Dear Mr. Walker:

The Confederated Tribes of the Colville Indian Reservation (Colville Tribes) is pleased to provide the following recommendations for the development of a mainstem plan for the Columbia and Snake rivers, which will be adopted as an amendment to the NWPPC?s Columbia River Basin Fish and Wildlife Program. These recommendations, developed by the Colville Tribes, are based on several assumptions:

• The purpose of the Program is to protect, mitigate, and enhance fish and wildlife affected by the federal hydropower system.
• The current mainstem program activities should be retained in the new program until amended by the mainstem plan.
• The amended mainstem plan should delineate the decisions required, the process and criteria by which the decisions should be made, and the roles of those affected by the decisions.

The Colville Tribe?s recommendations for the mainstem plan include the following:

• The Mainstem Plan should have an overall goal such as that listed below:

Regional Goal for the Mainstem Plan

A functioning Columbia Basin mainstem, one that supports both human settlement (support tribal and non-tribal harvest and cultural and economic practices) and the long-term sustainability of native fish and wildlife species in native habitats where possible, while recognizing that where impacts have irrevocably changed the ecosystem, we must protect and enhance the habitat and species assemblages that remain. To implement this goal, the Plan will deal with the Columbia Basin mainstem as a system; will protect, mitigate and enhance fish and wildlife while assuring an adequate, efficient, economical and reliable power supply; and will be consistent with the activities of the fish and wildlife agencies and tribes. Implementation will fulfill the nation?s and the region?s obligations under treaties and executive orders with Northwest Indian tribes, treaties with Canada, and applicable resource protection, restoration and enhancement statutes and regulations.

• The Colville Tribes recommend the plan include as a priority, a measure that investigates the feasibility of restoring anadromous fish in the blocked areas, especially above Chief Joseph and Grand Coulee Dams.

In 1939 Grand Coulee Dam was completed, blocking all anadromous fish migrations. Subsequently, in 1958, Chief Joseph Dam blocked upstream anadromous migrations another 50 miles downstream. The construction of Chief Joseph and Grand Coulee Dams blocked anadromous and resident fish migration to the Upper Columbia mainstem. These dams were not built with fish ladders or other devices to allow fish migration upstream. As a result, the Upper Columbia mainstem is called the "blocked area".

Prior to hydropower development, the Upper Columbia areas supported a large diverse fish population, which included eleven anadromous salmonid stocks. The construction of Chief Joseph and Grand Coulee Dams caused the complete extirpation of those eleven anadromous fish stocks, reducing the native salmonid species assemblage by approximately 64 percent. The loss of salmon irrevocably altered the ecosystem and forever changed the social ?economic systems of those inhabiting the blocked area. The Native American culture, religion and their livelihood were dependent upon the once abundant salmon.

The following anadromous fish strategies should be included as part of this recommendation:

1. Investigate the feasibility of providing anadromous fish passage (adult and juvenile) over Chief Joseph and Grand Coulee dams.
2. Survey and estimate anadromous salmonid production from the mainstem of the Columbia River between Chief Joseph and Grand Coulee Dam and upriver of Grand Coulee Dam.
3. Implement preferred alternatives based upon results of strategies 1 and 2.
4. Develop water management plans (releases), which are coordinated with juvenile outmigrant survival.
5. Use hatcheries, with an emphasis on native stocks, employing the most innovative fish culture techniques to produce fish with similar behavior and instincts of wild fish.
6. Utilize native fish, where possible, to reestablish anadromous fish populations into their historical range.

• The Colville Tribes recommend the plan investigate measures to improve mainstem spawning and rearing habitat conditions throughout the Columbia River, especially in the tailrace of Chief Joseph Dam.
   
• The plan should include a measure to review the current flood control program to determine if flood control rule curves could be relaxed in order to provide additional water for upriver storage reservoirs. This action would help stabilize reservoir elevations, increase water and nutrient retention times, thus improving storage reservoir productivity which would benefit resident fish resources. This action would also provide additional water, which could be used to increase flows for reducing smolt travel time, and improve the survival of juvenile outmigrants.
   
• The Colville Tribes recommend the plan include a measure to improve water quality in the Upper Columbia River mainstem. Both temperature and total dissolved gas concentrations exceed acceptable water quality standards. While these water quality issues are being addressed to some degree in the upper basin, more focus and effort needs to be exerted in the upper river basin. The resident fish resources of Lake Roosevelt are severely impacted during normal to above normal water years by high total dissolved gas levels. These TDG levels violate both State and Tribal Water Quality Standards. They also exacerbate TDG levels downstream and affect the ability of several mainstem hydro-projects from providing spill levels necessary to meet their performance standards for juvenile fish passage survival.
   
• The extirpation of anadromous fish resources from the Colville Reservation resulting from the development of the Federal Hydro-system substantially reduced fishing opportunities and subsistence harvest for the Colville Tribes. Our culture, religion and way-of -life were forever changed. Biological and environmental changes also occurred on the Colville Reservation and can be directly linked to the extirpation of the anadromous fish resource. The nutrient component derived from the anadromous fish component was lost and undoubtedly interrupted the nutrient cycle important to remaining resident fish populations, particularly in locations where anadromous and resident fish co-existed. Environmental conditions of interior waters of the Reservation not associated with the anadromous fish resource were also impacted due to the elimination of the anadromous fish. The reduction and eventual extirpation of anadromous fish forced the native cultures in the affected area to seek alternative resources to persist, largely because anadromous fish no longer provided the principle means of existence. Land-use activities such as agriculture, timber harvest, mining and live-stock grazing were and continue to be important means of existence for Colville people and surrounding communities, unfortunately these activities have degraded the historical resident fish habitat and capacity to provide subsistence opportunities. Finally, the direct inundation of the upper Columbia River drastically altered 190 mile of fluvial habitat, reducing production capacity of resident salmonid populations in the affected area.

As a result of these hydrosystem impacts, resident fish substitution has been deemed appropriate mitigation for lost salmon and steelhead in areas that previously had anadromous fish, but where anadromous fish access is now permanently blocked by hydropower development and where in-kind mitigation cannot occur.

If the Mainstem Plan is intended to be consistent with a program framework, which provides for mitigation across the basin for the adverse effects to fish and wildlife caused by the development and operation of the federal hydrosystem, it must include a section on resident fish substitution for mainstem reservoirs in the blocked areas.

While the Colville Tribes support resident fish substitution mitigation, we are very concerned about the ability of the current NWPPC Fish and Wildlife Program to provide successful resident fish substitution mitigation in the mainstem above Grand Coulee Dam. Entrainment of fish from Lake Roosevelt, through Grand Coulee Dam has been identified as a serious impediment to the fisheries resource in Lake Roosevelt and constrains the success of current mitigation measures in the blocked area. The operation of the Columbia River System for flood control, power production and flow augmentation for anadromous fish all affect entrainment of fish at Grand Coulee. Successful implementation of a deterrent system may prove to be the single most effective measure to protect, mitigate and enhance fisheries resources in the blocked area and provide flow augmentation benefits in downstream locations.

The Colville Tribes recommends that the Mainstem Plan include measures to address the continued development and implementation of a fish entrainment deterrent system at Grand Coulee Dam. In addition the plan must address and protect, mitigate and enhance all resident fish in hydropower system storage projects to the fullest extent practicable from negative impacts associated with basinwide water management implementation.

• The Council?s program accords highest priority to rebuilding to sustainable levels weak, but recoverable, native populations of resident fish injured by the hydropower system, when such populations are identified by the fishery managers.

A transboundary effort, initiated by Canadian and U.S. fishery managers, is currently underway to recover and manage Upper Columbia River white sturgeon. The white sturgeon that inhabits the upper reaches of the Columbia River in Canada and the U.S. is considered distinct from other populations. There are several known or suspected subpopulations that are isolated from each other by dam construction. Most of these subpopulations are suffering from recruitment failure and are depressed to an extent that they require immediate attention. The development and operation of the hydroelectric facilities on the Columbia River are considered to be the major contributor to this observed impact.

The recovery effort includes the development of a recovery plan that will identify management strategies to stabilize populations of white sturgeon in the mainstem Columbia River above Grand Coulee Dam and prevent further declines and possible extinction. The general framework for recovery has identified three strategies as having the greatest likelihood for recovery of upriver white sturgeon. Although additional research may identify other factors, the stabilization and maintenance of the population will likely require implementation of one or more of the following strategies: 1) modification of the annual Columbia River hydrograph; 2) supplementation of the native population using a capture broodstock and hatchery rearing program; and 3) enhancements of critical habitats.

While the Council?s program does include a measure to initially assess the sock status of upriver white sturgeon in Lake Roosevelt, most of the current recovery efforts are occurring in Canada and for the initial two years of planning the Canadians are funding most of the activities. The implementation of a successful recovery effort for Upper Columbia River white sturgeon will be accomplished only through international (Canada and U.S.) and inter-agency cooperation and participation. The existing budgets of participating and responsible parties are likely not sufficient to fund all the tasks that will be required for recovery.

The Colville Tribes are currently actively participating in this recovery effort and recommend that the Council include as a measure in their mainstem plan, the planning, coordination and funding of recovery actions necessary to restore and stabilize this population. We cannot envision a better candidate species for inclusion in the mainstem plan. This is a long-lived species that spends its entire life in the mainstem Columbia River and now finds itself imperiled and on the brink of extinction as a result of hydro-development.

Thank you for the opportunity to provide recommendations for development of the mainstem plan element of your program. If you have any questions or need additional information, please feel free to contact me at 509 634-2113 or e-mail joe.peone@colvilletribes.com.

• The Council accords highest priority to rebuilding to sustainable levels weak, but recoverable, native populations injured by the hydropower system, when such populations are identified by the fishery managers; then to resident fish substitution measures in areas that previously had salmon and steelhead, but where anadromous fish are now blocked by federally operated hydropower development. Because these losses have endured mostly unmitigated for more than 60 years, and because in-kind mitigation cannot occur, the Council intends that in any project ranking.

Sincerely,

Joe Peone, Director
Fish & Wildlife Department
Colville Confederated Tribes

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