Rec. 05 - Oregon Department of Fish and Wildlife

June 15, 2001

Dear Mr. Cassidy:

On behalf of the State of Oregon, the Oregon Department of Fish and Wildlife is submitting the enclosed recommendations (see Acrobat file) for the mainstem Columbia and Snake rivers to be adopted as amendments to the Northwest Power Planning Council's (Council) Fish and Wildlife Program (Program). We believe the state's recommendations lay important groundwork for implementing the Council's vision for a habitat-based approach to fish and wildlife recovery and mitigation. Further, the state's recommendations will provide much needed improvements in mainstem survival to address the critical status of Endangered Species Act (ESA) listed fish and help meet short-term mitigation goals of the Program. However, our recommendations and measures set forth in the federal Biological Opinions will fall short of meeting the Council's long-term vision for the basin and mitigation responsibilities to restore the basin's fish and wildlife. To meet the long-term objectives of the Program and meet ESA and Clean Water Act (CWA) requirements will require bold and aggressive alternative strategies to the current National Marine Fisheries Service's (NMFS) and U.S. Fish and Wildlife Service's Biological Opinions and continued consideration of all strategies including breaching of Snake River dams that are effective in improving survival of fish through the mainstem corridor. The Program needs to include specific direction to the federal agencies to conduct necessary planning and evaluation to ensure that all strategies are ready to be implemented in the event that non-breach alternatives and offsite mitigation plans fail to meet Power Act, ESA, and CWA standards. The Council's Program needs to include these additional strategies and measures to address the long-term mitigation needs of fish and also include habitat replacement measures identified in the 1995 Program as a means to address the long-term mitigation needs of wildlife.

There is an urgent need for the Program to include measures that go beyond the Biological Opinions in making improvements in mainstem survival of ESA listed fish. Compelling scientific information indicates that the opinions are inadequate and many ESA listed salmon populations will become extinct in less than 15 years if our combined efforts don't improve the downstream survival of these fish. The state's recommended improvements in flow, spill, transportation, juvenile bypass systems, turbine designs, and control of fish, bird, and mammal predators will provide greater improvements in mainstem survival than that provided by the opinions, but may not be enough. We strongly urge the Council to include other measures to ensure timely evaluation and implementation of measures to provide immediate improvements in mainstem survival that are adequate for meeting the short-term recovery and mitigation needs of the Power Act and ESA.

This years' emergency hydro operations where nearly all of the NMFS Biological Opinion's fish protection measures were suspended to meet power demands highlight glaring deficiencies in the Council's Program to provide for fish protection during low runoff conditions. This year's record low flows combined with near elimination of biological opinion spill at mainstem dams will cause an irreversible impact to this years' juvenile migrants and may cause a near brood failure to weakened stocks. In the interim until the power capacity of the regional power system can be increased, the Council's Program needs to adopt better operating strategies to balance fish and power needs under low runoff conditions to share any shortfall of water between fish and power operations. The Program should set forth principles for proportionate allocation of any curtailment of fish operations or reductions in power system reliability due to insufficient runoff. Such an allocation scheme will ensure that minimum standards for maintaining both viable fish and wildlife populations and a reliable power supply are achieved under all river flow conditions.

We appreciate the opportunity to provide these comments.


Ronald E. Anglin
Deputy Director

cc: Eric Bloch, John Brogoitti (OR-NPPC)
Neal Coenen
Core Team