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| ! |           | ## Department of Energy    |          |           |   |
| [ |           |                            |          |           |   |
| ] |           | Bonneville Power           |          |           |   |
| ( |           | Administration\            |          |           |   |
| m |           | P.O. Box 3621              |          |           |   |
| e |           |                            |          |           |   |
| d |           | Portland, Oregon           |          |           |   |
| i |           | 97208-3621                 |          |           |   |
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|   |           |                            |          |           |   |
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|   | June 21,  |                            |          |           |   |
|   | 2002      |                            |          |           |   |
|   |           |                            |          |           |   |
|   | In reply  |                            |          |           |   |
|   | refer to: |                            |          |           |   |
|   | KEW-4     |                            |          |           |   |
+---+-----------+----------------------------+----------+-----------+---+

Mr. Frank L. Cassidy, Chairman

Northwest Power Planning Council

851 SW Sixth Avenue, Suite 1100

Portland, OR 97204

Dear Chairman Cassidy:

Enclosed is the first set of our funding decisions on the Blue Mountain
and Mountain Snake Provinces' fish and wildlife mitigation and recovery
proposals submitted through the Northwest Power Planning Council's
(Council) provincial review process. We have decided to segment our
funding decisions in order to move projects forward in a timely manner
when there are no issues pending. The enclosed table presents the
decision on all projects. As indicated in the table we are deferring a
final funding decision for the small subset of wildlife land acquisition
and U.S. Forest Service (USFS) related habitat projects identified in
this letter. We are gathering additional information from the USFS or
the project sponsors prior to making final decisions. We anticipate
finalizing these decisions on proposed projects on USFS land within the
next two weeks. We will make decisions on other outstanding projects as
the requested information is provided, and anticipate that a full Blue
Mountain and Mountain Snake Provincial decision will be completed in
early July.

On February 11, 2002, we sent you our fiscal years (FY) 2002 through
2004 Blue Mountain and Mountain Snake Provincial proposal solicitation
comments. Our review made an effort to integrate the fish and wildlife
mitigation needs identified in the Council's Fish and Wildlife Program
(Program) with the needs of Bonneville regarding implementation of the
National Marine Fisheries Service's (NMFS) and U.S. Fish and Wildlife
Service's (FWS) 2000 Biological Opinions (BiOp) on the operation of the
Federal Columbia River Power System (FCRPS).

On April 3, 2002, the Council adopted their funding recommendations and
on April 19, 2002, the final recommendations were sent to Bonneville and
posted on the Council's Web site. Since that time, we reviewed the
Council's recommendations and held several discussions with the Council,
the Idaho Office of Species Conservation (IOSC), and project sponsors
regarding project-specific issues. We concur with the vast majority of
Council recommendations as presented but we are not in complete accord
in the following areas discussed here.

> **1. Wildlife Habitat Acquisition Projects**
>
> Our initial recommendation was not to fund the following five projects
> due to the existing level of mitigation achieved for wildlife for the
> Lower Snake River and Dworshak dams:

a.  Proposal No. 28010 -- Nez Perce River Terrestrial

b.  Proposal No. 28018 -- Lower Salmon River Tributary Protection and
    Enhancement

c.  Proposal No. 28021 -- Lower Clearwater Habitat Enhancement Project

d.  Proposal No. 27023 -- Precious Lands Wildlife Habitat Expansion

e.  Project No. 2000-021-00 -- Securing Wildlife Mitigation Sites --
    Oregon, Ladd Marsh WMA Additions

> While we understand that the project sponsors have significantly
> reduced the scope of these initial projects, the larger concern
> remains with respect to available wildlife mitigation credits. In
> recognition of the ongoing crediting discussions under the auspices of
> the Council's Wildlife Crediting Subcommittee and in the interest of a
> collaborative approach to this issue, we are discussing with the
> project sponsors our willingness to evaluate these revised proposals
> to determine whether they contain actions that will implement RPA 150
> of the NMFS 2000 Biological Opinion. If so, these projects may be
> eligible for RPA 150 "crediting" toward Bonneville's responsibilities
> for habitat enhancement under this RPA, as identified in the Action
> Agencies' Implementation Plan, and for mitigation under the Northwest
> Power Act.
>
> We intend to withhold our decision on these five revised projects
> pending receipt of additional information from the project sponsors on
> the specific proposed habitat acquisitions and following field visits
> by Bonneville staff to verify their applicability and contribution to
> RPA 150.

2.  **U.S. Forest Service Related Habitat Projects**

> We would like to express our appreciation to the USFS for their
> cooperation in reviewing project proposals that involve actions on
> Federal lands for which the USFS is anticipated to provide a
> cost-share. Bonneville is deferring funding decisions on the following
> eight projects that in whole, or in part, are on USFS lands while we
> complete a review of the information requested from USFS.

a.  Proposal No. 27022 -- Wallowa Culvert Inventory

b.  Proposal No. 28047 -- Protect and Restore Red River Watershed

c.  Proposal No. 28048 -- Protect and Restore Crooked Fork Creek to Colt
    Killed Analysis Area

d.  Project No. 1996-077-02 -- Protect and Restore Lolo Creek Watershed

e.  Project No. 1996-077-03 -- Restoring the Waw'aatamnima (Fishing)
    (Squaw) Creek to Imnaamatnoon (Legendary Bear) (Papoose) Creek
    Watershed Analysis Area

f.  Project No. 2000-034-00 -- Protect and Restore the North Lochsa Face
    Analysis Area Watersheds

g.  Project No. 2000-035-00 - Rehabilitate Newsome Creek Watershed -
    South Fork Clearwater River

h.  Project No. 2000-036-99 - Protect & Restore Mill Creek

> For the remainder of the projects on Federal lands that the Council
> recommended for funding, the project sponsor and the USFS have
> supplied information to Bonneville verifying the USFS cost share and
> project priorities relative to USFS planning. The information also
> verifies their ability to complete the projects within the estimated
> time frames, complete project deliverables, and address questions on
> augmentation of appropriations and Environmental Assessments at the
> Watershed Scale (EAWS). We will move forward with these projects at
> this time.
>
> **3. Research, Monitoring and Evaluation Projects**
>
> As you know, there is an ongoing effort to develop the framework for a
> regional RM&E plan to provide guidance for developing, prioritizing,
> integrating, analyzing and using RM&E on a comprehensive Columbia
> River Basin scale to meet the NMFS and FWS 2000 Biological Opinion
> responsibilities. Our comments on RM&E projects generally indicated
> our preference for delaying the initiation of new work until a
> regional RM&E plan has been developed.
>
> Given the Program's current extensive RM&E funding, it is essential
> that RM&E projects be managed to provide common protocols for data
> gathering and reporting and clear and prioritized questions for
> resolution through research. Protocols for the use of appropriate
> analytical tools, and integration of RM&E in the Basin such that the
> results can inform regional decision-making should also be provided.
>
> We intend to work with the project sponsors to implement the projects
> below (in part or in full depending on contract negotiations) with the
> following requirements:

1)  Statements of work and budgets will be developed in coordination
    with NMFS and Bonneville and may be revised as the needs of RPAs 180
    and/or 183 are clarified; and

2)  Project management will require adherence to specific timelines (at
    least annually) for analysis and reporting to serve as the basis for
    additional project modifications and scope changes. Projects also
    may be modified further after the regional RM&E plan is developed.

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a.  Proposal No. 27002 - Assess Salmonids in the Asotin Creek Watershed

b.  Proposal No. 28034 - Chinook Smolt Survival and SAR, South Fork
    Salmon River

c.  Proposal No. 28045 -- Evaluate Stream Habitat Using the Nez Perce
    Tribe Watershed Monitoring and Evaluation Plan

d.  Project 1997-030-00 -- Chinook Salmon Adult Abundance Monitoring.

> **4. Bull Trout Projects**
>
> In our comments, we recommended that the following projects not be
> funded at this time, but should be reviewed after the completion of
> subbasin planning.

a.  Proposal No. 27017 -- Bull Trout Population Assessment and Life
    History Characteristics in Association With Habitat Quality and Land
    Use: Template for Recovery Planning

b.  Project No. 1994-054-00 -- Characterize Migratory Patterns of Bull
    Trout

> Considering our obligation to avoid jeopardy from FCRPS operations and
> to protect, mitigate and enhance fish and wildlife resources affected
> by the construction and operation of the hydropower system, we have a
> continued interest in a clear definition of our FCRPS responsibility
> relative to bull trout tributary projects. Acknowledging that there is
> a role for Bonneville with respect to these projects, we are concerned
> with the rapid expansion of these projects (both current and proposed)
> in advance of a FWS Bull Trout Recovery Plan or subbasin planning.
> Project No. 1994-054-00 serves as an example of this point. Through
> the Columbia Plateau and Middle Snake Provincial reviews, the project
> has been proposed for rapid expansion in scope and level of effort
> from a FY01 funding level of \$387,182 to a proposed FY02 level of
> \$1,550,636 cumulatively across the two provinces. This significant
> expansion, in advance of subbasin planning and the FWS Bull Trout
> Recovery Plan, expected later this year, strikes us as premature.
>
> To address this concern we recommend that the region conduct a forum
> as soon as the FWS Bull Trout Recovery Plan is completed. The goal of
> the forum would be to assess current, proposed and potential future
> projects to determine priorities in relation to bull trout recovery
> goals. We believe it is time to pause on expansion of on-going
> projects and the initiation of new projects until the recovery plan
> can establish clear goals and objectives to guide the Council and
> Bonneville in prioritizing and funding bull trout projects. Therefore,
> we intend to defer consideration of expansion of Project
> No.1994-054-00 and initiation of Project No. 27107 until the
> conclusion of a bull trout forum and subbasin planning.
>
> **5. Salmon Basin Resident Fish Assessment**
>
> Our recommendation of February 11, 2002, that was consistent with both
> Independent Scientific Review Panel (ISRP) and Columbia Basin Fish and
> Wildlife Authority recommendations was not to fund Proposal No. 28030.
> We understand that the Council recommendation has removed all but
> Objective 1 of this project but we continue to believe that it should
> be deferred to the Council's subbasin planning process. As we have
> discussed with the Idaho Office of Species Conservation, we do not
> intend to fund this project at this time.
>
> **6. Consolidated SNAPP**
>
> The ISRP reviewed the consolidated Safety Net Artificial Propagation
> Program (SNAPP) project proposal on May 20, 2002. We are working with
> NMFS and proposal sponsors on a revised work plan that will address
> ISRP concerns and expect that the revised plan will be presented to
> the Fish and Wildlife Committee and the Council at their July meeting
> in Yakima, Washington. We anticipate continuing to work with the
> Council and the ISRP as necessary, and expect to move quickly to
> implement this risk assessment in order to meet requirements of the
> NMFS 2000 BiOp.

The enclosed table presents the Blue Mountain and Mountain Snake
Province projects that appear in the Council's April 19, 2002,
recommendations. The table identifies the Council's recommended FY02
budget for each project and indicates the status of Bonneville's
decision and planned FY02 budget. Where Bonneville suggests a different
FY02 budget, estimates of FY03 and FY04 funding levels are not presented
but will be negotiated over the course of the fiscal year with Council
staff. Otherwise, Bonneville is assuming the same out-year budgets as
has the Council, recognizing the potential for out-year budget changes
based on changing Basin-wide priorities, as influenced by BiOp
implementation planning and subbasin/recovery planning. Relevant
comments are also included for clarification of our rationale where our
decision differs in some way from the Council recommendation or where
particular contingencies or requirements are placed on the project
through adoption of the Council recommendation or by Bonneville's
decisions as described earlier in this letter.

Again, we have used our best efforts to prioritize Bonneville-funded
fish and wildlife mitigation and recovery projects in the Columbia River
Basin given the implemented ecosystem (All-H) approach to mitigation and
recovery that is being implemented and given that the amount of desired
funding for such an approach exceeds that which is available. We want to
ensure our ratepayers that fish and wildlife mitigation and ESA-focused
recovery funding is going to those projects that provide the greatest
biological benefit at the least-cost.

We want to emphasize our appreciation for the extraordinary work the
Council has done in conducting an open and inclusive process of project
proposal review including, of course, independent scientific review. It
is no small effort to ensure the kind of participation and scrutiny of
fish and wildlife proposals that is afforded by the Council's process.
This process enhances the quality and focus of the projects Bonneville
funds under the Council's Program and it provides a tremendous value to
the Region. We also acknowledge the challenges we face together as we
work to integrate the traditional scope of the Council's Fish and
Wildlife Program with the ESA priorities arising from our Implementation
Plans for the 2000 Biological Opinions. Through a collaborative and
flexible relationship, we believe that successful integration can be
achieved to successfully serve both the fish and wildlife interests and
the ratepayers. We look forward to continuing to work with the Council
on this important effort.

We hope that the information contained in this decision letter is
helpful and, as always, are willing to discuss any issues that you may
have with our funding decisions for the Blue Mountain and Mountain Snake
Provinces. Please feel free to give Bob Austin or me a call if you have
any questions or concerns.

Sincerely,

![](media/image2.wmf){width="2.0in" height="0.4236111111111111in"} for

Sarah R. McNary

Director for Fish and Wildlife

Enclosure

cc:

Mr. Larry Dawson, Clearwater National Forest

Mr. Rod Sando, Columbia Basin Fish & Wildlife Authority

Mr. Brian Brown, National Marine Fisheries Service

Mr. Bruce Bernhardt, Nez Perce National Forest

Mr. Doug Marker, Northwest Power Planning Council

Mr. Jeff Blackwood, Umatilla National Forest

Mr. Bill Shake, U.S. Fish and Wildlife Service

Mr. David Heller, U.S. Forest Service -- Region 6

Ms. Linda Ulmer, U.S Forest Service -- Region 1

Ms. Karyn Wood, Wallowa Whitman National Forest