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Commentaries and editorials

NOAA Issues Findings Letter
on Salmon Recovery Efforts

by Barry Espenson
Columbia Basin Bulletin - May 23, 2003

A NOAA Fisheries "findings letter" generally gives good grades to the three action agencies charged with implementing actions designed to avoid jeopardizing the survival of salmon and steelhead stocks passing through the Federal Columbia River Power System.

But the agency responsible for protecting salmon stocks listed under the Endangered Species Act expressed concern that key elements of a 10-year recovery plan are lagging.

Specifically off-schedule is the development of scientific frameworks necessary to evaluate whether off-site mitigation actions, such as habitat restoration, are producing the expected improvements in fish survival.

Likewise, the development of individual subbasin plans that are intended to identify factors that limit fish production and help prioritize mitigation actions is behind schedule.

"Schedule slippage in subbasin planning and action effectiveness monitoring will likely impact the Action Agencies' ability to demonstrate 'that proposed actions can increase life stage survivals,' and that they are 'being implemented at a scale sufficient to avoid jeopardy' -- as called for as part of the 2005 and 2008 check-ins," D. Robert Lohn, NOAA's regional administrator, said in a cover letter accompanying the findings.

NOAA Fisheries is closing in on the first so-called "check-in" required under the FCRPS biological opinion the agency issued in December 2000. The document said that planned federal hydrosystem operations would jeopardize the survival of eight of the 12 listed Columbia Basin salmon and steelhead stocks. But the agency outlined in the BiOp's "reasonable and prudent alternative" some 199 actions that could be taken both within the hydrosystem and off-site (habitat, harvest and/or hatchery) to avoid jeopardy.

The fiscal 2003, year-end check-in is by design "programmatic," meaning the agency will evaluate whether the planned activities and products are being started on the dates called for in the BiOp. The 2005 and 2008 dates again check implementation progress but are also supposed to chart through a variety of biological performance standards whether the work that has been done is producing needed survival improvements. There is, however, at this point no measuring stick to judge the survival improvements gained from such off-site work as habitat improvement.

Two of seven problem areas noted in the recently released findings letter focused on the need for such tools -- effective monitoring for offside mitigation actions and research, monitoring and effective database development. Initiatives in both areas are moving forward, but not on schedule. That could cause problems, Lohn said.

"NOAA Fisheries' ability to assess the effects of ongoing and future offsite improvements on fish population growth rates, abundance, distribution and resulting extinction risks for the check-ins on 2005 and 2008 will also be affected," Lohn wrote. "As a result, unless we can quickly develop alternative means of assessment, at the 2003 check-in NOAA Fisheries will need to evaluate whether there will be greater uncertainly associated with the Opinion's reliance on offsite mitigation that will remain beyond the 2005 check-in and any significance for avoiding jeopardy."

Complex times and complex issues have resulted in somewhat halting advances in both the BiOp RM&E and subbasin plan development.

"The reasons for subbasin planning and effectiveness monitoring slippage are understandable because these actions are very complex," Lohn wrote. "They require close, extensive coordination with regional and local interests and related activities being carried out by these other entities.

"That process, relying on the Northwest Power and Conservation Council, has not progressed as NOAA Fisheries had anticipated," Lohn said. "Nevertheless, NOAA Fisheries still believes that habitat improvements achieved through collaborative regional process will result in more sustainable benefits for listed salmon and steelhead."

Many of the BiOp's RM&E needs are being processed through the Council's provincial review process as mainstem/systemwide projects. That process has been slowed for a variety of reasons. Among those reasons have been the need satisfy both ESA and Council program needs within a constrained budget and to win the endorsement of the Council's Independent Scientific Review Panel, as well as the federal agencies and the Columbia Basin Fish and Wildlife Authority's fish and wildlife managers.

The Council and staff also was thrown into a separate and time-consuming process this past winter, in effect reprioritizing and cutting back spending at the request of BPA, which funds the program. The federal agency launched a cost-cutting initiative at the end year in an attempt to reduce anticipated red ink and reduce the size of an anticipated wholesale electricity rate increase.

BPA is also aware of the ESA pressure.

"That's why we've been coming back (to the Council and ISRP) and refining" RM&E projects that are critical for the 2003 check-in, said Sarah McNary, BPA's fish and wildlife director. And while a Council funding recommendations on the mainstem/systemwide projects are not anticipated until at least next month, it has agreed to move forward the design phase of one of the RM&E projects highlighted in the NOAA findings letter -- pilot tributary effectiveness studies.

Time is of the essence, she said. Even if those pilots are launched next year in the field, that means only one year of data will be available to inform the 2005 check-in.

"It takes quite a bit of time to actually gather a sufficient amount of data," McNary said, to make sound judgments about whether specific actions are producing the anticipated results.

That effectiveness monitoring, once in place, will have ESA applications "and make a heck of a lot of sense for the effectiveness of the (Council) program overall," McNary said.

The 2000 BiOp calls for the action agencies to produce annual and five-year implementation plans that describe progress to date, layout details of the short- and long-term plans for achieving performance standards, proposed adjustments to the RPA actions, and describe the rationale for those adjustments. The recent findings judge the 2003/2003-2007 implementation plans produced by the action agencies -- the Bonneville Power Administration, U.S. Army Corps of Engineers and Bureau of Reclamation. BPA markets the power generated in the federal power system. The Corps and Bureau operate the dams.

According to the findings, of the 124 RPA actions due for "definition, implementation, or completion" before the end of fiscal 2003, 97 are on schedule. Of the 27 actions that have fallen off schedule, 20 are not of immediate concern for meeting BiOp objectives for the 2003, 2005 or 2008 mid-point evaluations.

Of the remaining seven issues, three are for hydroelectric RPAs, two are for habitat RPAs and two are for research, monitoring and evaluation RPAs.

Related Sites:
NMFS, NW region:

Barry Espenson
NOAA Issues Findings Letter on Salmon Recovery Efforts
Columbia Basin Bulletin, May 23, 2003

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