BPA/NOAA Fisheries' designation of critical path
February 12, 2003
Mr. Doug Marker
Director of Fish and Wildlife
Northwest Power and Conservation Council
851 SW Sixth Avenue, Suite 1100
Portland, OR 97204-1348
Dear Mr. Marker:
This letter transmits a comprehensive list of projects (Enclosure 1, 60k PDF) that represents the Bonneville Power Administration (BPA) and National Marine Fisheries Service (NOAA Fisheries) coordinated effort to respond to the Northwest Power and Conservation Council (Council) request that we inform ongoing reprioritization discussions with our view of projects necessary to implement the 2000 NOAA Fisheries FCRPS Biological Opinion (BiOp). This list represents the professional judgment of BPA and NOAA Fisheries. The list also contains BPA's identification of projects critical to meeting the 2000 U. S. Fish and Wildlife Service FCRPS Biological Opinion and BPA's technical support on which NOAA Fisheries does not opine. By nature of the fact that most of the projects identified on the list existed under the Council's Fish and Wildlife Program (Program) prior to the 2000 BiOps, this list of projects also represents the centerpiece of an integrated fish and wildlife program, advancing objectives of both the Council's Program and the BiOps.
Enclosure 1 updates the list provided to the Council by BPA on January 23, 2003, in two important ways. First, the revised list benefits from the combined judgment of both BPA and NOAA Fisheries. Second, it represents a more refined interpretation of the intent of Reasonable and Prudent Alternative (RPA) Actions and the contributions of projects toward those actions (i.e., the rationale for assigning a project to an RPA). The complexity of these two issues should not be underestimated; in fact, there remain legitimate differences of opinion on the applicability and/or importance of an individual project to a RPA Action. While such differences in opinion might indicate areas where further discussion may be beneficial, it would be inappropriate to assume that such differences should be the basis for inaction on subject proposals.
On this list NOAA Fisheries has identified some projects as "non-discretionary" and "strongly advised." Additional projects will be necessary to meet 2003 check-in criteria and long-term performance standards, but NOAA Fisheries has determined that the specific suite of additional projects is at the discretion of BPA and the other FCRPS Action Agencies. BPA has included a partial list of those additional projects and intends to work with the Council to define a final suite of projects. Enclosure 2 describes the process used by NOAA Fisheries in its review and explains the basis for assigning projects to each category.
BPA and NOAA Fisheries trust that this attempt to provide upfront guidance meets the Council's need to inform efforts to reprioritize the Program to meet the funding levels available from BPA. If you have further questions regarding the content of the attached documents, please contact Dr. Chris Toole (503) 230-5410 of NOAA Fisheries or Mr. Bill Maslen of BPA (503) 230-5549.
Sincerely,
[signed]
Sarah R. McNary
Director
Division of Fish and Wildlife
Bonneville Power Administration
Brian J. Brown
Assistant Regional Administrator
Hydropower Division
NOAA Fisheries