[Letter to Sarah McNary, Bonneville Power Administration]
October 30, 2002
Dear Ms. McNary:
The Northwest Power Act directs the Council to provide Bonneville recommendations for funding projects to protect, mitigate, and enhance fish and wildlife in the Columbia Basin. The purpose of this letter is to transmit the Council's recommendations for funding such projects in the Estuary, Lower Columbia, Columbia Cascade, Upper Snake and Middle Snake provinces for Fiscal Years 2003 through 2005. The Council made its recommendation decisions for proposed projects in these provinces at its September 11th meeting in Spokane, Washington.
The Council's project recommendations are the product of what I believe is the most intense and publicly accessible review process for the administration of a natural resources program in the region, and perhaps the nation. The process for developing these recommendations was initiated with the development of Subbasin Summaries for each watershed or subbasin by broad and diverse groups of stakeholders. After Subbasin Summaries were completed, we joined in a solicitation letter asking for project proposals, and provided links to numerous guidance documents. That solicitation letter suggested what types of projects might be favorably received, such as those that respond to Bonneville's Endangered Species Act obligations. When the responses to our solicitation were received, the Independent Scientific Review Panel (ISRP) went on site-visits to proposed project areas, reviewed each project proposal and supporting documents against statutory criteria designed by Congress to ensure the scientific soundness of Bonneville funded projects. The ISRP entertained oral proposal presentations/defenses and issued a preliminary report. The ISRP reviewed projects a second time with additional sponsor information in a "fix-it-loop" process, and issued a final report to the Council. Public comment was taken on the projects and the ISRP reports. Bonneville, and the Columbia Basin Fish and Wildlife Authority provided comprehensive comment and recommendations during the public comment period. For projects affecting listed salmonids, NOAA Fisheries provided project-by-project findings on the responsiveness of specific proposals to particular Action Items in the Reasonable and Prudent Alternative for the Operation of the Federal Columbia River Power System. Finally, project sponsors participated in a prioritization exercise, taking into account this large amount of information, comment, and findings that had been received during the public process.
Council state and central offices participated in the development of the project recommendations in each of these provinces. Projects and associated budgets were discussed in great detail in meetings with proposal sponsors. For the two Snake River provinces, the Idaho Office of Species Conservation worked in partnership with the Idaho Council Office. In the Estuary and Lower Columbia Provinces, the Oregon and Washington state Council offices worked jointly to assist stakeholders in the development of project recommendations. The direct involvement of Council state and central staffs helped to ensure that the projects recommended here are consistent with the project funding policies applied in previously reviewed provinces.
The Council's funding recommendations for these provinces continues to be consistent with the project funding targets provided by Bonneville. That is, the Council has taken care to ensure that its funding recommendations made here, added to those previously made and yet to be occur (Mainstem/Systemwide), are within the $186 million annual average direct program budget target that Bonneville established last year. The budget trimming and prioritization process that occurred in these provincial reviews was demanding, as there were many more projects that met the scientific review standards than could be funded with the funds committed by Bonneville.
The Council's project funding recommendations are captured in a table for each province, and a companion Issue Memorandum. The tables show which projects are recommended for Bonneville funding, and provide recommendations by project phase for each project. The tables also illustrate the findings of NOAA Fisheries relative to Reasonable and Prudent Alternative Action Items and the recommendations of CBFWA. The Issue Memorandum has a chapter for each province. The Issue Memorandum does not speak to each and every project recommended for funding. Rather, the memorandum explains special conditions or considerations for particular projects. For example, if one or more of the entities (ISRP, CBFWA, Bonneville, etc) that reviewed projects had critical comment about a proposal, and the Council has recommended the project for funding, the memorandum seeks to explain how those or concerns were considered. The memorandum should be carefully reviewed to understand and apply project-specific conditions that the Council makes for several projects.
As you know, the Council has been growing increasingly concerned about the degree of fidelity Bonneville has to its project funding recommendations. The Council understands that Bonneville is the final decision-maker in this process. However, the Council strongly believes that the role assigned it by Congress in project funding decisions, and the arduous public process that has facilitated to develop these recommendations demands a high degree of respect and deference. Separately, the Council is responding to your comments concerning the "in lieu" provision of the Power Act as applied to some projects in these provinces. The Council provincial review process has been successful in delivering the projects that meet Bonneville's off-site mitigation Biological Opinion needs while also moving forward on the broader fish and wildlife mandates of the Power Act. It has done this publicly, applying sound and independent science, and within the budget prescribed by Bonneville. I am hopeful that the Administrator, you and your staff appreciate the work that has gone into developing these recommendations, and will decide to follow them closely as Bonneville enters into contracts for projects in these provinces.
Sincerely,
Doug Marker
Director, Fish and Wildlife Division