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Scientists: One-Fourth Subbasin Plans
Scientifically Sound

by Barry Espenson
Columbia Basin Bulletin - August 27, 2004

Scientists asked by the Northwest Power and Conservation Council to review "subbasin plans" say that "approximately one quarter of the plans are complete enough to serve as standalone, scientifically sound amendments to the Fish and Wildlife Program without major additional treatment."

NPCC staff said this week that another set of plans could potentially be made ready for adoption into the program on the Council's original schedule -- in December or January. Another set may be ready for consideration as soon as a couple months later, while a handful will take longer to bring into alignment with criteria set out in the Northwest Power Act.

"We'll have half of the plans ready to adopt before the end of the year," unless unforeseen issues or problems arise, NPCC senior counsel John Ogan predicted.

"I'm really thrilled to be where we are," said Doug Marker, NPCC Fish and Wildlife Division director. That does not mean that the work is done, or even nearly so.

"We've got issues big and small that we still need to work through," Marker said. The Council, its central and state office staffs, statewide coordinators and local planners in Idaho, Montana, Oregon and Washington are now launching into a "response" period during which they will attempt to address shortcomings in the plans.

Aug. 12 marked the end of the public comment period on 45 subbasin plans covering 58 Columbia/Snake river subbasins that had been submitted on or before May 28 as proposed amendments to the Council's program. The plans were developed over the past two years by fish and wildlife managers and others involved in local planning groups. The plans are supposed to identify fish and wildlife project needs and priorities that can be used to direct program funding provided by the Bonneville Power Administration.

A group of 26 scientists that are members of the Independent Scientific Advisory Board, the Council's Independent Scientific Review Panel, and/or its Scientific Peer Review Groups, reviewed the individual plans for technical merit, and provided "overarching programmatic observations" as well. The reviews include short summaries of each plan's scientific strengths and weakness.

The Council staff spent the week following the comment deadline defining issues brought out in the independent science review and those emerging from reams of comment from state, federal and tribal entities, local governmental bodies, private citizens and others. At the heart of the staff analysis is the need to identify issues that affect the "adoptability" of the plans under terms of the Northwest Power Act. Among those provisions is the need for the amendments to be "based on, and supported by, the best available scientific knowledge."

The ISRP/ISAB reviews noted a number of "planning achievements" ranging from broadened stakeholder involvement, a sharpened focus on the causes of fish and wildlife declines and enhanced empirical bases for assessment of habitats with data records to match.

"The strongest part of most subbasin plans was the Assessment, where substantial information about the subbasin's physical environment and biological resources was described.. This achievement alone should be viewed as a major accomplishment.." The subbasin plans were to include an assessment historical and existing conditions, a clear and comprehensive inventory of existing projects and past accomplishments, and a 10-15 year management plan with a vision, biological objectives and strategies.

"In some instances, the thoroughness of the Assessment sets the stage through the limiting factors analyses to prioritize proposed implementation objectives and strategies in the Management Plan, i.e., the ultimate goal of the process. Although many of the plans failed in these later phases, that failure was not due to an inadequacy in their asssessments," the scientists wrote.

"A few plans stand out for their completeness -- these include the Flathead, Kootenai, Fifteenmile, Willamette, and the Umatilla plans," the scientists said. "Even these plans, however, lack a scientifically acceptable and complete Research, Monitoring, and Evaluation Section. The remaining three quarters of the plans, however, need substantial additions and revisions, especially to establish restoration priorities and to complete the Management Plan."

The NPCC staff has suggested that the RM&E issues be addressed universally via processes that are ongoing to better coordinate and direct such processes regionally.

Council and staff are continuing to bring into focus the type of tasks that will be necessary in the coming weeks to lift more of the plans into the adoptable category. Among the considerations, Marker said, is the "feasibility" issue -- can the necessary work be done in the short time period that remains.

"We're still compiling and synthesizing that comment right now," Marker said Thursday. Meanwhile, state subbasin coordinators are now crisscrossing their states, discussing the tasks at hand and what can be done to conform to the Council's desired time frame. The planners have until Oct. 15 to "respond" to comments and issues identified by the ISRP and Council staff. The schedule now calls for the Council to adopt "draft" amendments in November, take comments and hold public hearings and then adopt final subbasin plan amendments in December and January.

It is expected that some of the fixes will take a month or two longer while others will need major revisions.

"We think that some plans are going to take a little longer -- a small group," Marker said.

The states are, relatively, in the same boat with some plans in good shape, others that need work but are believed fixable in a short timeframe, and a few not likely to be ready for adoption on schedule. The exception is Montana with both of the plans constructed there -- the Kootenai and Flathead -- seemingly in good shape.

"Each state has at least a couple of basins that are problematic," said Karl Weist of the Council's Oregon office. As an example, the Oregon's John Day River, and perhaps the Grande Ronde, assessments may have to be reworked because of apparent statistical biases apparent in the habitat assessment tool -- the Ecosystem Diagnosis and Treatment model or EDT. The model is intended to assess habitat capacity by species and identify habitat attributes that are likely limiting factors to survival and production. A skewed model portrait ultimately would skew the remedial priorities identified through the assessment and strategies outlined in the management

The majority of the Oregon plans, however, "came in in really good shape," Weist said.

Comments received from the Columbia River Inter-Tribal Fish Commission took the NPCC process to task both technically and legally.

A cover letter signed by CRITFC's executive director, Olney Patt Jr., says that legal shortcomings in the process and technical flows evident in most of the plans require the Council to start over.

"Given that the NPCC attempt to limit the sub basin plans to broad strategies, the Commission encourages the Council to issue a new Request for Recommendations that complies with Section 4(h)(2) of the Northwest Power Act, addresses the technical shortcomings described in the enclosed technical comments, and requests a prioritized list of measures along with a budget as a final phase in its subbasin planning process prior to incorporation into the Program," Patt wrote. The subbasin planning process was launched in August 2002 with a request for recommended amendments -- subbasin plans -- to its program.

Patt says that the Council, in setting up the process, deliberately ignored a power act provision that says that 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 are "measures which can be expected to be implemented.." 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.

That will not do, Patt said.

"Without specific recommended actions provided by fish and wildlife agencies and tribes as required by the Northwest Power Act for any major revision of the Program, the Program will be subject of feckless wrangling over the prioritization and funding of projects that is inconsistent with the Northwest Power Act's requirements for a systemwide program of measures as well as objectives, coordination, research and monitoring," Patt wrote. The act does not specifically define measures.

"While the subbasin planning effort may have been a worthwhile step in assessing watershed conditions, suggesting remedial strategies and developing partnerships, it needs to be followed up with a timely process to develop on-the-ground actions and projects as well as the resources to implement adopted measures," Patt wrote.

Council staff said the procedural complaint took them by surprise. The various local planning groups included the participation of CRITFC member tribes.

"We've got the comments. We're not ready to suggest a course of action," Marker said.

The CRITFC tribes' technical comments touched on a variety of topics, and perceived flaws in the plans. Many were related to the time, money and technical effort that was allocated to the process.

"The time allowed for developing, reviewing, and getting policy approval of subbasin plans has been and is inadequate. Plan quality has been sacrificed to meet an inflexible time schedule. The result has been draft plans of differing quality, with compromised technical merit, and without policy approval by the tribal resource managers. The Council should adopt a realistic schedule for addressing these shortcomings before the plans can become part of a sound system-wide Fish and Wildlife Program the Council is required to develop under the Northwest Power Act," according to the comments.

Related Sites:

Barry Espenson
Scientists: One-Fourth Subbasin Plans Scientifically Sound
Columbia Basin Bulletin, August 27, 2004

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