June 15, 2001
Dear Mr. Cassidy:
Thank you for providing the opportunity to make recommendations to the Council regarding the mainstem Columbia and Snake rivers. Beginning with the early programs, the Council has created new frames of reference for Federal Columbia River Power System (FCRPS) operations and fish and wildlife mitigation through innovative measures. Today, almost two decades later, the region has built out from those early beginnings to a series of biological opinions, and soon implementation plans, that embrace and enlarge the mainstem measures from past programs. We commend this and previous Councils for their efforts in this regard.
Compared to 1982, and the creation of the water budget, we now have a much more regulated FCRPS relative to fish and wildlife protection and more extensive mitigation under the Northwest Power Act and recovery processes under the Endangered Species Act (ESA). Because of the increased complexity and diversity of mandates between the two statutes, the Bonneville Power Administration (Bonneville) believes there needs to be considerable coordination and integration. We have an opportunity now, as the mainstem rulemaking is underway and the Action Agencies are working to finalize the initial one and five-year implementation plans, to make a more deliberate and complete merging of Bonneville?s obligations under the Northwest Power Act and those under the ESA into a Unified Plan.
Bonneville hopes that as this rulemaking proceeds we can work together to unify these efforts. Our initial five-year Implementation Plan is currently undergoing agency review. We expect to provide copies for regional discussion by the end of June, with the final plan available in September.
Overall, Bonneville believes there should be few conflicts between the mainstem actions called for in the National Marine Fisheries Service (NMFS) and Fish and Wildlife Service (FWS) biological opinions (BOs) and the objectives and measures that the Council may consider. The actions we plan to implement under the BOs for listed native fish will also benefit most other native species in the mainstem, from bald eagles to cutthroat trout. With this rulemaking focusing on the similarities between the program and the BOs, we anticipate few if any new measures will be necessary for Bonneville to fulfill its complementary fish and wildlife obligations.
Enclosed is a document (Enclosure 1, see 10kb Acrobat file) that illustrates this point by showing the extensive overlapping between actions called for in the biological opinions and the primary strategies outlined in the 2000 Program Amendments starting in section III.D.6. This overlap of actions shows the strong foundation we already have for completing a Unified Plan and our Implementation Plan. Please note that we also wish to incorporate by reference the NMFS and FWS BOs for the record. They provide the basis for the implementation plans and Bonneville?s recommendations for this rulemaking.
A second enclosure (Enclosure 2, see 30kb Acrobat file) discusses a number of issues that Bonneville believes should be addressed in the mainstem rules and a number of topics specifically requested by the Council. Many of these issues go to the crux of sensitive regional debates. An underlying theme in this enclosure is that some of the goals and biological objectives of the program need to be clearer and more specific, especially as applied to the mainstem. For instance, the overall vision of the program calls for "protecting and restoring the natural ecological functions, habitats, and biological diversity" of the Columbia River Basin. While we agree with this vision as a broad-scale, long-term goal, it offers little in the form of concrete objectives applicable within a practical planning horizon. We ask that the Council consider setting tangible targets, such as improvements in juvenile migration survival, against which priorities can be established and progress can be measured in the near term, given the presence of the hydrosystem and its feasible modification. Thus, the challenge for achieving the program vision of using natural ecological functions, where feasible, is determining how to articulate those functions in a highly regulated mainstem and how to use those articulations in developing quantitative biological goals for the mainstem. It is critically important that the Program?s mainstem amendment provide clarity on how this vision can be achieved in light of the increasing regional population and societal demands and their impacts on natural resources.
In addition to this question regarding the application of the vision to the mainstem, other issues discussed in the final enclosure include the need to have power impacts discussed in greater detail when alternative means of achieving a biological goal are addressed; acknowledging a place and time for emergency operations; and coordination of RM&E so the region has one set of protocols for both mitigation and recovery efforts.
Thank you for this opportunity to make these recommendations. We anticipate that we will provide more specific input as this rulemaking progresses, and look forward to the dialogue of this rulemaking. If you need further documentation or explanation, please do not hesitate to contact my staff or me.
Robert J. Austin
Deputy Director for Fish and Wildlife
Mr. Rob Walton, Public Power Council
Dr. Brian Allee, Columbia Basin Fish and Wildlife Authority
Mr. John Shurts, Northwest Power Planning Council
Federal Caucus Agencies