Rec. 02 - Public Power Council

June 15, 2001

Attached (view Acrobat PDF file), please find the recommendations of the Public Power Council (PPC) on the Council's Mainstem Plan. Here is a summary of PPC's recommendations.

I. The Council should be assertive in fulfilling its obligations regarding management of the Federal Columbia River Power System (FCRPS).

II. The Council should carefully design its Mainstem Plan so that it makes sense and is effective from a "big picture" perspective.

A. Start with an overall framework for the mainstem plan that is designed to achieve a balance between fish and power obligations (as opposed to starting by adopting specific measures).

B. Include clear statements of biological and power system goals, objectives and performance standards.

C. Include methodologies for assessing the degree to which proposed strategies and measures can be expected to achieve the goals, objectives and performance standards as well as measuring actual performance.

D. Use cost-effectiveness applied to the goals, objectives and performance standards as the basic evaluation criteria. Because the Pacific Northwest Electric Power Planning and Conservation Act (Act) requires the Council to seek a balance between fish and wildlife mitigation and power supply, the use of cost effectiveness should guide the Council on key issues such as considering how far to go in protecting and restoring natural functions in the basin.

E. Tailor the Mainstem Plan so that it effectively contributes to

1. the federal Implementation Plans for the 2000 Biological Opinion and

2. ensuring the region of an adequate, economic, efficient and reliable power supply.

Attached, please find PPC's detailed recommendations. Thank you for this opportunity to submit recommendations. PPC looks forward to working with the Council during this rulemaking.

Sincerely,

Robert G. Walton
Assistant Manager