number of Atlantic salmon sufficient to justify dam removal, Staff should state this number in the EIS and provide the evidence or scientific literature used to arrive at it.

If Commission Staff believe there is no number of Atlantic salmon sufficient to justify dam removal, then Staff should state this explicitly in the EIS.

In Scoping Document 2, Staff declared their intent to fully analyze the potential benefits for Atlantic salmon that might accrue from dam removal. In accordance with this goal, in the DEIS Commission Staff conducted a detailed analysis of Atlantic salmon benefits from dam removal and hired consultants (the Louis Berger Group) to gather key scientific information for this analysis. All of this clearly implies the Commission Staff must have developed a specific "yardstick" of what number of Atlantic salmon would be sufficient to justify dam removal and what number would not be sufficient.

Without the inclusion of specific, detailed information about this numeric "yardstick" and the basis upon which it was derived, Staff's conclusion regarding Atlantic salmon in the DEIS is completely arbitrary and without any factual support .

B. THE DEIS FAILS TO EXPLAIN HOW ITS LICENSE RECOMMENDATION WILL ALLOW FOR ACHIEVEMENT OF DECLARED CITIZEN, STATE AND FEDERAL AGENCY GOALS TO RESTORE ATLANTIC SALMON TO THEIR NATIVE HABITAT IN THE PRESUMPSCOT RIVER.

In Scoping Document 2 and the DEIS, Commission Staff clearly signal their intent to fully consider the potential for restoring Atlantic salmon to the Presumpscot River in the project areas. This statement of intent was in response to the high level of interest in Atlantic salmon restoration on the Presumpscot expressed by local citizens, citizen intervenor groups and state and federal fisheries agencies. Statements of interest in Atlantic salmon restoration by these parties were made via oral and written comments during the Scoping process and through numerous filings with the Commission by citizen intervenors and state and federal agencies.

Despite this broad swath of interest in Atlantic salmon restoration, Staff in the DEIS recommends a license alternative it admits will preclude the restoration of Atlantic salmon in the Presumpscot River in the project areas; and Staff rejects the only proferred license alternative that -- based on Staff's own analysis -- would allow Atlantic salmon to be restored to the project areas.

While rejecting the selective dam removal option offered by citizen intervenors on the basis that it would not produce "enough" salmon, Commission Staff fail to propose or recommend a license option that would allow for ANY opportunity to restore ANY anadromous Atlantic salmon to their historic habitat in the project areas.

In the DEIS, the Commission appears to have unilaterally decided that Atlantic salmon should not be restored to their native home in the Presumpscot River above Ammoncongin Falls; that state and federal agency goals for the species in the Presumpscot River should be vacated and ignored; and that the significant public desire for Atlantic salmon to be restored to their native home in the Presumpscot River should be arbitrarily and completely denied.

Staff's conclusion completely trivializes the EIS process for this relicensing. Five citizen groups, all granted intervenor status by the Commission, have specifically identified restoration of Atlantic salmon to the Presumpscot River in the project areas as one of their key interests in this proceeding. During the oral and written scoping phase of this proceeding, all five citizen intervenor groups specifically requested that Atlantic salmon restoration be a key issue for study by the Commission in the EIS. Two public agencies, the Maine Atlantic Salmon Commission and the U.S. Fish & Wildlife Service, have made similarly pointed and specific requests.

The DEIS clearly shows that when confronted with a species such as Atlantic salmon that cannot survive in a river that has been converted to a continuous chain of dam impoundments, Commission Staff chose to simply ignore Atlantic salmon and to ignore the interests of all the parties who seek the restoration of Atlantic salmon to its native home in the Presumpscot River.

C. STAFF'S LICENSE RECOMMENDATION WILL PREVENT THE MAINE ATLANTIC SALMON COMMISSION FROM ACHIEVING ITS LEGISLATIVELY ESTABLISHED PURPOSE OF RESTORING ATLANTIC SALMON TO THEIR NATIVE HABITAT IN THE PRESUMPSCOT RIVER.

In 1999, the 119th Maine Legislature enacted 12 MRSA §9901, creating the Maine Atlantic Salmon Commission. In this law, Maine's Legislature established the purpose of the Maine Atlantic Salmon Commission. Sub-section one of this law states:

"1. Commission established; purposes. The Atlantic Salmon Commission referred to in this Part as the "commission" is established to protect, preserve, enhance, restore and manage the Atlantic salmon and its habitat; to secure a sustainable recreational fishery in the state; and to conduct and coordinate all projects involving research, planning, management, restoration or propagation of the Atlantic salmon."

By recommending a license option which Commission Staff admits will prevent restoration of anadromous Atlantic salmon to the Presumpscot River above Cumberland Mills, Staff have fundamentally prevented the Maine Atlantic Salmon Commission from achieving its legislatively established purpose to "protect, preserve, enhance, restore and manage the Atlantic salmon and its habitat" in the species' historic habitat in the Presumpscot River from Ammoncongin Falls to Sebago Lake.

In comments filed with the Commission, the Maine Atlantic Salmon Commission has repeatedly stated its interest in seeking conditions which would allow for the restoration of anadromous Atlantic salmon to the portion of the Presumpscot subject to this proceeding; and the Maine Atlantic Salmon Commission has informed Commission Staff that the Presumpscot River above Ammoncongin Falls is historic anadromous Atlantic salmon habitat and thus is fully covered in the Atlantic Salmon Commission's legislatively established purpose to "protect, preserve, enhance, restore and manage the Atlantic salmon and its habitat."

By its own admission, Staff's license recommendation in the DEIS will fundamentally prevent the Maine Atlantic Salmon Commission from fulfilling its legislatively mandated mission to restore Atlantic salmon to their habitat in the Presumpscot River above Ammoncongin Falls in Westbrook.

In its Atlantic salmon analysis in the DEIS, Staff does not discuss whether its license recommendation will allow the Maine Atlantic Salmon Commission to achieve its mission to "protect, preserve, enhance, restore and manage the Atlantic salmon and its habitat" in the Presumpscot River as set forth by the 119th Maine Legislature in 12 MRSA §9901.

The DEIS fails to mention or discuss the fact that selective dam removal is -- according to Staff's own analysis -- the only license option that would allow the Maine Atlantic Salmon Commission to achieve its legislatively established purpose to "protect, preserve, enhance, restore and manage the Atlantic salmon and its habitat" in the species' historic habitat in the Presumpscot River above Cumberland Mills.

In the DEIS, the Staff fails to mention or discuss that its recommended license alternative would fundamentally prevent the creation of a "sustainable recreational fishery" for Atlantic salmon in the Presumpscot River above Cumberland Mills, thus preventing the achievement of the second legislative charge of the Maine Atlantic Salmon Commission as set forth in 12 MRSA §9901.

Staff also fails to mention or discuss that according to its own analysis, selective dam removal is the only license option studied in the DEIS that would allow for any future recreational fishery for Atlantic salmon in the Presumpscot River above Ammoncongin Falls in Westbrook, a public benefit and goal clearly envisioned and desired by the Maine Legislature when it established the purpose of the Maine Atlantic Salmon Commission.

The analysis provided by Staff in the DEIS shows its recommended license option will fundamentally prevent the achievement of any of the goals set forth by the Maine Legislature for the Maine Atlantic Salmon Commission respecting anadromous Atlantic salmon and their habitat in the Presumpscot River above Ammoncongin Falls in Westbrook.

CONCLUSION

The Presumpscot River is virtually unique among historic Atlantic salmon rivers in Maine due to its extremely intensive use as a source of hydro-electric power. Today, dam impoundments on the Presumpscot River inundate nearly the entire river bed from the head of tide at Presumpscot Falls to the river's source at Sebago Lake. These dam impoundments have destroyed virtually all of the historic habitat for anadromous Atlantic salmon in the Presumpscot River. The five dams in this proceeding have inundated and destroyed virtually all of the historic habitat for the species in the river from Saccarappa Falls dam to the base of the North Gorham dam.

Due to the inability of Atlantic salmon to utilize dam impoundments as spawning and rearing habitat, and the impoundment of virtually the entire Presumpscot River above Saccarappa Falls by dams, the retention of all of the dams in this proceeding precludes the restoration of the anadromous Atlantic salmon to their indigenous habitat in the project areas.

In the DEIS, Commission Staff does not question or reject the validity or existence of state and federal Atlantic salmon restoration goals for the Presumpscot River; nor does Staff say the species was never present in the river or project area; nor does Staff say that Atlantic salmon could not be restored to the project area even if the dams were removed; nor does Staff assert that federal and state Atlantic salmon restoration goals can be met with all the dams remaining in place.

Instead the DEIS uses a de minimis argument, arguing that since removing one dam will only restore a "few" salmon, that's not enough. Since removing two dams will only restore a "few more" salmon, that's not enough. And since removing three dams will only restore a "few more" salmon, that's not enough either.

In the DEIS, Staff use circular logic in dismissing their responsibility to carefully and equitably strike a balance between hydro-electric power and the needs of Atlantic salmon in the Presumpscot River, ie.:

-- restoring a small number of salmon is unacceptable because the number is too low to justify the loss of a small amount of power.
-- restoring a "medium" number of salmon is unacceptable because the number is still too low to justify the loss of a "medium" amount of power.
-- restoring a large number of salmon is unacceptable because the number is still too low to justify a "large" loss of power.
-- in Staff's view, there appears to be no number of Atlantic salmon sufficient to justify any loss of hydro-electric power.
-- therefore, no Atlantic salmon.

Given the latitude of options the Commission has in this five dam proceeding, it is specious for the Commission to claim it has given "equal consideration" to Atlantic salmon by rejecting every license option that provides some consideration to Atlantic salmon and selecting a license option that gives no consideration to Atlantic salmon.

Balance usually implies a point somewhere between 100 and zero. The balance struck for Atlantic salmon in DEIS will, by staff's own admission, result in the species' continued extirpation from the Presumpscot River above the Saccarappa Falls Dam. In this case, it seems the Commission's "balance" for Atlantic salmon is a point somewhere between zero and zero.

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Literature Cited:

Baum, E.T. 1997. Maine Atlantic Salmon: A National Treasure. Atlantic Salmon Unlimited, Hermon, Maine.

Berger Group. 2001. Impact assessment of the removal of the Little Falls, Mallison Falls, and Saccarappa dams along the Presumpscot River and appendices. Prepared for Federal Energy Regulatory Commission, FERC RIMS DOC 2192120.

Dadswell, M. J. 2001. Fishery impacts from relicensing five hydroelectric projects on the Presumpscot River, Maine. Friends of the Presumpscot River. June 2001.

Federal Energy Regulatory Commission. 2001. Draft environmental impact statement. Presumpscot River projects. FERC/DEIS -- 0139D.

Federal Energy Regulatory Commission. 1997. Lower Penobscot River Basin. Final Environmental Impact Statement. FERC/FEIS--0082.

Federal Energy Regulatory Commission. 1997. Kennebec River Basin. Final Environmental Impact Statement. FERC/FEIS--0097.

Kendall, W.C. 1935. The Fishes of New England. The Salmon Family. Part One - The Salmons. Memoirs of the Boston Zoological Society.

Northern Ecological Associates. 2001a. Substrate survey of the Mallison and Little Falls impoundments and preliminary substrate survey of the Saccarappa impoundment, Presumpscot River, Maine. Prepared for American Rivers, Inc and The Friends of the Presumscot River. January 2001.

Northern Ecological Associates. 2001b. Final report of a substrate survey of the Mallison, Little Falls, and Saccarappa impoundments, Presumpscot River, Maine. Prepared for American Rivers Inc and The Friends of the Presumpscot River. February 2001.

Northern Ecological Associates. 2001c. Remaining substrate survey of the Saccarappa impoundment, Presumpscot River, Maine. Prepared for American Rivers Inc. and The Friends of the Presumpscot River. June 1, 2001.


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