P.O. Box 200701
Helena, MT 59620-0701

May 12, 2000

Mr. Larry Cassidy, Chairman
Northwest Power Planning Council
Fish and Wildlife Program Amendments
851 S.W. 6^th Avenue, Suite 1100
Portland, OR 97204 -1348

Dear Mr. Cassidy:

Our proposed amendments to the Fish and Wildlife Program address: 1) subbasin planning; 2) changes to system-wide dam operation, 3) statewide and regional data management; and 4) techniques to improve cost effectiveness. Basin specific amendments will be detailed in our subbasin plans. Also attached are excerpts and our comments (in bold print) re: the draft amendments prepared by CBFWA. The hardcopy submittal will also contain a pertinent publication that is referred to in this letter.

Subbasin Planning

• Issue – While most of the data required for subbasin planning already exist in various reports, publications and spatial and tabular data files, the process will require additional work. The program should provide additional funding to carry out planning and public scoping. Care should be taken to minimize impacts to on-the-ground actions.
• Strategy – Funding should be provided to staff subbasin planning adequately to meet the ambitious schedule without affecting ongoing program measures and staff.

The fish and wildlife managers will have the ultimate responsibility for development of the fish and wildlife management objectives and will be responsible for coordinating the development of these objectives during the Council’s public process. It is expected that land managers, watershed councils, private land owners and any other interested parties will also have an opportunity to comment on the strategies and actions, within the side boards set by science. We anticipate that our portion of plan preparation and the public scoping and involvement process will cost roughly $200,000 based on past experience with our mitigation planning effort. This expense cannot be borne by our existing projects without sacrificing existing mitigation actions. Additional funding should be provided through the Program. We recommend that the Council take the lead in public review of the draft plans.

System Operation

• Issue - To date, operational strategies to recover fish species in one part of the basin have inadvertently caused negative impacts on sensitive species elsewhere in the basin. This is inconsistent with the intent of the Endangered Species Act and the Northwest Power Planning Act. Dam operation will soon be affected by the Biological Opinions on bull trout and anadromous fish species. The Recovery Plan for the endangered Kootenai white sturgeon specifies operational procedures at Libby Dam. The operation of the Federal Dams on the Columbia River must be designed to benefit all listed stocks in the Columbia Watershed.
• Strategy - Implementing Integrated Rule Curves (IRCs) at all storage projects can reduce negative biological impacts. The IRCs for Hungry Horse and Libby Reservoirs were adopted by the Northwest Power Planning Council in 1994, and recommended as a high priority for development at other Columbia River storage projects. The Independent Science Group has determined that the IRCs are consistent with their Normative River Concept and recommended that they be applied to other Columbia River subbasins. For these reasons, the Fish and Wildlife Program should direct the implementation of IRCs at Hungry Horse and Libby Reservoirs.
• The Program should also develop IRCs for projects that do not presently have integrated operational rules and implement the "tiered flow" approach for Kootenai River white sturgeon below Libby Dam. (note: the hardcopy submittal contains a publication Marotz et al. 1999, that contains details on a basin-wide application of IRCs to benefit resident and anadromous fish species).

• Issue - Montana has been involved with collecting and managing resident fish and wildlife data as part of StreamNet (and its predecessors) for the last 15 years. While Montana maintains these data as part of the Montana Rivers Information System, it also provides access to these data in regional datasets maintained by StreamNet. As issues become more complex, it is essential that the Council provides coordination to the collection, management and access to these data sets.
• Strategies – Montana supports the full recommendations on data management submitted by the StreamNet Steering Committee to the Council which include the need for:
• Regionally standardized data collection and data management
• Regional priorities for data collection and availability
• The use of new technology to improve data management effectiveness
• Integration of data management and data analysis as part of project development
• An electronic library/archive to provide access to reports and other regionally significant scientific literature in paper and electronic form.

• Issue – The proliferation of bureaucratic process is diverting a large portion of staff time and monetary resources away from meaningful on-the-ground actions. A review of the costs associated with process is warranted.
• Strategies – Reduce, where practical, meetings and associated travel costs by utilizing technology. Telephone conferencing can be useful when all participants are on the line. Phone conferencing with ongoing meetings is only marginally effective because those on the line often have difficulty hearing, and can not see visual aids during these deliberations. The Program should stress the use of video conferencing, and eventually Internet video conferencing, to reduce travel costs. Using this technology will reduce expenditures related to airfare, ground transportation, hotel stays, per diem and travel time. Savings can be redirected toward on-the-ground actions. Face to face meetings will still be required at times for specific coordinated actions. We recognize that these technologies are not uniformly available throughout the Columbia Basin. Gaps in the needed technology should be identified and targeted for improved communication. Cost savings from travel reductions will offset these communication costs.
• Issue – Project managers require flexibility to respond to schedule changes, unforeseen opportunities and cost-share arrangements. For instance, implementation of a planned action may be delayed due to permitting processes, changing public sentiment or problems with equipment or contracting. A second opportunity could arise as an immediate substitute. Project managers are most efficient when such adjustments can be made rapidly. The existing process appears to remove this needed flexibility.
• Strategy – The Program should contain a mechanism to award cost cutting measures and cost-share arrangements. Money saved can be used for other actions to benefit fish and wildlife. Project sponsors should also be allowed line item transfer ability, within the scope of the approved project, to respond to opportunity.

Sincerely,

Larry G. Peterman, Administrator
Fisheries Division

C: Mark Walker, mwalker@nwcouncil.org

Go to top | Go to index