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Draft Mainstem Amendments to the Columbia Basin Fish & Wildlife
Program
October 2002 |
document 2002-16
Links:
Letter inviting public comment
October 28, 2002
Dear Interested Parties:
The Council invites your review and comment on
the Council's recently approved draft amendments to its Columbia River
Basin Fish and Wildlife Program. These draft amendments would add a
?mainstem plan? to the general provisions of the Council's 2000 Fish
and Wildlife Program, as the next step in the Council's comprehensive
revision of its Fish and Wildlife Program.
In March 2001 the Council initiated the process
for amending the mainstem plan into the program. The Council
described its expectations for the elements of the mainstem plan in the
2000 Fish and Wildlife Program, in the Basinwide Hydrosystem Strategies
and the Schedule for Further Rulemakings. The mainstem plan is to
contain the specific objectives and measures (or strategies) that the
program calls on the federal operating agencies and others to implement in
the mainstem Columbia and Snake rivers, including especially the
operations of the hydrosystem, to protect, mitigate and enhance fish and
wildlife affected by the development and operation of the hydroelectric
facilities, while assuring the region an adequate, efficient, economical
and reliable power supply. The draft mainstem plan includes
objectives and strategies relating to, among other matters:
- the protection and enhancement of mainstem
habitat, including spawning, rearing, resting and migration areas for
salmon and steelhead and resident salmonids and other fish;
- system water management;
- passage spill at mainstem dams;
- adult and juvenile passage modifications at
mainstem dams;
- juvenile fish transportation;
- adult survival during upstream migration
through the mainstem;
- reservoir elevations and operational
requirements to protect resident fish and wildlife;
- water quality conditions; and
- research, monitoring, evaluation and in-season
decisionmaking.
Amendments to the fish and wildlife program must
also account for the impact of fish and wildlife operations on the region's
power supply. To that end, the Council has included with the draft
amendments a paper analyzing the effects of proposed fish and wildlife
operations on the adequacy, efficiency, economics and reliability of the
power supply. The Council also is seeking public comments on the
paper.
In preparing this draft mainstem plan, the
Council solicited recommendations
from the region's state and federal fish and wildlife agencies, Indian
tribes, and others, as required by the Northwest Power Act. The
Council prepared this draft after reviewing the recommendations,
supporting information submitted with the recommendations, and comments
received on the recommendations. The Council is also inviting review
and additional comments on the recommendations, including whether there
are objectives or measures in the recommendations that the Council should
have included in the final mainstem amendments but did not.
Specific issues for comment
Reviewers are invited to comment on any and all
provisions in the draft mainstem amendments. But the Council
particularly seeks comment on a number of difficult issues reflected in
the draft amendments, including:
- Changes in storage reservoir operations, in
general. The Council approved for comment proposed changes
in the way federal storage reservoirs are currently operated in the
Columbia River basin. The Council's purpose is to improve
habitat conditions for all the fish that live in and migrate through
the Columbia mainstem, not just listed anadromous fish, while also
providing more flexibility in power generation, especially in the
winter, when compared to operations under the National Marine
Fisheries Service's 2000 Biological Opinion.
In many years these operations would result in
reductions in flow through the lower Columbia hydrosystem in both spring
and summer, but it is the Council's hypothesis that these flow
reductions would be statistically insignificant and not adversely affect
the survival of listed anadromous fish migrating through the system at
these times, while improving the biological benefits for listed and
non-listed resident fish in and around storage reservoirs. The
Council requests comment in general and scientific and technical
assistance in particular concerning (a) the extent of the biological
benefits to fish species and populations from these changes; (b) whether
and to what extent anadromous fish will be adversely affected by these
flow changes; and (c) whether and to what extent the region's power
system will benefit from these changes.
For more information on the proposed operations,
and the possible hydrological, power supply and biological effects of
these changes, please review the 'strategies? for ?Water Management?
in the draft amendments; the table summarizing the mainstem operations
attached to this notice; the power supply paper included with the draft
amendments; power system and biological effects analyses posted on the
Council's website; and the recommendations and supporting information
originally received by the Council.
- Changes in storage reservoir operations ?
alternative that preserves status quo operations while evaluations are
pending. The Council considered an alternative proposal that
questioned the biological benefits of the full extent of current
reservoir and flow operations for listed anadromous fish, when
compared to the benefits to other species and populations and to the
power system that might result from changes in those operations.
That alternative then called for the Council to consult with
Bonneville, the National Marine Fisheries Service, U.S. Fish and
Wildlife Service, fish and wildlife managers, tribes and other
entities to determine whether and how to conduct a comprehensive flow
target and flow augmentation evaluation, with the goal of providing
revised recommendations to the federal agencies for continuing or
modifying the current system water management program. But that
alternative did not call for any changes in the status quo of
operations while the evaluation takes place. The Council seeks
comments on whether this alternative should be preferred over the
alternative chosen for the draft amendments, which does call for
changes in operations.
- Changes in storage reservoir operations ?
elimination of April 10 flood control elevation target. One
of the Biological Opinion operations that the Council proposes to
change is to eliminate the requirement that the storage reservoirs
(Libby, Hungry Horse, Grand Coulee and Dworshak dams) be operated to
assure a high probability that reservoir levels are near or at the
upper flood control rule curve by April 10. The purpose, in the
Biological Opinion, is to keep the reservoirs as full as possible
consistent with flood control protection coming out of the winter, so
that less of the spring run-off is needed to fill the reservoirs and
more of it may be passed through to the lower river.
The Council proposes to remove the April 10
target, while still requiring operators, as a highest priority, to assure
a 95% probability of refill of the reservoirs by the end of June.
This would allow the operators, in many years, to draft the reservoirs
somewhat deeper in winter, to provide additional flexibility for power
generation at peak winter times as needed. This could reduce spring
flows to a certain extent in certain years, as more of the spring run-off
would be used to fill the drafts from the reservoirs. But it is the
Council's hypothesis that this reduction in spring flows would be muted
by the 95% priority refill requirement at the end of June (that is, the
reservoirs could never be drafted too deep in winter or that would put at
risk end-of-June refill), and thus that the reductions in spring flows
would be relatively minor and not have significant adverse effects on
survival of spring migrating anadromous fish.
The Council is seeking comment on this
hypothesis: Is the Council correct in its understanding of the
hydrological and power system effects of removing this operational
constraint? Would the resulting spring flow reductions adversely
affect survival of spring migrants? Would the elimination of the
April 10 flood control target cause any other adverse biological effects,
including an adverse effect on fish populations in the reservoirs, such as
in Grand Coulee, or on estuary habitat? Does removal of the April 10
flood control target provide additional flexibility for the power system,
and, if so, how much?
- Changes in storage reservoir operations ?
summer flows. Another change in operations proposed by the
Council concerns storage reservoir operations in summer, based in
large part on the recommendations and comments from state fish and
wildlife agencies and tribes with an interest in the fish populations
in and below those reservoirs. Under the Biological Opinion the
reservoirs are drafted to certain levels by the end of August in an
attempt to meet summer flow targets at McNary and Lower Granite dams,
targets that are rarely if ever met.
The operations, in the Council's opinion, have
an adverse effect on the conditions for fish in the reservoirs and in the
rivers immediately below the reservoirs, due both to the depth of the
summer drafts and to the fluctuating manner in which the water is
released. The Council proposes to change the operations to restrict
the depths of the drafts in most or many years, to stretch the period of
drafting to these revised draft limits to the end of September (at Libby,
Hungry Horse and Dworshak dams), and to require that the water be released
in a stable way that minimizes or eliminates fluctuations. One other
result of these changes would be to reduce flows in the lower river
minimally in July and to a somewhat greater degree in August and to
increase flows in September.
The Council seeks comment on the Council's
hypothesis that these changes will have significant biological benefits to
the fish species that live in and below these reservoirs; the increased
flows in September will benefit returning adult anadromous fish; and the
decreases in flows in August are not of such an extent as to have
significant adverse effects on out-migrating juvenile anadromous fish.
- Changes in storage reservoir operations ?
alternative that calls for allocating more water to meeting or
exceeding Biological Opinion flow targets. The Council also
considered an alternative based on recommendations from state fish and
wildlife agencies and tribes that called for the federal agencies to
allocate more of the water in the system to meeting or exceeding the
spring and summer flow objectives in the Biological Opinion. The
Council chose a different path in the draft amendments, but seeks
comment on the biological and power system benefits and costs of this
alternative approach.
- Changes in storage reservoir operations ?
relation to late fall/winter flows for chum and chinook spawning below
Bonneville Dam. The Biological Opinion includes late fall
and winter flow targets intended to benefit listed chum and chinook
spawning below Bonneville Dam. The Council seeks comment on
whether the revised reservoir operations proposed in the draft
amendments would interfere with this winter operation and, if so, the
extent of the effects. The Council considered an alternative
proposal that would have increased the flow targets for chum and
chinook spawning below Bonneville Dam in order to increase and protect
the amount of habitat available for spawning. The Council also
seeks comment on the benefits and drawbacks of this proposal.
- Spill operations ? dam-specific spill
level studies. With regard to current requirements for
spilling water at mainstem dams for fish passage, the draft amendments
are premised upon a hypothesis that the level of spill at each project
that is optimum for fish survival may not be the maximum level
of spill now called for at each project (that is, spill up to 120%
total dissolved gas supersaturation). And if spill can be
reduced at one or more projects without adverse biological effects,
the region will also benefit from increased power generation.
Thus, in the draft amendments the Council calls
for comprehensive spill survival studies to begin immediately, and the
Council intends to recommend specific spill levels at individual projects
at the conclusion of these studies. In the comments, the Council
requests assistance in designing and implementing the dam-specific spill
survival studies. While the spill evaluation is pending, status quo
spill operations called for in the Biological Opinions should continue,
although the Council did propose that the operating agencies make a
greater effort not to exceed the 120% total dissolved gas level whenever
possible.
- Alternative spill operations. The
Council considered an alternative that would have called for the
operating agencies, in the interim pending the completion of the spill
evaluations, to reduce spill by not allowing spill that
resulted in greater than 115% total dissolved gas in the river, except
during certain spill evaluation tests. The Council requests
comment on that particular alternative. The Council also
considered an alternative that would have increased spill above
what is called for in the Biological Opinions by implementing 24-hour
spill at Lower Granite, Lower Monumental, McNary and John Day
dams. The Council also requests comment on that alternative.
- Juvenile fish transportation. The
draft amendments endorse the strategy of ?spread the risk,? that
is, to allow part of the juvenile salmon migration to migrate inriver
and part to be transported, until it is determined whether migration
inriver or transportation provides the best levels of survival.
The Council is seeking comment as to whether this has already been
determined under certain circumstances and if so, where. For
example, does transportation in the Snake River under low flow
conditions provide significantly greater levels of survival than
inriver migration?
- Smolt-to-adult survival rates.
The Council received recommendations to adopt as a program objective
achieving smolt-to-adult survival rates (SARs) in the 2-6% range, with
a minimum of 2% and an average of 4%, for listed Snake River and upper
Columbia salmon and steelhead. The draft amendments describe
these as ?interim objectives? while the Council consults with
state and federal fish and wildlife agencies and tribes, the
Independent Scientific Advisory Board and the federal operating
agencies to evaluate the scientific soundness and achievability of
these SARs. The Council seeks comment as whether it makes sense
to adopt these objectives even as ?interim? in the mainstem plan,
especially as to whether mainstem actions could have any relation to
achieving survival rates in the higher parts of this range. Are
SARs the right kind of objectives for the program, or are there better
tools to use? Should the Council adopt instead (or in addition)
objectives for increases in the productivity of specific populations,
such as are central to the National Marine Fisheries Service's 2000
Biological Opinion for the listed populations?
- Biological Objectives for Environmental
Characteristics, Appendix D to the 2000 Fish and Wildlife Program.
In the 2000 Fish and Wildlife Program, the Council stated that ?biological
objectives? describe the physical and biological changes needed to
achieve the program's vision, and that biological objectives have
two components: (a) biological performance objectives, which describe
the response of populations to habitat conditions in terms of
capacity, abundance, productivity and life history diversity, and (b)
environmental characteristics objectives, which describe the
environmental conditions or changes sought to achieve the desired
population characteristics. The Council then adopted basinwide
biological objectives for population performance (one half of
biological objectives) as part of the main text of the 2000 program.
The Council also developed a provisional set of basinwide
biological objectives for environmental characteristics, drawn from
the 2000 program recommendations and from the relevant scientific
literature, and then attached those to the 2000 program as Appendix
D. The Council then stated that it would ask the Independent
Scientific Advisory Board to review these provisional basin-level
environmental characteristics, asking the ISAB for its view of the
scientific soundness and basinwide applicability of the environmental
characteristics; their utility for further defining biological objectives
at lesser levels of the program, such as in the subbasin and mainstem
plans; and the applicability of these objectives in the most altered areas
of the basin, the blocked areas. The Council said it would then make
the ISAB's report publicly available and seek comment from interested
parties, and then consider the report and comments and decide whether to
confirm or revise these basin level objectives for environmental
characteristics for purposes of providing guidance for subbasin level
planning and further program amendments.
The Council did obtain the views of the
Independent Scientific Advisory Board (see report)
on these provisional objectives, as well as the other biological
objectives (overarching and population performance objectives) in the 2000
Fish and Wildlife Program. The Council has not yet sought the views and
comments of interested parties on the ISAB's report. The Council
has now included biological objectives and strategies in the draft
mainstem amendments that are derived in part from the provisional
objectives for environmental characteristics in Appendix D, as well as
from provisions in the main text of the 2000 Program and from
recommendations. See especially the biological objectives for
mainstem habitat conditions and the first set of water management
strategies in the draft mainstem amendments.
In reviewing and commenting on these draft
mainstem objectives and strategies, the public is invited and encouraged
to review Appendix D to the 2000 program and the ISAB's report on the
biological objectives in the 2000 program. The Council is seeking
comment on the scientific soundness of the provisional basinwide
objectives for environmental characteristics in Appendix D and the
soundness of the proposed objectives in the mainstem plan that are based
in part on what is in that appendix.
- Criteria and procedures for emergency
operations. In 2001 the region suffered through a serious
drought and accompanying power system emergency, which for a number of
reasons resulted in the federal agencies being forced to curtail
regional load and reduce system operations intended to benefit of fish
and wildlife in order to maintain the reliability of the region's
power system. The draft analysis of the adequacy, efficiency,
economics and reliability of the region's power supply that
accompanies the draft mainstem amendments includes consideration of
the current status of the region's power system. The Council's
draft conclusion is that the region's power system should be
adequate and reliable for the next few years, due to power supply,
demand and loss of load developments that have occurred since early
2001, and that the objectives and measures to protect, mitigate and
enhance fish and wildlife included in this draft mainstem plan will
not affect that conclusion. The analysis also concludes,
however, that the region faces the possibility in later years of
spiraling back into the power supply problems seen in 2001, unless
measures are taken to ensure that new resources are added to the
regional power supply in a more certain fashion than now seems
likely. The analysis suggests possible actions by the federal
agencies and by others in the region that will ensure that the federal
system is better able to provide the specified operations for fish and
wildlife and meet appropriate load demands in at least most if not all
low-water years. The Council has begun the process of reviewing
and revising its 20-year power plan as called for by the Northwest
Power Act. The power plan will address in more detail the region's
power supply and reliability issues.
The Council received recommendations that it
adopt, as part of the mainstem amendments, criteria and procedures for
declaring a power system emergency in the future that could lead to
reducing or curtailing operations for fish. For the reasons stated
above, the Council intends to address additional power resources and power
system emergency issues as part of the revision of its power plan.
Thus the draft mainstem amendments do not contain provisions for when and
how it would be permissible to declare a power system emergency and reduce
or eliminate operations for fish. The Council seeks comment on
whether this is the right approach to considering the additional power
supply and power system emergency matters.
Sincerely,
Frank L. Cassidy, Jr.
Chair
read full Draft Amendments report >
(250k PDF)
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