Strategy
Assure funding to identified program priorities to maximize the biological response resulting from ratepayer and cost-shared investments.
Rationale
The Council’s program contains hundreds of measures at the basinwide, mainstem and subbasin levels. Program measures are funded and implemented not just by Bonneville, but also through programs under the authority of the U.S. Army Corps of Engineers (the Corps), the Bureau of Reclamation (the Bureau) and the Federal Energy Regulatory Commission as its licensed non-federal hydroproject operators.
Bonneville has chosen to implement many of its Northwest Power Act requirements through a series of long-term commitments that it believes help address its legal obligations through at least 2018 and beyond in some cases. Bonneville continues to prioritize ESA responsibilities in its investment plan, although it also funds elements of the Council’s program that address the other, non-listed fish and wildlife affected by the hydrosystem.
The program represents a substantial investment by the ratepayers of the Northwest and the nation’s citizens. For example, over the last three decades Bonneville and the other program implementers have made substantial investments in a wide variety of physical structures and land acquisitions to benefit fish and wildlife. There is a growing need throughout the Columbia River Basin to protect or upgrade these investments as facilities age or become obsolete, structural standards change, and extreme-event damages accumulate.
The Council recognizes that ratepayer funding requires some basic controls and that there is not unlimited funding to address every need for fish and wildlife affected by the development of the federal hydrosystem, all at once. At the same time, the Council received recommendations to continue the ongoing work under the program along with recommendations for new or expanded work. Bonneville’s existing budget commitments limit its flexibility for funding new work, constrain expansion of ongoing work, may leave unfunded some of the state and federal fish and wildlife agencies’ and tribes’ priorities, and provide for only limited capacity for maintenance of past investments.
To assure thoughtful use of Bonneville funding to maximize benefits to fish and wildlife, the Council has identified the following principles and priorities to guide the funding and implementation of program priorities by Bonneville, the Corps, the Bureau, project sponsors, and their partners.
Principles
- Bonneville will fulfill its commitment to meet all of its fish and wildlife obligations.
- Program funding levels should take into account the level of impact caused by the federally operated hydropower system and the off-site protection and mitigation provisions of the Northwest Power Act enabling program investments in related spawning grounds and habitat.
- Wildlife mitigation should emphasize addressing areas of the basin with the highest proportion of unmitigated losses.
- The Council will continue to evaluate the distribution of funding to provide fair and adequate treatment across the program. Meanwhile, the Council maintains the current funding allocation for anadromous fish (70 percent), resident fish (15 percent), and wildlife (15 percent).
- Hydropower facility site-specific invasive species prevention actions and toxics reduction activities are ongoing maintenance issues. Funding for these efforts should be derived primarily from the Corps and the Bureau operations and maintenance budgets rather than from Bonneville’s fish and wildlife budget to implement the program.
- The Council believes that final determination of a yearly direct program budget should occur no later than one year before the relevant projects are to be funded. Generally these projects’ budgets are difficult to forecast more than three years in advance of initiation; so the budget is expected to be a rolling three-year spending plan, developed by Bonneville, that will have a current spending estimate replaced by a new three-year estimate every year.
- Priority work funded through the Columbia River Fish Mitigation Program (CRFM) should not go unfunded because of competing priorities between districts of the Corps (e.g., between the Columbia/Snake hydropower projects and the Willamette Basin projects). The Council urges the action agencies to meet their Willamette and FCRPS Biological Opinion implementation and mitigation obligations.
- Provide for timely ongoing operation and maintenance costs associated with existing investments. Some existing projects are aging and need repair. Long term maintenance for existing projects including fish screens, hatchery structures, wildlife acquisitions, and other long term needs must be supported to meet project and program objectives.
- Bonneville and the action agencies should allocate and assure adequate funding for the application and recovery or detection of PIT tags, coded wire tags, acoustic and radio tags, and genetic tags.
- Bonneville will continue to provide adequate support for terminal fisheries in the estuary and other basinlocations.
Emerging program priorities
The Northwest Power Act establishes Bonneville’s obligation to protect and mitigate for fish and wildlife impacts from the development and operation of the hydropower system. The Council recognizes its obligation, in turn, to construct a program that guides Bonneville’s protection and mitigation efforts. Work necessary to satisfy Bonneville’s mitigation obligation must be sized appropriately during Bonneville’s rate cases and as it projects its capital and expenditure budgets, so as to provide equitable treatment to high-priority fish and wildlife projects, regardless of whether or not they are identified in a biological opinion or in an accord, while also accommodating yearly budget limitations.
Many of the program’s current measures represent ongoing activities that already have multi-year funding and implementation commitments from Bonneville and the other federal agencies for the foreseeable future. These ongoing activities and existing program areas represent a set of priorities from earlier programs and largely continue into the new program.
At the same time, the Council received recommendations for many new measures for inclusion into the 2014 Program. All measures are subject to the same legal obligation on the part of the federal agencies with responsibilities toward the Council’s program under the Northwest Power Act. Some of the new measures recommended for inclusion in the 2014 Program expand existing work in new or additional directions; others represent new directions for the program.
The Council is providing the following guidance to Bonneville, the other federal agencies, and the region in general as to which of these new measures are emerging priorities for implementation in the next five years. During the course of the next five years, the Council anticipates that Bonneville will take the necessary steps to integrate these priorities into the program and will report annually to the Council on its progress. The Council may adjust the following ordered program priorities:
- Provide for funding long-term maintenance (Appendix P) of the assets that have been created by prior program investments
- Implement adaptive management (including prioritized research on critical uncertainties) throughout the program by assessing the effectiveness of ongoing projects, developing program objectives when appropriate and taking into account the effects of climate change
- Preserve program effectiveness by supporting: (1) expanded management of predators; (2) mapping and determining hotspots for toxic contaminants; and (3) aggressively addressing non-native and invasive species
- Investigate blocked area mitigation options through reintroduction, passage and habitat improvement, and implement if warranted
- Implement additional sturgeon and lamprey measures (passage and research)
- Update the subbasin plans most in need of updates
- Continue efforts to improve floodplain habitats
Bonneville funding for emerging program priorities
Bonneville should fund any new fish and wildlife obligations from identifying savings within the current program and as necessary, from additional expenditures. Savings from the current program should not compromise productive projects that are addressing needs identified in this program. For example, additional funding can be obtained when projects complete their goals, such as a research project, or when a project is no longer reporting useful results. Funding should also be sought in general overhead budgets including Bonneville’s overhead for its Fish and Wildlife Division. To the extent that targeted savings are insufficient to meet Bonneville’s financial obligations in this program, Bonneville should consider increasing expenditures. Prior to every rate case Bonneville should report to the Council how it plans to budget for implementation of the fish and wildlife program. [see cost-effectiveness recommendations from the IEAB].
