Fish & wildlife Subbasin planning Guides and forms ESA

NMFS Recovery Plan Guidelines

[This is an attachment to NMFS' letter to the Council on the relationship between subbasin planning and the Endangered Species Act. Bold formatting added by Council for faster web viewing.]

The following guidelines are generally applicable to any local recovery planning effort in Oregon, Washington and Idaho at the scale of the subbasin. For ease of application by subbasin planners participating in the Council's program, they are organized here according to the outline of the Council's Technical Guide for Subbasin Planners. There is nearly complete overlap with the Council's Technical Guide. We have noted the instances where the NMFS? guidelines may go further due to NMFS? statutory obligations or where additional explanation is warranted.

I. Technical Guide Introduction

1. Include a schedule for revising and updating the plan, based on new information (e.g. a description of the Fish and Wildlife Program rolling provincial reviews). annotation >

2. Include participation by entities with the appropriate authorities, responsibilities and interests to implement conservation actions. annotation >

II. Technical Guide Subbasin Assessment

3. Identify the plan area and its relationship to the affected populations and ESUs. annotation >

4. Use an accepted technical assessment template such as the subbasin assessment template for the Northwest Power Planning Council's Fish and Wildlife Program. annotation >

5. Identify and classify finer-scale watersheds that are priorities for protection, and restoration, or other strategies. annotation >

6. Describe assumptions about conditions and actions outside the local plan area (e.g. ocean survival). annotation >

7. Identify factors limiting recovery; be as specific as possible by applying limiting factors analyses to specific life cycle stages. annotation >

III. Inventory of Existing Activities

8. Identify existing local management programs and evaluate their ability to fix the limiting factors and factors for decline and to meet recovery goals. Identify inadequacies in either design or implementation. Identify inadequacies in either design or implementation. The ESA statute and case law require NMFS to review the inadequacies of existing regulatory mechanisms when it makes delisting decisions. annotation >

9. Include measurable objectives or criteria for fixing the limiting factors and the factors for decline. The statute obligates NMFS to have these as part of delisting criteria. This goes beyond what is in the Technical Guide. annotation >

IV. Management Plan

10. Incorporate biological recovery goals for the ESUs and populations in the plan area. Where these have not yet been developed,  incorporate NMFS? interim targets. annotation >

11. Address within subbasin/watershed habitat, artificial production and local harvest management strategies. annotation >

12. Identify and prioritize specific actions (including programs) for both protection and restoration at the subbasin scale. This goes beyond the strategies described in the Technical Guide due to the ESA's requirement to express site specific actions. This is a problem that NMFS and Council staff are working on. annotation >

13. Identify and prioritize specific strategies or actions (including programs) for both protection and restoration at the watershed (finer) scale where possible. This goes beyond the strategies in the Technical Guide. To the extent that actions have been defined through planning and assessment at finer scales, those actions should be incorporated or referenced. annotation >

14. Include an analysis of whether the existing and proposed programs and actions will achieve the recovery goals. The Technical Guide requires an explanation of the linkage between strategies and objectives. This guideline underscores the need for a transparent relationship between the technical information, analyses and decisions about actions. This goes beyond the Technical Guide, which requires an explanation of the linkage between strategies and objectives. This guideline calls for a more specific analysis that relates the package of strategies to achievement of recovery goals. annotation >

15. Include a monitoring program and adaptive management program.  annotation >

Guidelines Annotated

1. Include a schedule for revising and updating the plan, based on new information.

The initial rounds of local recovery planning are not expected to be perfect. Initial rounds need to be based on existing information. As we do assessments, we will find that existing information leaves us with critical uncertainties and data gaps. Research and monitoring needs to be directed toward filling those gaps. Also, as the ESU scale of recovery planning evolves, it will provide additional context for the subbasins and the independent populations. Local recovery plans should be viewed as iterative documents that can adapt to new information and that will become more sophisticated with time. < return to text

2. Include participation by entities with the appropriate authorities, responsibilities and interests to implement conservation actions.

Entities with the responsibilities and authorities to implement actions that affect salmon and steelhead need to participate in the development of local recovery plans. Ideally, all such relevant entities would provide assurances that their part of the plan will be implemented so that all participants can rely on that implementation. < return to text

3. Identify the plan area.

The plan area may be smaller or larger than populations or ESUs. In any case, the relevance of the plan area to the population structure of listed fish needs to be clear. < return to text

4. Use an accepted technical assessment template, such as the subbasin assessment section for the Northwest Power Planning Council's Technical Guide for Subbasin Planners.

There are several assessment methods available. NMFS? primary concerns are that the assessments answer key questions and that they are og good quality. The list of questions the assessments should answer is in the Council's Technical Guide. There also needs to be quality assurance criteria for assessments. < return to text

5. Identify and classify finer-scale watersheds that are priorities for protection, restoration or other strategies.

It is difficult to make technically credible site-specific choices from the subbasin perspective. A closer look is needed. In many cases, finer-scale assessment and planning will provide the level of resolution needed for planning and implementing specific actions. Where finer-scaled plans are available, they should be recognized and used or referenced in the subbasin plan. Where finer-scaled plans are not available, the subbasin assessment will help indicate which areas should be prioritized for finer-scale assessment and funding through state, federal, Council and other programs. < return to text

6. Describe assumptions about conditions and actions outside the local plan area.

There are many influences on salmon survival outside the subbasin/watershed area. It is important that subbasin planners use a consistent set of assumptions regarding these influences. NMFS, in coordination with regional experts, will provide a set of assumptions that should be consistently applied across the populations in an ESU. Such assumptions will include natural and climatic variability, survival through hydropower systems, ocean and mainstem fishing mortality, and estuarine survival. < return to text

7. Identify factors limiting recovery, be as specific as possible.

The more specific limiting factors descriptions are, the more useful they will be for targeting priority actions that are meaningful to fish at key life history stages. There are many limiting factors analyses already complete or underway. NMFS? concern is that some of the limiting factor analyses may be quite general and need additional specificity. At any rate, existing analyses should be used and enhanced as needed through the subbasin assessment and TRT process. < return to text

8. Identify existing local management programs and evaluate their ability to fix the limiting factors and factors for decline and to meet recovery goals. Identify inadequacies in either design or implementation.

There are many restoration programs sponsored by tribes, states, federal agencies and local governments and nongovernmental organizations. It is important to look at these as a package, along with the programs that manage land and water in the affected area. While many state, federal and local land and water management programs have improved, there are still daily management actions that continue to degrade the environment. The benefit of restoration programs can best be measured if we know what is protected and whether the environment will stay the same or continue to degrade. < return to text

9. Include measurable objectives or criteria for fixing the limiting factors and the factors for decline.

NMFS? delisting criteria need to include not only biological delisting criteria, but also criteria for addressing the factors for decline. Most of the ESUs in the Columbia River were listed due to a combination of all five statutory listing factors:

1. present or threatened destruction, modification or curtailment of habitat or its range;
2. over-utilization;
3. disease or predation;
4. inadequacy of existing regulatory mechanisms;
5. other natural or manmade factors;

In its recovery guidance for West Coast salmonids, NMFS calls these criteria ?administrative criteria? as opposed to biological criteria.  < return to text

10. Incorporate biological recovery goals for the ESUs and populations in the plan area, as developed through the Technical Recovery Teams, working with local planners. Where these have not yet been developed, incorporate NMFS? interim targets.

First, identify ESUs and populations within the plan area. Then, apply biological viability goals developed through the TRT process. These viability goals are meaningful when viewed as a package of: abundance, productivity, spatial distribution and genetic diversity. Biological recovery goals will also ultimately need to be developed and applied ESU-wide, meaning that the individual populations will be looked at together for ESU-wide population scenarios. The development of and decision on ESU-wide population scenarios provide a good opportunity for policy input from subbasin and recovery planners.

In addition to biological recovery goals, NMFS needs to have criteria for evaluating whether the factors for decline have been fixed. The package of biological (or viability criteria) and factors for decline criteria together are the minimum set of improvements that we need for delisting.

Recovery goals should also evolve into ?broad sense? recovery goals that go beyond mere viability and provide for sustainable fisheries and other uses. It is NMFS?  hope that those involved in local recovery planning will participate in the development of these ?broad sense? recovery goals. It is likely that in the first round of subbasin planning for at least some subbasins,  the ESU-wide relationship of the populations will not be decided upon, and the broader sense recovery goals will not have been developed. In these cases, local recovery plans should address goals for their individual populations. In cases where the full suite of viability criteria (abundance, productivity, spatial distribution and diversity) are not ready, then apply the interim targets issued in our April 4, 2002 letter to the Council. These interim criteria should be applied with the understanding that they do not include all of the viability criteria,  factors for decline criteria  nor broad sense recovery. < return to text

11. Address within subbasin/watershed habitat, artificial production and local harvest management.

It is important to look at the relationship of habitat and production together. < return to text

12. Identify and prioritize specific actions (including programs) at the subbasin scale.

Some strategies and actions do not need finer scale assessment and planning before site specific choices are made. These actions are appropriately reviewed and determined at the subbasin scale; such actions might address tributary hydropower or water storage projects and artificial production programs. < return to text

13. Identify and prioritize specific strategies or actions (including programs) at the watershed (finer) scale where possible.

Where finer-scale assessments and plans are available, they should be used and referenced in the earliest rounds of subbasin planning. A key issue is the statute's requirement that recovery plans include site specific actions. It would be very difficult and not very effective for NMFS to determine site specific actions at the scale of a recovery plan. Recovery plans need to point to  A process that 'steps down? the subbasin scale to the finer scale for decision-making. NMFS is looking to the states and tribes who are doing finer-scaled and detailed subbasin assessment and planning to provide guidance about how this step down should work. < return to text

14. Include an analysis of whether the existing and proposed programs and actions will achieve the recovery goals.

For starters, the strategies and actions need to be evaluated against the priorities that are apparent through assessments that include limiting factor analyses. The relationship between available data, the assumptions used, the analyses, and decisions made about actions needs to be transparent. NMFS will work with its science partners in efforts to provide quantitative tools for this analysis. < return to text

15. Include a monitoring program and adaptive management program.

It is crucial that monitoring be integrated across programs and land ownerships in the planning area. It is also crucial that monitoring in the local plan area fits with larger-scale monitoring at the ESU and statewide scales. < return to text

NMFS Recovery Plan Guidelines

[This is an attachment to NMFS' letter to the Council on the relationship between subbasin planning and the Endangered Species Act. Bold formatting added by Council for faster web viewing.]

The following guidelines are generally applicable to any local recovery planning effort in Oregon, Washington and Idaho at the scale of the subbasin. For ease of application by subbasin planners participating in the Council's program, they are organized here according to the outline of the Council's Technical Guide for Subbasin Planners. There is nearly complete overlap with the Council's Technical Guide. We have noted the instances where the NMFS? guidelines may go further due to NMFS? statutory obligations or where additional explanation is warranted.

I. Technical Guide Introduction

1. Include a schedule for revising and updating the plan, based on new information (e.g. a description of the Fish and Wildlife Program rolling provincial reviews). annotation >

2. Include participation by entities with the appropriate authorities, responsibilities and interests to implement conservation actions. annotation >

II. Technical Guide Subbasin Assessment

3. Identify the plan area and its relationship to the affected populations and ESUs. annotation >

4. Use an accepted technical assessment template such as the subbasin assessment template for the Northwest Power Planning Council's Fish and Wildlife Program. annotation >

5. Identify and classify finer-scale watersheds that are priorities for protection, and restoration, or other strategies. annotation >

6. Describe assumptions about conditions and actions outside the local plan area (e.g. ocean survival). annotation >

7. Identify factors limiting recovery; be as specific as possible by applying limiting factors analyses to specific life cycle stages. annotation >

III. Inventory of Existing Activities

8. Identify existing local management programs and evaluate their ability to fix the limiting factors and factors for decline and to meet recovery goals. Identify inadequacies in either design or implementation. Identify inadequacies in either design or implementation. The ESA statute and case law require NMFS to review the inadequacies of existing regulatory mechanisms when it makes delisting decisions. annotation >

9. Include measurable objectives or criteria for fixing the limiting factors and the factors for decline. The statute obligates NMFS to have these as part of delisting criteria. This goes beyond what is in the Technical Guide. annotation >

IV. Management Plan

10. Incorporate biological recovery goals for the ESUs and populations in the plan area. Where these have not yet been developed,  incorporate NMFS? interim targets. annotation >

11. Address within subbasin/watershed habitat, artificial production and local harvest management strategies. annotation >

12. Identify and prioritize specific actions (including programs) for both protection and restoration at the subbasin scale. This goes beyond the strategies described in the Technical Guide due to the ESA's requirement to express site specific actions. This is a problem that NMFS and Council staff are working on. annotation >

13. Identify and prioritize specific strategies or actions (including programs) for both protection and restoration at the watershed (finer) scale where possible. This goes beyond the strategies in the Technical Guide. To the extent that actions have been defined through planning and assessment at finer scales, those actions should be incorporated or referenced. annotation >

14. Include an analysis of whether the existing and proposed programs and actions will achieve the recovery goals. The Technical Guide requires an explanation of the linkage between strategies and objectives. This guideline underscores the need for a transparent relationship between the technical information, analyses and decisions about actions. This goes beyond the Technical Guide, which requires an explanation of the linkage between strategies and objectives. This guideline calls for a more specific analysis that relates the package of strategies to achievement of recovery goals. annotation >

15. Include a monitoring program and adaptive management program.  annotation >

Guidelines Annotated

1. Include a schedule for revising and updating the plan, based on new information.

The initial rounds of local recovery planning are not expected to be perfect. Initial rounds need to be based on existing information. As we do assessments, we will find that existing information leaves us with critical uncertainties and data gaps. Research and monitoring needs to be directed toward filling those gaps. Also, as the ESU scale of recovery planning evolves, it will provide additional context for the subbasins and the independent populations. Local recovery plans should be viewed as iterative documents that can adapt to new information and that will become more sophisticated with time. < return to text

2. Include participation by entities with the appropriate authorities, responsibilities and interests to implement conservation actions.

Entities with the responsibilities and authorities to implement actions that affect salmon and steelhead need to participate in the development of local recovery plans. Ideally, all such relevant entities would provide assurances that their part of the plan will be implemented so that all participants can rely on that implementation. < return to text

3. Identify the plan area.

The plan area may be smaller or larger than populations or ESUs. In any case, the relevance of the plan area to the population structure of listed fish needs to be clear. < return to text

4. Use an accepted technical assessment template, such as the subbasin assessment section for the Northwest Power Planning Council's Technical Guide for Subbasin Planners.

There are several assessment methods available. NMFS? primary concerns are that the assessments answer key questions and that they are og good quality. The list of questions the assessments should answer is in the Council's Technical Guide. There also needs to be quality assurance criteria for assessments. < return to text

5. Identify and classify finer-scale watersheds that are priorities for protection, restoration or other strategies.

It is difficult to make technically credible site-specific choices from the subbasin perspective. A closer look is needed. In many cases, finer-scale assessment and planning will provide the level of resolution needed for planning and implementing specific actions. Where finer-scaled plans are available, they should be recognized and used or referenced in the subbasin plan. Where finer-scaled plans are not available, the subbasin assessment will help indicate which areas should be prioritized for finer-scale assessment and funding through state, federal, Council and other programs. < return to text

6. Describe assumptions about conditions and actions outside the local plan area.

There are many influences on salmon survival outside the subbasin/watershed area. It is important that subbasin planners use a consistent set of assumptions regarding these influences. NMFS, in coordination with regional experts, will provide a set of assumptions that should be consistently applied across the populations in an ESU. Such assumptions will include natural and climatic variability, survival through hydropower systems, ocean and mainstem fishing mortality, and estuarine survival. < return to text

7. Identify factors limiting recovery, be as specific as possible.

The more specific limiting factors descriptions are, the more useful they will be for targeting priority actions that are meaningful to fish at key life history stages. There are many limiting factors analyses already complete or underway. NMFS? concern is that some of the limiting factor analyses may be quite general and need additional specificity. At any rate, existing analyses should be used and enhanced as needed through the subbasin assessment and TRT process. < return to text

8. Identify existing local management programs and evaluate their ability to fix the limiting factors and factors for decline and to meet recovery goals. Identify inadequacies in either design or implementation.

There are many restoration programs sponsored by tribes, states, federal agencies and local governments and nongovernmental organizations. It is important to look at these as a package, along with the programs that manage land and water in the affected area. While many state, federal and local land and water management programs have improved, there are still daily management actions that continue to degrade the environment. The benefit of restoration programs can best be measured if we know what is protected and whether the environment will stay the same or continue to degrade. < return to text

9. Include measurable objectives or criteria for fixing the limiting factors and the factors for decline.

NMFS? delisting criteria need to include not only biological delisting criteria, but also criteria for addressing the factors for decline. Most of the ESUs in the Columbia River were listed due to a combination of all five statutory listing factors:

1. present or threatened destruction, modification or curtailment of habitat or its range;
2. over-utilization;
3. disease or predation;
4. inadequacy of existing regulatory mechanisms;
5. other natural or manmade factors;

In its recovery guidance for West Coast salmonids, NMFS calls these criteria ?administrative criteria? as opposed to biological criteria.  < return to text

10. Incorporate biological recovery goals for the ESUs and populations in the plan area, as developed through the Technical Recovery Teams, working with local planners. Where these have not yet been developed, incorporate NMFS? interim targets.

First, identify ESUs and populations within the plan area. Then, apply biological viability goals developed through the TRT process. These viability goals are meaningful when viewed as a package of: abundance, productivity, spatial distribution and genetic diversity. Biological recovery goals will also ultimately need to be developed and applied ESU-wide, meaning that the individual populations will be looked at together for ESU-wide population scenarios. The development of and decision on ESU-wide population scenarios provide a good opportunity for policy input from subbasin and recovery planners.

In addition to biological recovery goals, NMFS needs to have criteria for evaluating whether the factors for decline have been fixed. The package of biological (or viability criteria) and factors for decline criteria together are the minimum set of improvements that we need for delisting.

Recovery goals should also evolve into ?broad sense? recovery goals that go beyond mere viability and provide for sustainable fisheries and other uses. It is NMFS?  hope that those involved in local recovery planning will participate in the development of these ?broad sense? recovery goals. It is likely that in the first round of subbasin planning for at least some subbasins,  the ESU-wide relationship of the populations will not be decided upon, and the broader sense recovery goals will not have been developed. In these cases, local recovery plans should address goals for their individual populations. In cases where the full suite of viability criteria (abundance, productivity, spatial distribution and diversity) are not ready, then apply the interim targets issued in our April 4, 2002 letter to the Council. These interim criteria should be applied with the understanding that they do not include all of the viability criteria,  factors for decline criteria  nor broad sense recovery. < return to text

11. Address within subbasin/watershed habitat, artificial production and local harvest management.

It is important to look at the relationship of habitat and production together. < return to text

12. Identify and prioritize specific actions (including programs) at the subbasin scale.

Some strategies and actions do not need finer scale assessment and planning before site specific choices are made. These actions are appropriately reviewed and determined at the subbasin scale; such actions might address tributary hydropower or water storage projects and artificial production programs. < return to text

13. Identify and prioritize specific strategies or actions (including programs) at the watershed (finer) scale where possible.

Where finer-scale assessments and plans are available, they should be used and referenced in the earliest rounds of subbasin planning. A key issue is the statute's requirement that recovery plans include site specific actions. It would be very difficult and not very effective for NMFS to determine site specific actions at the scale of a recovery plan. Recovery plans need to point to  A process that 'steps down; the subbasin scale to the finer scale for decision-making. NMFS is looking to the states and tribes who are doing finer-scaled and detailed subbasin assessment and planning to provide guidance about how this step down should work. < return to text

14. Include an analysis of whether the existing and proposed programs and actions will achieve the recovery goals.

For starters, the strategies and actions need to be evaluated against the priorities that are apparent through assessments that include limiting factor analyses. The relationship between available data, the assumptions used, the analyses, and decisions made about actions needs to be transparent. NMFS will work with its science partners in efforts to provide quantitative tools for this analysis. < return to text

15. Include a monitoring program and adaptive management program.

It is crucial that monitoring be integrated across programs and land ownerships in the planning area. It is also crucial that monitoring in the local plan area fits with larger-scale monitoring at the ESU and statewide scales. < return to text