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May 12, 2000
Northwest Power Planning Council
851 SW Sixth Street, Suite 1100
Portland, OR 97204
Re: Fish & Wildlife Program/Framework Concept: Strawman
Dear Sirs:
PNUCC believes that the Council has a very unique opportunity as you create your next fish and wildlife program. The Council is well positioned to pick up the regional ball on Columbia River Basin fish and wildlife planning and to incorporate, coordinate and balance the various fish and wildlife activities in the region with the needs of the people in the Pacific Northwest. We see the Council’s program amendment process as the place where the mandates of the Northwest Power Act, the Endangered Species Act and Northwest state interests can be integrated as a comprehensive, scientifically-based plan to benefit the region’s salmon and wildlife populations.
Thus, we offer the following general comments to enhance the work you have begun. The attached detailed comments support these general thoughts and further articulate our ideas, suggested changes and concerns.
The Strawman Concept Paper is a good start for a framework that provides guidelines for developing the Council’s next Program. This kind of structured thinking and vision have been lacking in the region’s fish and wildlife management. Through participation in your Framework study, we are convinced that the lack of a regionally accepted, consistent vision is at the root of today’s salmon crisis. It is crucial that the Council’s final conceptual framework include a vision that is clear about where you see the region heading and what you expect to achieve, establishes internally consistent, scientifically sound goals, and defines which goals are most important by setting specific priorities. To help illustrate what we mean we have provided an example vision in the attached detailed comments.
Further, to assure your vision and goals are achievable the Council will have to help resolve the inherent conflicts found in a long list of mandates and laws designed to provide policy guidance. The Council should take on the challenge of identifying the conflicts that exist and propose ways to eliminate them.
Creating this Program will require a new level of coordination with federal, state, county and local agencies. The Council is in the unique position to provide this badly needed leadership by developing a clear watershed-by-watershed priority scheme that identifies biological objectives for each watershed within the Program. In this way we see you helping the region decide on clear biological goals of each sub-basin guided by your overall vision for the region. This activity is critical to bring about a rational balance between the mandates of the ESA and the drive to enhance production of fish to support fisheries. Only when the region has clearly defined the relationship between "recovery" and "production" in a way that establishes some degree of compatibility between these goals will it be remotely possible to achieve either goal.
The Strawman Concept Paper is too complex and lacks clarity. We recommend you remove as much of the jargon as possible and keep the discussion at the policy level. We suggest that a scientific document be developed to accompany the Concept paper. Its purpose would be to articulate the scientific foundation for the Council’s framework and the Program. We believe the planning assumptions included in your document need sorting. The original list of assumptions includes both policy judgements and simple factual statements or assumptions. These are currently intermingled and cause confusion about the policy decisions the Council is making. We have also provided you with a list of additional planning assumptions and policy judgements that the Council should consider for inclusion in your final conceptual framework.
We agree that the Program should address the entire salmon and steelhead life-cycle including spawning and rearing habitat, river passage for both adults and juveniles, and conditions in the estuary and ocean. By accepting the challenge of creating a comprehensive program the Council will help the region bring together disjointed and uncoordinated policies and decisions of numerous agencies and groups. In this way the Program could provide an umbrella for coordinating the frequently disconnected policies guiding changes in harvest, hatcheries, habitat and hydropower. While the Council lacks statutory authority in some of the areas of the salmon’s lifecycle, there is a desperate need for leadership, coordination and accountability. We support the Council developing what can become a "habitat conservation plan" for the Columbia River Basin.
We look forward to discussing these issues and any others as they arise during the amendment process. Thank you for tackling this important, challenging task.
Sincerely,
(Original with signatures)
| Gerry Miller | Dave Piper | Jim Miller |
| Goldendale Aluminum | PNGC | Idaho Power Co. |
| Chairman | 1st Vice-Chair | 2nd Vice-Chair |