May 12, 2000

Mr. Mark Walker
Director of Public Affair
Northwest Power Planning Council
851 SW Sixth Avenue, Suite 1100
Portland, Oregon 97204

Dear Mr. Walker:

The Washington State Department of Fish and Wildlife (WDFW) and the Governor’s Joint Natural Resources Cabinet* (JNRC) have the following recommendations for amendments to the Fish and Wildlife Program (Program) relative to salmon recovery. You will also be receiving recommendations covering all aspects of fish and wildlife management from WDFW. The Northwest Power Planning Council (Council) requested amendment recommendations under Section 4(h)(2) of the Northwest Power Planning Conservation and Electric Act (the "Act") in a letter dated January 12, 2000.

Regional Coordination Issues

The Council’s "strawman" document is relatively silent on the issue of coordination between the Council’s Subbasin Plan for Fish and Wildlife and the state’s salmon recovery strategy. We believe that the coordination of these major undertakings is one of the most important challenges facing the Columbia Basin region. For example, in Washington there is broad overlap between issues addressed by the Council’s Program and those addressed by the state Salmon Recovery Funding Board. There is also considerable overlap between current state funded watershed planning efforts and those proposed by the Council. It also appears that the Council’s subbasin assessment process duplicates current state watershed assessment efforts already underway in many of the watersheds in the Columbia Basin. We are very concerned that unless there is coordination, both on the ground and at the policy level, between the state’s efforts and those of the Council, there will be major confusion among local governments, citizens and tribes. We strongly encourage you to work with JNRC, which includes WDFW, in order to ensure that there is meaningful coordination between the Council’s Fish and Wildlife Program and the state’s salmon recovery strategy.

Subbasin Plans

The central focus of the Program should be subbasin plans: what they are; how they are created and amended into the Program; and how they affect fish and wildlife actions in the Columbia River Basin. The Elements of a subbasin plan section in the "strawman" describes this well, and we concur with it.

That being said, the state is very concerned by the Council proposal, as outlined in the April 11, 2000 clarification letter, for an abbreviated subbasin planning process. Initially, the Council conceived a three-year period for development of subbasin plans, consistent with initial implementation of the "rolling review." We regarded that time schedule as a relatively reasonable compromise between timeliness and quality. The April 11 letter outlined a drastically curtailed time frame, with subbasin assessments completed during 2000 and subbasin plans completed by the fall of 2001. We believe the Council is making a fundamental error in approaching subbasin planning on such a short time frame.

The April 11 letter notes that the Council is relying on subbasin plans to provide "specific objectives and action measures" for the Program, and the Council expects that "public involvement … will be critical to the success of the subbasin-planning phase of the program revision." In order to be successful in these efforts, it appears that the Council is expecting the various agencies of Washington State to participate in the development of subbasin assessments and subbasin plans for 34 separate subbasins in eight provinces in the next year-and-a-half. The level of funding to enable such participation remains uncertain at this stage and has not been discussed for agencies other than WDFW. It also appears that Council expectations for state involvement include the compilation and interpretation of technical information, and the facilitation of involvement by local agencies, watershed councils, landowners and others. We agree that these are reasonable expectations by the Council, but we cannot agree that either WDFW or other Washington State agencies can meet those expectations under this timeline, with an uncertain level of funding.

We strongly encourage the Council to reconsider its proposal to shorten the subbasin planning time frame. We believe a three-year time frame is much more realistic given the enormity of the task the Council is preparing to undertake. A more realistic time frame will result in subbasin plans that are credible and, importantly, more likely to have the support of local governments and communities.

Immediate Action Items

The Joint Natural Resources Cabinet, WDFW, federal agencies and others have suggested that as planning and studies continue, immediate actions may be necessary to forestall further declines in Columbia River Basin fish and wildlife. Authority for these high priority, early actions comes as a part of the trust responsibilities of the federal government to the tribes and from responsibilities under the Endangered Species Act and the Clean Water Act.

In order for projects to meet the definition of "immediate actions", we recommend that the Council expedite their review process and that applicants ensure that all assessments and planning (e.g., NEPA) work should be completed so the project can begin as soon as possible in 2001. In addition, Washington recommends that projects need to meet one or more of the following threshold criteria:

1. Action is necessary to reduce imminent risk to state or federally listed species or their habitat.
2. Action will secure high quality or critical habitat, or will provide connectivity between patches of high quality or critical habitat, and the habitat is at imminent risk of alteration.
3. Action will result in immediate improvement in native resident fish, anadromous fish or wildlife survival. Actions that improve conditions for multiple stocks or populations would have greater urgency.

In response to these criteria, Washington State agencies have developed the enclosed list of the types of projects or actions that should be considered for Immediate Action. In the course of compiling this list, we received and reviewed some proposals from other organizations that also show considerable merit, and they are included as well. These are projects that are "ready to go today" type actions that ranked highly in a preliminary state-level screening process. We want to emphasize that we intend this list to provide the Council and others with an indication, not recommendation, of the nature and relative cost of the projects that should result from implementation of an Immediate Action program.

Sincerely,

Jeff Koenings, Director
Curt Smitch, Chair
Washington Department of Fish and Wildlife Joint Natural Resources Cabinet

cc: Joe Dear, Chief of Staff, Office of the Governor
Bob Nichols, Senior Executive Policy Advisor, Office of the Governor
Joint Natural Resources Cabinet
Enclosure

*The Joint Natural Resources Cabinet, created by the Governor to develop and implement the state’s salmon recovery strategy, consists of the following agencies: Agriculture, The Conservation Commission, Community Trade and Economic Development, Ecology, Fish and Wildlife, InterAgency Committee for Outdoor Recreation, Northwest Power Planning Council, Parks and Recreation, Puget Sound Water Quality Action Team, and Transportation.

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