Mark Walker
Director of Public Affair
Northwest Power Planning Council
851 SW Sixth Avenue, Suite 1100
Portland, Oregon 97204

Dear Mr. Walker:

The Washington Department of Fish and Wildlife (WDFW) has developed the following recommendations for amendments to the Fish and Wildlife Program (Program). The Northwest Power Planning Council (Council) requested amendment recommendations under Section 4(h)(2) of the Northwest Power Planning Conservation and Electric Act (the "Act") in a letter dated January 12, 2000. Many of our comments either endorse or respond to concepts advanced by Council staff in their "strawman" document, the version available on the Internet on May 11; we appreciate their work. Much of our response is the result of a concept paper by Columbia Basin Fish and Wildlife Authority (CBFWA) staff (May 9 draft); we also appreciate their work.

It is certainly an appropriate time for the Council to revise their Program. After almost a decade of learning the ramifications of the Endangered Species Act (ESA) in the Basin, WDFW believes that we can apply those lessons to development of the new Program. Simultaneously, the fish and wildlife programs in the Basin have undergone increased scientific scrutiny, and we are in the fortunate position of being able to apply the review results to the amendment process as well. Recent efforts to portray the ecosystem dynamics of the Basin can and should contribute to a Program that is better grounded in ecosystem management concepts than previous Programs.

And, in recognition of the Regional examination of the performance, and even of the credibility of our fish and wildlife restoration efforts in the Basin, our recommendations for the revised Program have two major accountability foundations.

First, the Program should have a clear description of a straightforward process by which the region makes decisions regarding fish and wildlife funding by Bonneville Power Administration (BPA) and other entities. This process must be based on existing legal authorities and spell out the roles of the involved parties.

Second, the Program should present the standards or criteria by which fish and wildlife plans are developed and funding decisions are made. This allows all participants in the Program to know how their efforts will be judged and allows the public to hold decision-makers accountable.

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