Fish & wildlife Subbasin planning Guides and forms ESA

Willamette/Lower Columbia ESA Executive Committee
Questions regarding Sufficiency Guidelines for Recovery Plans

February 28, 2003

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The Willamette/Lower Columbia ESA Executive Committee (Ex Com) has asked the National Marine Fisheries Service (NOAA Fisheries) to address the following questions related to how NOAA Fisheries will assess the adequacy of ESA recovery plans:

1. What sufficiency guidelines will NOAA Fisheries use to evaluate recovery plans in relation to both threats/limiting factors and biological recovery goals?
2. What analytical tools will NOAA Fisheries use to evaluate the sufficiency of recovery actions and plans?
3. With what degree of specificity do recovery actions need to be identified?
4. What is the relationship between NOAA Fisheries? sufficiency guidelines and the draft RTT population viability criteria?
5. Will NOAA Fisheries evaluate recovery plan actions as they relate to biological criteria or to threats analyses?  What role will the TRTs have in evaluation?
6. How will NOAA Fisheries evaluate the sufficiency of individual recovery plan components in the absence of a full ESU recovery plan? Will the criteria for approving an individual recovery plan component be different if other entities within an ESU have not developed recovery plans?
7. How will NOAA Fisheries aggregate subbasin/local plans to the ESU scale? At what point in the process will this be done?  What analytical framework will be used for assessing the adequacy of the ESU plan?
8. How will NOAA Fisheries communicate sufficiency guidelines to local planners?
9. What if an Ex Com member doesn't endorse NOAA Fisheries? sufficiency guidelines or the viability criteria?
10. How will PFC for site compliance relate to ESU criteria?
11. How and by whom does NOAA Fisheries anticipate the adequacy of existing regulatory and other programs will be evaluated relative to sufficiency of recovery plans and relative to de-listing?
12. Does NOAA Fisheries anticipate reviewing individual subbasin plans?  If so, how does that review process intersect with NPPC review, including review by the ISRP and ISAB?  What is the timing of that review process and who will conduct it (e.g., TRTs, NWFSC, other science groups, etc.)?
13. ESA recovery plans are supposed to include implementation plans that express the timing and cost of recovery actions, will these implementation plans also obligate entities to implementing specific actions?
14. How will a recovery plan affect section 7 consultations, section 10 permits and 4(d) rule implementation?

The responses below are preliminary and intended to improve understanding of these issues and stimulate discussion.  We hope to continue to develop our thinking on these issues through the collaborative recovery planning process and continued discussion with the Ex Com.

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