Related link: Budget Tracking and Adjustment
Process (60k PDF)
August 22, 2005
Mr. Bill Maslen
Director, Fish and Wildlife
Bonneville Power Administration
P.O. Box 3621
Portland, Oregon 97208
Dear Mr. Maslen,
RE: Recommendations
for project funding in Fiscal Year 2006 to implement the Fish and
Wildlife Program
At its August 2005 meeting in
Missoula, the Council decided on its start-of-year project and
budget recommendations to Bonneville to implement the Council's
Columbia River Basin Fish and Wildlife Program in Fiscal Year 2006. Attached to this letter are a
set of tables (100k PDF) listing the
projects recommended for both expense and capital funding, with
recommended budgets and, where appropriate, specific guidance
through brief comments.
Budget total. The
projects recommended for expense funding by Bonneville total
$157,168,092 million, along with $55,827,548 million in capital
funding. The Council acknowledges Bonneville's accrual
target for the rate period ending with FY06 has been to spend an
average of $139 million per year in expense funds on the fish and
wildlife program. Based on our past experiences with the
differences between the planning budget and actual spending, the
Council concluded that a start-of-year planning budget for expense
funding of that amount for FY06 is appropriate and will not result
in Bonneville spending more in FY06 than is consistent with meeting
this accrual target. If anything, it seems more likely
Bonneville will not spend as much in this rate period as originally
targeted. Bonneville representatives informed the Council that
any amounts not spent up to the target in this rate period will be
carried over and added to the amounts available for spending
on fish and wildlife in the next rate period. The Council
asked for your written confirmation of this understanding.
Principles governing these
project recommendations. The central principle the Council
has used to arrive at this set of projects has been to remain
consistent with the multi-year project recommendations that the
Council developed during the provincial review a few years ago. It was in this provincial review process that the
projects proposed for Bonneville funding received the review by the
Independent Scientific Review Panel, the public and the Council
required by Section 4(h)(10)(D) of the Northwest Power Act. These reviews and the basic set of resulting project recommendations
were intended to remain valid for the next few years as the Council,
the ISRP and others involved in project review focused on subbasin
planning and on adopting the subbasin plans into the program. The Council, working with Bonneville and CBFWA staffs, project
sponsors and others, have worked hard over the last months to
identify an appropriate set of projects for FY06 to reflect the
provincial review recommendations as evolved to this year, as well
as reasonable cost estimates for performing the scopes of work
recommended by the Council in the provincial review.
Two related governing principles
have been to hold most projects at level funding and not to
recommend any new projects or for an expansion of the scope of
existing projects into new work. The Council did make
exceptions in the application of these two principles, for reasons
and under certain conditions explained below.
Finally, the Council has been
adopting the subbasin plans into its program at precisely the same
time as it was reviewing the on-going projects for these FY06
recommendations. For this reason, the Council also requested a
threshold explanation from the project sponsors as to how projects
are consistent with subbasin plans and plan priorities, as well as a
clear and relatively detailed explanation of past and expected
accomplishments. The Council has been encouraged with the responses.
With the subbasin plan adoption now completed, the new project
review process for FY07 and beyond will include a new solicitation,
in-depth scientific and public review, and new multi-year Council
recommendations, all aimed at implementing the objectives,
strategies and priorities in the subbasin plans and a comprehensive
review of project consistency with the plans.
Overarching issues. As in every year, the Council's review of projects proposed for
funding in FY06 raised a small number of overarching policy issues. These issues included whether and how to address
concerns raised by the continuation of level funding for another
year; whether and how to incorporate the new projects proposed by
Bonneville to implement the federal action agencies? recently
adopted final Updated Proposed Action (UPA); how to respond to
requests for additional operation and maintenance funding for land
acquisition projects and to requests to fund certain recommended
habitat acquisitions out of the expense budget rather than the
capital budget; whether and how to close out a discrete set of
assessment, monitoring and evaluation projects; how to handle
projects that, from a review of the project responses, may need a
specifically focused Step or similar review before proceeding or
that raise an issue about a possible scope expansion; and so forth. For more detail on these, what these issues were and
how the Council worked through them, see the memoranda
prepared by the staff for the June, July and August Council meetings
(see 2006 budget page for links) and the
minutes of these meetings.
How the Council resolved these
issues is reflected in the projects and budgets recommended and,
where appropriate, in the comments in the table associated with
specific projects. In most cases, this is sufficient. For example, the comments in the budget tables identify those
projects for which the project response for FY06 raised the
possibility of a scope expansion that, if true, would not be
allowed, or that appear to require a review of some type before
proceeding. Working with the Council staff, Bonneville should
inquire further into these projects before contracting to determine
if the project is truly within one or the other of these categories
and, if so, to take or allow for the appropriate action.
For a few of these issues, the
Council offers the following further guidance:
-
UPA projects. The action agencies committed to what
is called the final Updated Proposed Action (UPA) as part of the
most recent Section 7 consultation under the Endangered Species Act
on the proposed operation of the Federal Columbia River Power System.
Bonneville proposed that to start a number of
activities to implement the UPA in FY06. The Council worked
with Bonneville to develop an appropriate list of UPA-related
projects and budgets, reflected in the attached tables. Some
of these are new projects, and some represent an expanded scope for
an existing project. These project recommendations are the
only exception in the Council's FY06 start-of-year planning to the
basic premise of not beginning new work in FY06. For that
reason, the Council included these projects in the planning budget only
under the condition that any new work derived from the UPA (whether
in a new project or an expanded scope for an existing project) first
undergo review by the ISRP and, subsequently, by the Council for a
specific recommendation before implementation. Also, some of
the projects are mere placeholders, such as the Columbia Cascade
habitat placeholder, and these will require much further definition
before they are ready for review.
-
O&M funding for wildlife land acquisitions. Budgets for those projects that maintain and protect land acquired
for wildlife habitat are based on the following principles:
Level funding applied to land acquisition O&M budgets (as to all
other projects), except in the case of new land acquisitions or
where there has been the adoption of a management plan since the
last budget recommendation. When new acquisitions have
occurred since the last budget recommendations, but no management
plan for the land exists, Bonneville should provide a consistent
base amount of operation and maintenance funding only, largely for
management planning and the most necessary maintenance. With
the adoption of a management plan, Bonneville should work with the
project sponsor to set O&M budgets that are relevant to the
tasks scheduled for implementation in the management plan, with
reference to the ?Guidelines for Enhancement, Operation, and
Maintenance Activities for Wildlife Mitigation Projects? adopted
by the wildlife managers in 1998. The amounts shown in the
budget table (largely derived from the sponsors? requests and
preliminary input from Bonneville) should be considered ceilings; it
may be possible to fund O&M for these projects consistent with
the principles expressed above for less than the proposed amount.
-
Funding projects to acquire habitat for fish out of the
expense budget. During the last provincial review
process, the Council recommended that Bonneville fund a set of
project proposed to acquire land to protect important habitat for
anadromous and resident fish. Bonneville recognizes the
importance of the projects, but has been unable to use its capital
funds for this purpose. The projects sponsors, with the
encouragement of Bonneville representatives, now propose to fund
acquisitions under these projects out of the expense budget in FY06.
The Council is willing to consider the concept of using
available funds in the expense budget to implement these projects in
FY06 but has requested defined, project specific budgets for
consideration. The project tables identify the five projects
involved, in the comments. But Bonneville and Council staff
and the project sponsors are still working to define precisely which
parcels may indeed be available in FY06 and at what specific budgets.
The Council staff will bring back to the Council for
review and possible recommendation specific proposed actions and
expense budgets for these projects. Bonneville should not use
its expense budget to acquire land under these projects if and until
the Council makes a recommendation to do so.
-
Projects coming to an end. The Council
identified a set of projects, mostly involving discrete assessment,
monitoring or evaluation activities, which should come to a
conclusion during FY05 or FY06. The Council staff worked with
Bonneville representatives to identify appropriate close-out budgets
in FY06 where necessary.
-
Recommended projects Bonneville has not funded after labeling
them low priority. The Council identified a small set
of projects in the area above Hells Canyon that the Council
recommended for funding during the provincial review, but which
Bonneville subsequently placed on a low-priority list and has
declined to fund, but which have not been closed out for other
reasons. The Council does not agree with Bonneville's action
and continues to recommend that these projects be funded. The
projects are included in the tables, along with recommended budgets
for those projects for which the project sponsors requested funding
during FY06.
Revised within-year process. The Council and Bonneville staff proposed revised procedures for
tracking what is being spent during the fiscal year and making
adjustments where necessary. The Council rejected one aspect
of the proposal ? the staff proposal to establish a monetary
threshold for within-year requests by project sponsors before these
requests would require Council scrutiny. Otherwise, the
Council approved the proposed revisions to the within-year process,
which is attached as revised under the title ?FY 2006 Budget
Tracking and Adjustment Process.?
Project performance audit pilot program. Finally, the Council approved in concept the idea
of recommending that Bonneville initiate in FY06 a pilot program
that subjects a certain number of projects to a performance audit. The Council directed the staff to develop the concept
into a proposal for the Council to consider at its September
meeting, the proposal to include a set of alternatives for how to
implement such a pilot program. The Council will be forwarding
to Bonneville a specific recommendation on this subject.
Please contact or
of my staff if you have questions or seek further information on
these recommendations. Please express our appreciation and
thanks to your staff for the congenial and productive way they
worked with the Council's staff to develop the project and budget
information and proposals for Council review.
Sincerely,
Doug Marker, Fish and Wildlife Division Director