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Council Votes to Send
Subbasin Plans, Issues Out for Comment

by Barry Espenson
Columbia Basin Bulletin - October 15, 2004

The Northwest Power and Conservation Council on Wednesday voted to release for public review and comment 29 locally produced "subbasin plan" recommendations as draft amendments to the Council's fish and wildlife program.

A notice letter expected to be sent out today or Monday to interested parties will ask for comments on specific plans and on a broader set of issues related to the subbasin planning process itself.

Among those issues is a charge that plans do not contain specific fish and wildlife mitigation actions as the law requires.

The comment period on the drafts and on those side issues extends to Nov. 22. The goal of the Council and its staff is to then assess the comments and make any necessary adjustments to the plans. The Council could then at its Dec. 14-16 meeting in Portland adopt any or all of the "final" versions as amendments to its Columbia River Fish and Wildlife Program.

The Council was created following 1980 adoption of the Northwest Power Act. The law called for the Council to create, and regularly update, a fish and wildlife program to protect, mitigate and enhance wildlife affected by the federal Columbia River hydrosystem. The program, now funded at $139 million annually for expense and $36 million for capital, is paid for with ratepayer revenues by the Bonneville Power Administration.

It is expected that the subbasin plans' objectives and strategies will drive the prioritization of spending within the program.

The Act requires that program amendments meet certain requirements, not the least of which being that they reflect the best available science. And while none of the 29 plans is perfect, a staff review of them and comments submitted over the summer produced the judgment that the plans "could be used to guide project selection process in the near term," NPCC senior counsel John Ogan told the Council.

"We feel very good about their consistency" with the Act, Ogan said. The plans (recommended amendments) were submitted on or before May 28 by local planning groups. Their submittal was followed by a public review period and scrutiny by the Council's Independent Review Panel that ended Aug. 12. The Council staff and statewide planning coordinators then reviewed both public and ISRP comment, as well as the plans themselves, in deciding which of the 59 submitted plans could move forward yet this year.

From that review "emerged one set of subbasin plans that looked very, very strong," Ogan said. Most, if not all, had deficiencies related to the needed monitoring and evaluation elements. And many did not properly define or integrate artificial fish production strategies with other elements of the plan. But the staff suggested, and the staff agreed, that those parts of the 29 plans could be shored up later when the output of related regional processes is available.

Ogan said that neither issue should hold up approval of the 29 plans. And otherwise, the ISRP and public critiques revealed "nothing that rose to the level of questioning the basic soundness" of the 29 plans.

Those "broader issues" do pose potential stumbling blocks, however.

"We hope that it's not necessary to resolve these (issues) by December," NPCC General Counsel John Shurts said. One of those issues involves the definition, legal or otherwise, of the word "measures" as used in the Act.

In a letter accompanying comments submitted in August, Columbia River Inter-Tribal Fish Commission executive director Olney Patt Jr. says that the Council, in setting up the process, deliberately ignored a Power Act provision that says, before any major revisions to the plan, the Council must ask for recommendations from the tribes and federal and state fish and wildlife agencies that include "measures which can be expected to be implementedů." CRITFC says measures are specific on-the-ground projects but that the Council instead requested "strategies" with specific projects to be developed through a regional project funding process.

Another broader issue of concern is how, specifically, the plans will be used to prioritize funding and select fish and wildlife projects. A "three-year provincial review" project selection process has effectively been scrapped and no new method for selecting projects has been devised.

Others want to know specifically what relationship the subbasin plans will have to ongoing federal and, in Washington's case, state Endangered Species Act salmon recovery processes. Still other questioners want to know how the plans will be used to formulate priority strategies at provincial and Columbia basinwide levels. The Council has broken up the basin into geographic "provinces."

"The implications are fairly significant," Shurts said. He suggested that the Council solicit comments on those broader issues on a "parallel track" with the draft plan comment period. The staff would then work, via consultation with interested parties, to better define the issues and identify potential resolutions.

The 29 plans issued for public review address the following rivers, some of which cross state lines. As well, for planning purposes some of the subbasins are specific reaches of the mainstem Columbia River. The subbasin locations are:

A total of 59 draft subbasin plans were submitted to the Council last May following nearly two years of work by watershed councils, local governments and state, federal and tribal agencies. The plans were produced in response a Columbia River Basin Fish and Wildlife Program directive that successful mitigation of the impacts of hydropower on fish and wildlife will be accomplished through the selection and implementation of subbasin-level goals, objectives and strategies.

Each subbasin plan has an assessment that describes historical and existing conditions, an inventory of existing fish and wildlife projects and past accomplishments, and a management plan that looks 10-15 years into the future. It is expected that only the management plans will be adopted officially as amendments to the Council program, In addition to guiding implementation of the fish and wildlife program, subbasin plans will be used by NOAA Fisheries and the U.S. Fish and Wildlife Service as a component of ESA recovery planning. State and federal agencies will use the plans to help reconcile hatchery and harvest goals and to complete an integrated monitoring and evaluation framework for fish and wildlife projects and research, according to a NPCC press release.

The schedule of hearings includes:

For more information on any hearings, contact Judi Hertz at 503-222-5161.

The draft plans are posted on the Council's website,

The Council is made up of two members each from the states Idaho, Montana, Oregon and Washington. Councilors are appointed by the governors of their state. The Act also charges them with assuring the region an adequate, efficient, economical and reliable power supply.

Related Sites:

Barry Espenson
Council Votes to Send Subbasin Plans, Issues Out for Comment
Columbia Basin Bulletin, October 15, 2004

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