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Mr. Frank L. Cassidy, Jr.
Chair, Northwest Power Planning Council
851 Sixth Avenue, Suite 1100
Portland, OR 97204-1348
Dear Chairman Cassidy:
This letter transmits the National Marine Fisheries Service’s (NMFS) recommendations to the Northwest Power Planning Council (Council) for amending the Columbia River Basin Fish and Wildlife Program (Program). NMFS provides these recommendations to strengthen the Program’s ability to help recover the Columbia River Basin’s anadromous salmonid populations that are listed under the Endangered Species Act (ESA) as threatened or endangered.
NMFS agrees with the Program amendment’s proposed direction. The proposed amendment will help ensure that funding decisions have improved context, scientific foundation, and accountability. NMFS also appreciates the sincere efforts the Council has made to work with NMFS and to address ESA concerns in these amendment proceedings.
The Council’s Program can substantially contribute to salmon and steelhead recovery in the Columbia River Basin. Presently, twelve evolutionarily significant units (ESUs) of chinook, chum, sockeye salmon and steelhead are listed throughout the Basin, including the Snake, Upper Columbia, Mid-Columbia, Lower Columbia, and Willamette basins. Although there are many recovery efforts throughout the Basin, the Council’s program is the only one that has the ability to integrate all of these efforts across the entire Basin. The Council can call for the establishment of consistent recovery goals and performance measures to guide the Program. Through the Bonneville funding process, the Council can direct the allocation of significant resources toward protection and restoration of anadromous fish. The Council also has an excellent record of public outreach and involvement that can ensure broad participation by the diverse parties in the Basin. NMFS believes the Council’s Program can provide a strong foundation for NMFS’ recovery planning efforts as well as those of other entities throughout the Basin.
The Council’s Program can target rate-payer resources effectively as well as influence the effective targeting of the resources of other entities in the Basin. The Program can target resources rapidly and effectively toward short term "immediate actions" and longer term subbasin assessments and plans. In the near term, the Council can direct funding toward high priority actions that are identified prior to the completion of subbasin assessments and plans. The more enduring effort will be to conduct subbasin assessments and implement subbasin plans of actions that target priority risks and opportunities. The Council is in a position to determine the quality and timeliness of the assessments and plans as well as the likelihood the plans will be implemented.
All restoration efforts in the Basin would benefit from an integrated and comprehensive framework for science, which the Council’s Program can provide. The common goals and performance measures mentioned above should guide the establishment of common research, monitoring and evaluation strategies. With the assistance of the Independent Science Advisory Board and other scientists in the Basin, the Council can develop a comprehensive monitoring program throughout the Basin and a standard data collection and reporting system that will greatly improve the scientific foundation of all restoration efforts in the Basin.
NMFS is presently developing key documents related to our ESA responsibilities that will have a bearing on the Council’s Program. Those key documents include an ESA section 7 consultation on the Federal Columbia River Power System (FCRPS Opinion) and the revised "All-H" Paper (Conservation of Columbia Basin Fish - Building a Conceptual Recovery Plan). The FCRPS Opinion will provide considerable detail on future operations and configuration of the Federal hydropower system. The All-H paper will provide a conceptual recovery framework for harvest, hatcheries, hydro power and habitat actions that affect listed salmonids. The All-H paper is being developed in partnership with the nine federal agencies comprising the Federal Caucus. When the All H paper and FCRPS opinion are final, they will add substantial detail and clarity to NMFS’ concerns and recommendations for the Program amendment.
NMFS is also initiating formal recovery planning for listed species in the region. We have initiated recovery planning for the Willamette and lower Columbia River ESUs. We have not yet scheduled formal recovery planning for the remaining Columbia River ESUs. We believe there will be significant opportunities to blend the NMFS recovery planning process with the Council program throughout the Basin. The All-H paper will provide a conceptual recovery plan framework for all ESUs, but will not include specific population assessments and management measures necessary for the formal recovery plans.
NMFS notes that the Council has already made substantial progress on important issues - completing Multispecies Framework process, developing a subbasin assessment template, and working toward criteria for high priority actions.
In preparing these comments, NMFS reviewed the Council’s January 12, 2000, request for comments, the February 24, 2000, draft strawman, and the April 11, 2000, Council clarification letter. In addition, senior NMFS staff have worked closely with Council staff on clarifying and developing components of the proposed amendment. We look forward to working closely with you over the summer to further address these and other entities’ recommendations for the amendment.
Sincerely,
Donna Darm
Assistant Regional Administrator
Protected Resources Division
Enclosure
cc: Federal Caucus Agencies
CRITFC - Don Sampson
CBFWA - Brian Allee