The summary materials submitted by CBFWA are an improvement over an earlier draft I saw some months ago. However, I don’t understand CBFWA’s reasoning for including salmon and steelhead biological objectives for each province and Subbasin in the plan. This information is already provided in the Subbasin/Recovery Plan and it would seem to be more appropriate to simply reference the Subbasin/Recovery plan, rather than replicate it in the basin plan. I say this for several reasons:

1. Lower Columbia and Gorge Province Biological goals are likely to change. The Lower Columbia ESU recovery plan for coho, Chinook, chum, and steelhead is not yet complete. The plan for the Washington portion of the ESU has been adopted by NOAA as an interim regional recovery plan for Chinook, chum, and steelhead. The Washington plan has also been adopted by the Council as the Subbasin plans for 8 subbasins. Oregon is working to complete planning efforts for its portion of the ESU. As we work with Oregon and NOAA to complete ESU plan, biological objectives for some populations are likely to change. These changes will be made to ensure that the final ESU plan goals meet NOAA’s viable salmonid population criteria. Referencing the recovery plans in the Council’s Fish and Wildlife program would avoid the necessity to frequently update the Council’s program to ensure consistency with the recovery plans as biological objectives evolve and/or are refined.

2. Summarizing biological objectives on the Province level can be misleading. For example, Lower Columbia Province biological objectives identified by CBFWA for Cowlitz Fall Chinook is a composite of the biological objectives of 4 separate populations. However, in order to meet the recovery criteria the biological objectives for each population must be met. Adult returns could exceed the composite objective of 6,900 without meeting the individual population recovery/biological goals. On the Subbasin level, the CBFWA information avoids this misleading presentation by showing the biological objectives for each of the four populations.

3. The limiting factor descriptions used by CBFWA are so general as to be of little or questionable value. For example, limiting factors listed by CBFWA for the Kalama are grazing, roads, diking, and agriculture. Grazing, diking, and agriculture are not significant limiting factors or threats in the Kalama Subbasin. Residential development and the effects of past forest practices are much more significant factors. Finally, without further evaluation, I can’t tell whether the “potential population response if [limiting factors] addressed” is consistent with the analysis in the Subbasin/recovery plan.

4. Strategies and measures are not consistent with Subbasin/Recovery Plan. The strategies listed in the CBFWA material are comparable in some instances to those of the Subbasin/Recovery Plan, but there are significant gaps and no priorities are provided. Based on a brief review, the measures are more problematic. For example, measures for the Kalama Subbasin include removal of dikes, agricultural water conservation, and improved irrigation conveyance and efficiency, none of which are particularly relevant to actual conditions in the Subbasin.

In summary, attempting to summarize biological objectives, limiting factors and threats, and strategies and measures is a difficult and complex undertaking and I’m not sure of the value it adds over simply referencing and relying on the Subbasin/Recovery Plan. Summarizing across the all provinces and subbasins can obfuscate important distinctions within and across provinces and subbasins and is confounded by the different or unique planning, analytical and policy approaches employed in the provinces and subbasins. In part this stems from the need to standardize terminology across the provinces and subbasins. But, how standardized terms are applied to describing objectives and conditions within a province or Subbasin is also significant issue. Finally, summarizing data from the Subbasin/Recovery Plan also adds an additional administrative burden of regularly reconciling the Basin program and the Subbasin/Recovery Plan to ensure consistency.

A detailed review of the CBFWA summary information will require a significant effort. If the Council feels that including such summary level information in the Basin program is important, we are willing to work with the Council and CBFWA to ensure that the information included for the Washington portions of the Lower Columbia and Gorge provinces accurately reflect and are consistent with the Subbasin/Recovery Plan.

Jeff Breckel
Lower Columbia Fish Recovery Board

We encourage the Northwest Power and Conservation Council (Council) to take the CBFWA recommendations into consideration when they develop the draft 2008 Fish and Wildlife Program. Thank you for the opportunity to provide our input into the program development process. We look forward to working with the Council as they amend the Columbia Basin Fish and Wildlife Program in 2008.

Should you have further questions, please contact Dan Diggs at 503-872-2217.

Sincerely,

David Wesley, Acting Regional Director

During the agencies and Tribes’ review it was noted that some of the recommendations provided by entities other than the CBFWA Members were inconsistent with the recommendations of the eleven tribes, four state, and two federal fish and wildlife managers. Of particular concern were recommendations by the Bonneville Power Administration (BPA) for amending the resident fish and wildlife portions of the Program. The attached table displays the inconsistency in recommendations by summarizing or providing excerpts from the BPA and CBFWA amendments and offering the state and federal fish and wildlife management agencies’ and Tribes’ recommended resolution to the inconsistencies and, in a few cases, identifying where the amendments are consistent (see Attachments 1 and II). The Members of CBFWA expect the Council to provide due weight to the comments and recommendations of the fish and wildlife managers in the Columbia River Basin, regardless of whether those recommendations are specifically mentioned in the attached table.

In our review, we found no inconsistencies between the recommendations provided by the individual agencies and Tribes of CBFWA and the collective recommendations provided through CBFWA. We also note that the collection of recommendations submitted to the Council by the agencies and Tribes and others provides much of the substantive material necessary to develop a comprehensive Program amendment including multi-year work plans, consistent with the subbasin management plans called for in the 2000 Program (Page 41). We encourage you continue the effort that BPA initiated in the development of the Columbia River Basin Fish Accords, by developing multi-year implementation work plans for the entire geographic scope of the Program. The agencies and Tribes have provided most of the information necessary to support this effort and where additional information is required we stand ready to assist you.

Having work plans to accompany a deliberative comprehensive adaptive management program represents sound resource management. The Council and its partners have completed significant assessment and planning activities over the past seven years and it is time to focus the Program, and BPA funding, in implementing on-the-ground actions. Several agencies and tribes have submitted project and Program specific recommendations that would support development of work plans consistent with the adaptive management framework we submitted on April 4. Where specific actions have not been identified, the agencies and Tribes are prepared to work with the Council to develop appropriate subbasin and systemwide work plans for inclusion in the amended 2008 Fish and Wildlife Program.

In addition to reviewing the suite of recommendations submitted to the Council by the agencies and Tribes and others, we have continued the development of two key elements of the adaptive management framework submitted on April 4. First, considerable time has been spent streamlining the resident fish portion of our recommendations (Section 4) by eliminating redundancies and aligning resident fish populations by common limiting factors and strategies. This has reduced the resident fish section by nearly 100 pages and we are including the revised Section 4 in this transmittal (See Attachment III).

The anadromous fish managers have initiated a comprehensive effort to complete Table 2.1 of our April 4 recommendations. The intent of Table 2.1 is to provide an association between the individual subbasin anadromous fish objectives (natural spawners, hatchery brood stock, harvest, etc.) and the basinwide anadromous fish goals (e.g., halt declining trends in populations, restore widest possible set of healthy populations, increase runs to 5 million anadromous salmonids passing Bonneville Dam, support harvest, etc.). In our efforts to document these associations we found several important issues that deserve additional dialogue and investigation. The anadromous fish managers will continue their work to express the subbasin and population scale objectives in a manner that supports a long term monitoring and reporting program. We invite the Council to participate in this discussion and will be providing additional information during the public comment period following the release of the draft Program amendment.

Sincerely,

Larry Peterman, Chairman
Columbia Basin Fish and Wildlife Authority

Enclosures: 3
1) Attachment I: Wildlife Table
2) Attachment II: Resident Fish Table
3) Attachment III: Resident Fish Section 4 Condensed

cc:
NPCC Members and Staff
CBFWA Members