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NW Fishletter #389, January 7, 2019
 Fish And Wildlife Program Recommendations Posted, Open For Comment
The Northwest Power and Conservation Council has posted the recommendations it received to amend its Fish and Wildlife Program, and is accepting comments on them until Feb. 8.
Under the Northwest Power Act, the Council amends its Fish and Wildlife Program every five years, following an 18-month process that includes a call for recommendations, public comment and review of those recommendations, issuance of a draft amended program, and more public comment before an amended program is adopted.
After calling for recommendations last May, the Council received by its Dec. 13 deadline responses from 51 entities--11 state fish and wildlife agencies and other state agencies, 16 tribes or tribal groups, four federal agencies, three utilities or utility-focused organizations, eight environmental groups, five entities that had implemented portions of the program, and four individuals.
The recommendations range from a two-sentence encouragement from individual Susan Crampton to support efforts to reintroduce anadromous fish above Grand Coulee and Chief Joseph dams, to a 46-page document from the Oregon Department of Fish and Wildlife with very specific requests for changing the 2014 Fish and Wildlife Program, along with a cover letter and table of contents.
The Council will now read and organize the recommendations and comments and decide the scope of its process before moving forward with a draft amendment.
One of the decisions will be whether the Council will "focus and make progress on a few key issues rather than revise all the program elements," as suggested in its call for recommendations.
In its recommendation, the Bonneville Power Administration (BPA) agreed that the Council should largely retain its 2014 program, but also asked to incorporate the Columbia Basin Accord extensions and other new fish and wildlife mitigation agreements into the update.
"[T]he cumulative scope and scale of the Program's achievements to protect, mitigate, and enhance fish and wildlife are tremendous and should be recognized and taken into account before the Program is changed or expanded in any significant way," BPA stated in the cover letter to its recommendation.
Among its suggestions to the Council is to "look beyond" the incremental costs anticipated in the Fish and Wildlife Program, and consider the full context of the Northwest Power Act's requirements.
BPA's recommendation focuses on "the Northwest Power Act's criteria for minimum cost alternatives to achieve those sound biological objectives, and whether they can be achieved in a manner consistent with the purposes of the Act, in particular to assure the Pacific Northwest an adequate, efficient, economical and reliable power supply."
The recommendation later states, "The energy market has changed, the law governing operation of the Columbia River System has changed, and Bonneville's financial condition has changed. It can no longer be said, as we stated in the 2014 Program, that Bonneville is not in difficult financial circumstances." The agency asks the Council to adhere to BPA's strategic plan for holding overall program costs at or below the rate of inflation through 2023.
Environmental groups, meanwhile, asked the Council for an ambitious amended program, with recommendations ranging from an evaluation of breaching dams on the Snake River to adopting timelines and numerical goals for fish returns in the Columbia Basin.
In a recommendation signed by Earthjustice attorney Todd True--representing the Sierra Club, Save Our Wild Salmon, Idaho Rivers United and the Association of Northwest Steelheaders--the groups said that the amended program should identify and adopt "specific, quantitative biological objectives to measure Program progress even in the absence of a consensus regarding such measures among the regional fish and wildlife managers."
They also asked the Council to support a permanent increase in water quality standards to allow total dissolved gas levels up to 125 percent at dams on the lower Snake and Columbia rivers.
In addition, they asked it to support a review of the biological benefits to juvenile salmon from both a flexible spill and a voluntary spring spill at 125-percent TDG, 24 hours a day at all eight dams on the lower Snake and Columbia rivers; and a review of the biological benefits to salmon survival from breaching or removing the four lower Snake River dams, along with the development of an action to remove the dams.
The groups also want the Council update to support an evaluation of the biological benefits from structural modifications at other lower Snake and Columbia river dams, such as drawdowns; and identify and analyze actions to reduce state temperature water quality standard violations in the lower Snake and Columbia rivers.
A joint recommendation from the Public Power Council, Northwest RiverPartners, PNGC Power and Northwest Requirements Utilities pointed out that their organizations collectively represent BPA customers who fund the Fish and Wildlife Program. "The Pacific Northwest's fish and wildlife mitigation effort is the largest of its kind in the nation and likely the world, yet it is a finite resource," they noted.
With that in mind, the groups asked the Council to consider ensuring a direct link between the program's fish and wildlife mitigation measures, and hydroelectric projects on the Columbia River and its tributaries.
Noting that the program's objectives overlap with requirements of the Federal Columbia River Power System's biological opinion, they also asked the Council to incorporate the biological opinion requirements into the program to avoid conflicts. "The program should demonstrate awareness of these processes and be flexible enough to incorporate the related actions upon their completion."
The groups also asked the Council to maximize benefits by establishing a method for prioritizing projects that could be ranked based on several criteria, including whether they are linked to a hydropower impact, produce broad biological benefits, produce measurable results, represent the least cost alternative, utilize cost sharing, and are not duplicated by other projects.
While urging the Council to support independent scientific review of each funding proposal and adopt recent recommendations from the Independent Scientific Advisory Board, the groups also asked the Council to develop a better strategy for more cost-effective research, monitoring and evaluation, which now accounts for about one-third of the program costs.
Like BPA, the Columbia River Inter-Tribal Fish Commission also recommended that the Council largely retain the 2014 program, and also asked to incorporate projects in the Columbia Basin Accord extensions.
In its recommendation, CRITFC outlined 10 areas for the Council to focus on, including efforts for project administration efficiencies; regional alignment on hydro system operations; habitat strategies and research, monitoring and evaluation; adaptive and data management; lamprey; predator control; climate change; main stem habitat and cold water refugia; regional coordination, and the Columbia River System Operations environmental impact statement.
The Council is expected to discuss the recommendations at its Jan. 15-16 meeting. NWPCC spokesman John Harrison said due to the partial government shutdown, the Council may consider extending the deadline for comments in order to give federal agencies more time to weigh in. -K.C. Mehaffey
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