June 15, 2001
Dear Mr. Crow:
This is in response to your request for Columbia and Snake Rivers' mainstem plan recommendations for amending the Council's Columbia River Basin Fish and Wildlife Program. These comments are also provided on behalf of the Bureau of Reclamation and in coordination with the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS). I understand the Bonneville Power Administration is providing a separate comment letter.
As you know, the Corps of Engineers, Bureau of Reclamation and Bonneville Power Administration have consulted with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service under Section 7 of the Endangered Species Act regarding operation of dams and reservoirs which are part of the Federal Columbia River Power System (FCRPS). The NMFS and FWS issued Biological Opinions on operation of the FCRPS on December 21 and December 20, 2000, respectively. These opinions contain "reasonable and prudent" alternatives which identify measures and actions which are necessary for the Corps, Bonneville Power Administration, and Bureau of Reclamation ("action agencies") to avoid jeopardizing listed anadromous and resident fish in the Columbia River. The NMFS opinion also requires the action agencies to prepare 5-year and 1-year implementation plans annually.
The action agencies are currently preparing the initial 5-year implementation plan which will identify mainstem and tributary goals, strategies and actions, and related performance standards and research, monitoring and evaluation, for assisting recovery of listed fish. It will contain actions and priorities over the next 5 years for mainstem hydro operations, configuration, and habitat improvements, as well as "offsite" activities in habitat, harvest and hatcheries programs. The 1-year plan for FY 2002 will identify specific projects and measures with tasks and schedules. Both plans will be made available for state, tribal and public review before being made final.
In that our mainstem program is established in the biological opinions and in view of our developing implementation plans, at this time we do not offer comprehensive comments to the Council on potential amendments to the Fish and Wildlife Program. We will however, share with you our draft plans in the near future and intend to work with the Council and others regarding mainstem actions for non-listed species. One specific comment is that we support the NMFS recommendation to include the Columbia River plume in the estuary province. Also, we may offer additional specific comments and will be available for discussion regarding recommendations made by others to your program if those recommendations relate to the programs and activities we plan to carry out in response to the biological opinions.
I am forwarding a copy of this letter to the Fish and Wildlife Service, the National Marine Fisheries Service, the Bureau of Reclamation and the Bonneville Power Administration. Thank you for the opportunity to comment and we look forward to continued coordination of our activities with the Council's program and processes.
Michael B. White
Director, Civil Works and Management