Sierra Club 
Columbia Basin Field Office
2703 Klemgard Road
Pullman, WA 99163
(509) 332-5173
FAX: (509) 332-1513
sierraclub@pullman.com

May 12. 2000

Northwest Power Planning Council
Larry Cassidy, Chairman
851 S.W. Sixth Ave., Suite 1100
Portland, OR 97204

RE: Recommendations for Columbia Basin Fish and Wildlife Program

Dear Sirs:

On behalf of the Sierra Club, this letter provides recommendations for the comprehensive revision by the Northwest Power Planning Council of the Columbia River Basin Fish and Wildlife Program. Although our focus remains at the Basin level, these recommendations otherwise follow the format requested by the Council offering recommendations for (a) a vision for the Fish and Wildlife Program, (b) biological objectives, (c) strategies for achieving the vision and objectives, (d) a general scientific framework, (e) a criterion for prioritizing fish and wildlife projects, and (f) improvements In program management, evaluation and coordination.

A. Vision

The Columbia River Basin Fish and Wildlife Program should (1) prevent any further extinctions of species or genetically differentiated subspecies of fish and wildlife; (2) recover anadromous and resident fish populations to sustainably harvestable numbers; (3) fully comply with all applicable federal laws and treaty obligations as well as state laws, state fish and wildlife programs, and tribal fish and wildlife programs; and (4) invest strategically in infrastructure to maintain or strengthen the regional and local economy.

With specific regard to the federal Endangered Species Act, the Program should prevent any further listings of fish and wildlife in the Columbia Basin, and seek the de-listing of threatened and endangered fish and wildlife. And with specific regard to the federal Clean Water Act, the Program should require compliance by the U.S. Army Corps of Engineers at its four Lower Snake River dams.

B. Biological Objectives

(1) Reproductive Success: Productivity of all fish and wildlife should reach population replacement in all years, and for declining species, population increase in most years. For anadromous fish specifically, stocks of salmon and steelhead should achieve a smolt-to-adult survival ratio of 2 percent in all years, and 4-6 percent in most years.

(2) Habitat: The Program should result in healthier, more diverse, more productive, and better connected habitats for fish and wildlife.

C. Strategies

Based upon the best available biology, the Sierra Club respectfully recommends the following actions in the "4Hs" of human impacts hydropower, habitat, hatcheries, and harvest.

(1) Hydropower

• Partial removal of the four Lower Snake dams;
• Permanent spillway crest drawdown of the John Day reservoir;
• Immediate termination of juvenile fish transportation by truck, and phasing out of fish barging;
• Dam and reservoir passage Improvements at the four Lower Columbia and the five mid-Columbia mainstem projects, including controlled spill for juvenile fish passage;
• Flow augmentation in the Columbia and Snake Rivers; and
• Strategic Investments in energy conservation and renewables, transportation infrastructure, and Irrigation pumping facilities in order to mitigate economic impacts, if not strengthen the regional and local economy.

• Partial removal of the four Lower Snake dams;
• Permanent spillway crest drawdown of the John Day reservoir;
• Near-term protection or restoration of riparian zones on all fishbearing streams in public lands:
• Long-term protection or restoration of riparian zones on all fishbearing streams in private lands;
• Establishment of 300-foot natural buffers on all anadromous and resident fish-bearing streams;

• Attainment of water temperatures no higher than 68 degrees Fahrenheit on all coldwater anadromous and resident fishbearing streams;
• Protection from sedimentation of all coldwater anadromous and resident fish-bearing streams;
• Maintenance or achievement of high water quality and quantity throughout the Columbia Basin;
• Retention of the "Protected Areas" rule;
• Protection and restoration of anadromous fish rearing habitat in the Columbia estuary, and cancellation of deepening of the sea navigation channel; and
• Strategic investments in land purchases, purchases of water rights, conservation easements, incentives, and infrastructure in order to implement habitat restoration at the fastest possible rate.

• Operation of hatcheries for species conservation and diversity, mitigation, and research; and
• Reduction of artificial fish production as fish populations and harvests recover.

• Maintenance of harvest for American Indian Tribes consistent with treaty rights;
• Promotion of selective harvest targetted on hatchery fish;
• Establishment of harvest rates and regimes for adult escapement by wild fish; and
• Strategic investments in new techniques to implement selective harvest.

According to the most basic ecological principle, a species will survive and thrive to the extent that it is provided the environmental conditions in which that species evolved. The Columbia Basin environment has been massively altered by humankind. Therefore, the Fish and Wildlife Program should rigorously follow this basic ecological principle of providing and restoring healthier, more diverse, more productive, and better connected habitats for fish and wildlife. For anadromous and resident fish, the Program should adopt the "normative river" concept of the Independent Scientific Group (1996), and should reject technological fixes.

E. Criteria for Prioritizing Fish and Wildlife Projects

Priority should go to fish and wildlife projects (1) which protect and restore healthier, more diverse, more productive, and better, connected habitats for fish and wildlife, (2) which do not rely upon technologies, and (3) which implement the "normative river" concept.

F. Improvements in Program Management, Evaluation, and Coordination

The Northwest Power Planning Council should carefully and fully implement section 4(h) of the Northwest Power Planning Act, particularly section 4(h)(6)(B) that all Fish and Wildlife Program measures "will complement the existing and future activities of the Federal and the region's State fish and wildlife agencies and appropriate Indian tribes."

Thank you for this opportunity to offer recommendations for the comprehensive revision of the Council's Fish and Wildlife Program. If you have questions or need further Information, please do not hesitate to contact us.

Sincerely,

[for] Edwina Allen
Northwest Regional Vice-President

[for] Bill Arthur
Northwest Regional Director
Sierra Club
 

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