*UPPER COLUMBIA UNITED TRIBES*

910 N. Washington, Suite 107

Spokane, Washington 99201

![](media/image3.png){width="2.1458333333333335in"
height="0.8958333333333334in"}(509) 838-1057

Colville \* Coeur d'Alene \* Kalispel \* Kootenai \* Spokane

August 11, 2004

Judi Danielson, Chair

Northwest Power and Conservation Council

851 S.W. Sixth Avenue, Suite 1100

Portland, Oregon 97204-1348

RE: Comments on Subbasin Plans in the Upper Columbia Ecoregion

Dear Ms. Danielson:

This letter is submitted as comments from the UCUT member Tribes, to
provide additional information concerning the measures submitted by UCUT
in May as components of the Intermountain Province (IMP) subbasin plans.
Our continued support for the six IMP subbasin plans (Coeur d' Alene,
Upper Columbia, Lake Rufus Woods, Pend Oreille, San Poil, and Spokane)
is strongly tied to the NPCC\'s adoption of these measures. Likewise, we
support the Kootenai River, Okanogan, and Upper Columbia Mainstem
subbasin plans with the expectation that \"strategies\" (measures) in
these plans will be adopted into the Council\'s Fish & Wildlife Program.

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We have participated in and support the full adoption of subbasin plans
in the Upper Columbia ecoregion as submitted to the NPCC for amendment
into its Fish and Wildlife Program, with UCUT measures as essential
components. We have made sure that all UCUT measures are supported by
and consistent with the subbasin plans, and have tied them directly to
objectives and strategies that are contained within the subbasin plans.
These measures were developed in coordination with other Fish and
Wildlife Managers and are not in conflict with their efforts or
strategies within the subbasin plans.

Ms. Judi Danielson

August 12, 2004 Page 2.

It is the UCUT position that, without specific measures, the subbasin
planning effort fails to meet specific requirements of the Act and
judicial interpretations of the Act. It is our recommendation that the
Council adopt these measures as submitted. If the NPCC chooses not to
accept our recommendations, the Act requires the NPCC to fully explain,
in writing, why it acted in opposition to the recommendations of these
tribes.

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In deliberations among UCUTs\' fish and wildlife managers - who
collectively have substantial expertise and many years of experience
implementing BPA-funded projects - we have assessed the measures with
regard to BPA's obligations and responsibilities for fish and wildlife
mitigation in the Upper Columbia River ecoregion. It is our
carefully-considered determination that full implementation of these
measures is necessary to remain consistent with the NW Power Act and
Fish and Wildlife Program Policies.

Further, our experienced managers have conservatively estimated the cost
of implementing these measures at a reasonable and achievable pace of
implementation. Full implementation of measures in the InterMountain
Province and Kootenai River, Okanogan, and Upper Mainstem subbasins will
require designated funding averaging approximately \$52 million annually
(combined capital and expense) over the next 10 to 15 years. The
spreadsheet attached to this letter summarizes the annual costs
associated with implementation of these measures. These estimates
incorporate funding for some of the Tribes\' planning and management
partners. We have attempted to organize measures into Habitat-Aquatic,
Habitat-Terrestrial, Program Support, Harvest and Artificial Production
categories, to be consistent with categories under consideration in
MOAII workgroups. We feel strongly that this is a practical figure based
upon a reasonable pace of implementation to continue short and long-term
benefits to this eco-region.

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We look forward to working with the NPCC members and staff, the
Independent Scientific Review Panel, and the Bonneville Power
Administration to ensure the measures are understood and incorporated in
the Fish and Wildlife Program. Please do not hesitate to contact UCUT
Central Office or member Tribes to further discuss issues related to the
subbasin plans, our collective measures, and budget estimates.

Ms. Judi Danielson

August 12, 2004 Page 3.

Thank you for your attention to this important matter.

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Sincerely,

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Warren Seyler,

Chairman, UCUT

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Enclosure

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cc: Jim Kempton

Melinda Eden

Gene Derfler

Ed Bartlett

John Hines

Frank "Larry" Cassidy

Tom Karier