June 15, 2001
Dear Mr. Cassidy:
This letter is in response to the Northwest Power Planning Council's (Council) request on March 14, 2001 for specific recommendations on elements of a mainstem plan to be adopted for the Columbia and Snake rivers as an amendment to the Council's 2000 Columbia River Basin Fish and Wildlife Program (Program). Washington Department of Fish and Wildlife (WDFW) is, at this time, providing you with recommendations on a number of key programmatic elements that we believe are critical to the success of a mainstem plan. The urgent need to respond to the challenges of this state's drought emergency and Bonneville Power Administration's (BPA) power emergency, as well as closing the state's biennial budget and still being within one of the longest legislative sessions ever has placed considerable time restraints on WDFW. I am unable at this point to be as specific as I would like. I surmise that most other fish and wildlife managers in the Columbia River Basin face similar time constraints. In light of that, I urge the Council to lengthen the time schedule for development of the mainstem plan and in particular the time frame for receiving specific recommendations with accompanying data and information.
At this point I can provide the council with several broad ecosystem objectives for the Columbia mainstem that the Council's Program must address and incorporate.
By its very nature, implementation of a detailed habitat driven program supported by a mainstem plan requires increased and extensive data coordination. The Council's Multi-Species Framework will not be a credible tool for analysis of mainstem actions without coordinated data inputs. We reiterate the Four Northwest Governors recommendation for a Coordinated Information System and suggest that efforts currently underway through the Regional Assessment Advisory Committee should help frame that need.
The Council should view the Biological Opinions (BiOps) from the National Marine Fisheries Service (NMFS) as the base for mainstem operations and hydrosystem configuration to address ESA listed fish. However, it remains the responsibility of the Council to provide additional actions to accommodate non-listed species and the broader mitigation objectives under the Power Act. Specifically, the mainstem plan must be inclusive of elements of the NMFS and U.S. Fish and Wildlife Service 2000 BiOps for the operation of the Federal Columbia River Power System and the draft Federal Salmon Recovery Strategy. Additional ESA and Federal Energy Regulatory Commission related processes in Washington State that must be integrated into the Council's efforts include the Draft Chelan/Douglas Public Utility District Habitat Conservation Plan, the Vernita Bar Agreement, and the Grant Public Utility District Spill Memorandum of Agreement.
The Council acknowledged in the 2000 amendments that curtailment of fish and wildlife operations during emergency situations should not be used in lieu of establishing an adequate and reliable power supply, but the BPA actions taken this year would seem to be at odds with the Council's statement. Energy needs of the region must be met by establishing an adequate, efficient, and reliable power supply that does not require any curtailment of important fish operations, i.e., one cannot run the river only for power. Therefore, the mainstem plan should not include the elements of the BiOp that allow the curtailment of measures critical for the survival of fish and wildlife simply for economic expediency.
The Council must help ensure that its Program's mainstem operations measures, and associated upper basin mitigation efforts, are not curtailed or set back due to the lack of necessary planning and capital investments in resources on the power side.
In addition, the Council needs to assess whether its Program has adequately addressed the hydropower impacts to wildlife and non-listed resident fish and has provided for species substitution in the blocked areas. The Council must provide for the establishment of performance measures for wildlife and non-listed resident fish in an appropriate manner; these performance measures should be developed cooperatively with the fish and wildlife managers. The region does need standards, as the Four Northwest Governors noted in their July 2000 recommendations, but it does not need a set of standards that are either unattainable or ill-advised through lack of local and regional involvement.
Adequate regional input and review must involve parties in addition to the fish and wildlife managers to assure that the product is accepted and can be implemented through a broad range of circumstances; the Council must incorporate the results of regional and local planning efforts in the Fish and Wildlife Plan. Three very important regional planning groups on Washington portions of the mainstem are the Lower Columbia River Estuary Program (LCREP), the Hanford Reach National Monument (HRNM) planning process, and the Lake Roosevelt Forum; all three have strong WDFW involvement and support. The Council should rely on the June 1999 Comprehensive Conservation and Management Plan from the LCREP as the foundation for the mainstem plan below Bonneville Dam. The LCREP includes state, tribal and local governments, as well as industry representatives and environmentalists in a major planning effort to preserve and enhance the estuary. The Council should not attempt to duplicate their efforts; instead it should incorporate them directly into the mainstem plan. The mainstem plan should recognize the existence of both the HRNM planning process as well as the Lake Roosevelt forum as venues for regional involvement and provide explicit mechanisms for incorporating recommendations that arise from those forums.
For the ongoing mainstem amendment revision for the Program, the Council must plan for and establish river operations and hydrosystem configurations for fish and wildlife as hard constraints on the power system. The power and fish crises this year have exposed glaring deficiencies in the region's efforts to restore and recover fish and wildlife in the Columbia River Basin. We appreciate the difficult challenges the Council faces in protecting, mitigating, and enhancing fish and wildlife in a manner that provides for their equitable treatment with the other uses of the hydropower system.
I also feel that the Council needs to address cumulative risks to salmon stocks. Accepting risks on a piece meal basis without knowledge of the total impact levels is simply not acceptable. Thus, I urge the Council to use the current crisis as a catalyst to bring about the major changes that are needed to meet the mandates of the Northwest Power Act, Endangered Species Act, Clean Water Act, and other applicable state and federal laws, and to recover and restore fish and wildlife in the Columbia River Basin.
Thank you for the opportunity to provide objectives for your mainstem plan amendment. I look forward to providing, under separate cover, our specific recommendations on matters critical for the recovery and sustainability of Columbia River Basin fish and wildlife populations by the end of July. We are hopeful you will accept this extension, based upon the extenuating circumstances mentioned in this letter. Please call me at (360) 902-2225 to confirm your approval of this extension.
Jeff P. Koenings, Ph.D.
cc: Mark Walker, NWPPC, Director of Public Affairs
Bob Nichols, Governor's Office
Brian Walsh, Stacey Horton, NWPPC, Washington Offices
Brian Allee, CBFWA
Don Sampson, CRITFC
Guy Norman, ODFW
WDFW Regional Directors