May 20, 2000

Frank L. Cassidy, Jr.
Chairman NWPPC
Northwest Power Planning Council
851 S. W. Sixth Avenue, Suite 1100
Portland, OR 97204-1348

The Confederated Tribes of the Umatilla Indian Reservation (CTUIR) is submitting recommendations for amendment of the anadromous fish portion of the Program through the Columbia River Intertribal Fish Commission. The attached document represents the CTUIR’s recommended direction pertaining to the wildlife sections of the Program. We respectfully submit these issues with the expectation that the Council’s staff will craft appropriate program language to meet our intent.

Thank you for the opportunity to provide input the amendment process. If you have any questions regarding our recommendations, please contact either Gary James, Fisheries Program Manager or Carl Scheeler, Wildlife Program Manager, at (541) 278-5298.

Jay Minthorn
Chairman, Fish and Wildlife Committee

Cc: BOT, DNR
 
 

• The CTUIR supports the funding of the Key Ecological Function Project proposed by Dr. D. H. Johnson as a credible means of integrating terrestrial and aquatic systems function analysis needed for a true multi species mitigation effort.

• The CTUIR supports the establishment of trust funds at a project, state or sub-regional basis, as a means of establishing perpetual operations and maintenance funds for existing and future wildlife mitigation projects.

• The CTUIR supports the establishment of trust funds as a means of establishing a flexible funding base for managers to protect important fish and wildlife habitats through acquisition, lease or easements.

• The current Program should be retained in the new program until replaced by subbasin plans.

• Credit projects not specifically designed to mitigate for defined wildlife construction/inundation losses (e.g., watershed projects, fish habitat projects) against secondary losses.

• Habitat units will be the preferred unit of measurement for construction and inundation mitigation accounting unless the region's wildlife managers agree to another method that, in the Council's opinion, adequately takes into account both habitat quantity and quality adequate to mitigate for the identified losses.

• Baseline protection credits in the form of habitat units (HU’s) will be granted to BPA for each habitat area protected or secured in perpetuity for mitigation. The determination of baseline protection credits should continue to be made through the application of the Habitat Evaluation Procedures (HEP) methodology. Baseline protection credits will be granted to BPA at the rate of one HU credit for every three HU’s protected. (This ratio is the Wildlife Managers consensus alternative for baseline protection crediting of wildlife acquisition projects.).

• Habitat enhancement credits will be provided to BPA when habitat management activities made possible through BPA provided funding lead to a net increase in habitat value when compared to the level identified in the most recent habitat inventory. This determination will be made through the periodic monitoring of the project site via the habitat evaluation technique referred to as Habitat Evaluation Procedures (HEP). BPA will be credited for habitat enhancement efforts at a ratio of one habitat unit (HU) credited for every one net habitat unit (HU) gained (1:1).

• Habitat units gained through the construction, inundation or operation of the basin's hydroelectric facilities should be recognized. The creation of new habitats does not replace the functions provided by the habitat types directly impacted by hydropower development. These gains are best suited for crediting to the secondary and operational components of the Program.

• The Council's Program will address and mitigate the direct and indirect impacts of the "hydropower facilities" in the broad sense that Congress intended, including all effects traceable to any of the projects' purposes (i.e., construction and inundation, operational, and secondary impacts).

• Wildlife Mitigation Projects should provide permanent protection or enhancement of wildlife habitat in the most cost-effective manner.

• The hydropower system must protect, mitigate and enhance wildlife to the extent affected by FCRPS. This obligation will be discharged when these effects are fully addressed, i.e., when mitigation actually offsets the loss caused by a hydropower facility, and when the operator provides adequate operation and maintenance funding to sustain the mitigation in perpetuity. Funding for monitoring and evaluation will be used to determine if the predicted benefits were realized.

• The Program should specify that any and all wildlife losses are fully mitigated only when Bonneville provides operations and maintenance funding over the life of the project or in perpetuity. Mitigation projects that seek a different arrangement for long-term operations and maintenance funding other than from Bonneville should be approved by the Council.

• Trust/settlement agreements and other mitigation programs shall demonstrate consistency with mitigation goals, objectives, and methods.

• Wildlife mitigation assessments should use the Habitat Evaluation Procedures with annualization.

• Mitigation programs should protect high quality or highly restorable native or other habitat or species of special concern, whether at the project site or not, including endangered, threatened or sensitive species.

• Mitigation programs should provide riparian or other habitat that can benefit both fish and wildlife.

• Mitigation programs should complement the activities of the region's state and federal fish and wildlife agencies and Indian tribes.