2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 55

Findings on the Recommendations for Mainstem Plan Amendments 

to the 2000 Columbia River Basin Fish and Wildlife Program

appendix B

Introduction

On March 14, 2001, the Northwest Power and Conservation Council1 requested that state and federal fi sh and 

wildlife agencies, Indian tribes and others submit recommendations for amendments to the Council’s 2000 Columbia 

River Basin Fish and Wildlife Program concerning the mainstem Columbia and Snake rivers. A memorandum accompanying the request for recommendations outlined certain points to consider in developing mainstem amendment recommendations. Council Document No. 2001-04.

By the June 15, 2001, deadline for submitting mainstem amendment recommendations, the Council received 

nearly 1,000 pages of recommendations and supporting information from 22 entities and individuals. As 

required by Section 4(h)(4) of the Northwest Power Act, the Council released the recommendations to the 

public for an opportunity for review and comment, until October 2001. Council Document No. 2001-16; http:

//www.nwcouncil.org/library/recommend/mainstem/Default.htm. 

In October 2002, the Council released for public review and comment a draft of proposed mainstem amendments to the fi sh and wildlife program, and at the same time invited further comment on the mainstem amendment 

recommendations originally received. The Council held a number of public hearings in the four states of the Council (Washington, Oregon, Montana and Idaho) and received extensive written comments on the draft amendments 

and the recommendations. Written comments on the draft mainstem amendments and recommendations are posted 

on the Council’s website, at http://www.nwcouncil.org/fw/program/mainstem/2002-16Comments/default.asp. After 

reviewing the recommendations and the comments on the draft mainstem amendments, the Council revised the 

draft and adopted substantive mainstem amendments to the program in April 2003.2

In this section of the program, the Council provides written fi ndings explaining its disposition of the mainstem 

amendment recommendations, as required by Section 4(h)(7) of the Power Act. When the Council rejected a rec1 When the Council issued the call for recommendations, it was known by the name Northwest Power Planning Council. In mid-2003, the 

Council changed the name by which it is known to the Northwest Power and Conservation Council. Both names are short forms of the 

Council’s offi cial legal name, the Pacifi c Northwest Electric Power and Conservation Planning Council.

2 The Council’s fi nal decision on the mainstem amendments occurred more than a year after the Council received the recommendations for 

mainstem amendments. See Northwest Power Act, Section 4(h)(9) (“The Council shall adopt such program or amendments thereto within 

one year after the time provided for receipt of the recommendations.”). The Act does not specify the consequences for failing to meet the 

specifi ed date, nor a procedure for extending the date to act on the recommendations.

In March of 2002, knowing that it would not be able to complete its consideration of and adopt fi nal mainstem amendments within the 

one-year time period, the Council decided, at its regular Council meeting for that month, to adopt a revised schedule that would move 

the completion of the mainstem amendments beyond the one-year date, and provided notice of this decision and its reasons to those 

who submitted recommendations and other interested parties. No recommending party or any one else complained about or challenged 

the Council’s decision to extend the schedule. The reasons given included the fact that the power system operational issues in 2001 

especially were extraordinary, diverting the Council and relevant staff away from being able to give the level of attention to the mainstem 

recommendations that they deserved. Yet the Council, staff and the public needed more time than usual to understand the general system 

planning issues in the context of the reliability crisis of that year. The Council had not been dilatory; the members and staff worked 

consistently on the mainstem plan recommendations and related mainstem issue since receiving the recommendations. Even so, it was not 

possible to complete the mainstem amendment process by mid-June 2002 and provide suffi cient consideration and public attention to the 

proposed amendments.
56 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

ommendation, these fi ndings explain how the Council’s decision comports with the standards in that section of the 

Act. In the course of responding to the recommendations, these fi ndings also address the major issues raised by 

commentors on the draft amendments. References in these fi ndings to the 2003 Mainstem Amendments are to what 

is called the “Pre-Publication Copy,” Council Document No. 2003-04 (April 2003).
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 57

Context and Scope of the Mainstem Amendments

 — General Findings on Recommendations

2000 Fish and Wildlife Program

The mainstem amendments are the second step in what will eventually be a comprehensive revision of the fi sh and 

wildlife program. In the fi rst phase, which resulted in the 2000 Fish and Wildlife Program, the Council reorganized 

the program around a comprehensive framework of scientifi c and policy principles. The fundamental elements of 

the revised program are the vision, which describes what the program is trying to accomplish with regard to fi sh and 

wildlife and other desired benefi ts from the river; basinwide biological objectives, which describe in general the fi sh 

and wildlife population and habitat characteristics needed to achieve the vision; implementation strategies, which will 

guide or describe the actions needed to achieve the desired ecological conditions; and a scientifi c foundation, which 

links these elements and explains why the Council believes certain kinds of actions should result in desired habitat 

conditions and why these conditions should improve fi sh and wildlife populations in the desired way.

The program amendments in 2000 set the stage for the subsequent phases of the program revision process, in 

which the Council will adopt specifi c objectives and strategies for the river’s mainstem and tributary subbasins, 

consistent with the basinwide vision, objectives and strategies in the program and its underlying scientifi c foundation. These fi ndings conclude the adoption of a set of program amendments relevant to the mainstem Columbia 

and Snake rivers. The Council next intends to incorporate specifi c objectives and measures for tributaries into the 

program in locally developed subbasin plans for the more than 60 subbasins of the Columbia River.

The role of the mainstem amendments was described in the 2000 Fish and Wildlife Program, in the section on 

Basinwide Hydrosystem Strategies and in the section entitled Schedule for Further Rulemakings. The Council 

repeated this guidance in the March 14, 2001, request for mainstem amendment recommendations. The mainstem 

amendments are to contain the specifi c objectives and strategies (or measures) for the federal operating agencies 

and others to implement in the mainstem Columbia and Snake rivers to protect, mitigate and enhance fi sh and wildlife affected by the development and operation of hydroelectric facilities while assuring the region an adequate, 

effi cient, economical and reliable power supply. The fi nal amendments thus include objectives and strategies relating to, among other matters:

• the protection and enhancement of mainstem habitat, including spawning, rearing, resting and migration areas 

for salmon and steelhead, resident salmonids and other anadromous and resident fi sh;

• system water management;

• passage spill at mainstem dams;

• adult and juvenile passage modifi cations at mainstem dams;

• juvenile fi sh transportation;

• reservoir elevations, operational requirements and habitat conditions to protect resident fi sh and wildlife;

• water quality conditions; and

• research, monitoring and evaluation.

In developing the mainstem amendments, the Council asked the recommending entities to consider, among 

other things, the consistency of their mainstem recommendations with the basinwide provisions in the 2000 Fish 

and Wildlife Program, especially the role of a mainstem plan in a multispecies, habitat-based, basinwide program. 

The Council evaluated the mainstem recommendations and the draft and fi nal program amendments for consistency 

with the program framework elements adopted in 2000, including the vision, biological objectives, habitat and 
58 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

hydrosystem strategies, and underlying scientifi c principles. The Council also evaluated the draft and fi nal amendments for consistency with, and a basis in, the mainstem recommendations, as explained in these fi ndings.

Biological Opinions on the operation of the federal Columbia hydrosystem

In the past, the Council’s fi sh and wildlife program included detailed provisions for the confi guration and operation of the hydrosystem to benefi t fi sh and wildlife. In December 2000, NOAA Fisheries (formerly the National 

Marine Fisheries Service) and the U.S. Fish and Wildlife Service issued biological opinions for the operation of the 

Federal Columbia River Power System to benefi t populations of salmon, steelhead, bull trout and white sturgeon 

listed as threatened or endangered under the federal Endangered Species Act and found throughout the mainstem. 

The mainstem and hydrosystem objectives and measures in these biological opinions run to hundreds of pages of 

detail and hundreds of actions on water management, system confi guration, river fl ows, reservoir management, passage improvements, spill, juvenile transportation, predator management, mainstem habitat and more. The federal 

system operating agencies — the Corps of Engineers, Bureau of Reclamation and Bonneville Power Administration 

— agreed in subsequent Records of Decision to implement the hydrosystem measures in the biological opinions. 

These measures affect the entire mainstem and every species of fi sh and wildlife in the mainstem, whether listed or 

not. And these measures are built on foundations developed in the Council’s program over the last 20 years.

Thus in developing the mainstem amendments, the Council asked the recommending entities to consider, among 

other things, how the mainstem amendments should relate to the biological opinions on hydrosystem operations. 

The recommendations received by the Council in response may be grouped into four categories:

• recommendations that the Council adopt mainstem amendments that incorporate or at least are consistent with 

the objectives and measures in the biological opinions;

• based on a conclusion that the biological opinions did not prescribe suffi cient fl ow, spill and passage operations 

to benefi t listed (as well as non-listed) salmon and steelhead, recommendations that the Council adopt 

additional or different measures to that end;

• based on a conclusion that the operations specifi ed in the biological opinions are not optimal or suffi cient to 

protect, enhance or mitigate for the adverse effects of the hydrosystem on resident fi sh, recommendations 

that the Council adopt objectives and measures for that purpose that would be supplemental to the biological 

opinion operations, or would require a shift in current implementation of the biological opinions but within the 

apparent fl exibility of the opinions; or would be in confl ict with biological opinion operations; and

• based on the conclusion that the biological opinions exceeded what is necessary in terms of fl ow and 

spill to benefi t listed fi sh, to the unreasonable detriment of the power supply and other uses of the river, 

recommendations that the Council call for scaled-back fl ow and spill operations, or at least immediate 

evaluations of the current operations to determine the most biologically and cost effective set of operations.

Given this set of recommendations, and the current state of federal mainstem operations for fi sh and wildlife, 

the Council decided on the following approach for adopting mainstem objectives and strategies, an approach with 

three main elements:

First, the Council incorporated the hydrosystem objectives and measures from the two biological opinions into 

the Council’s program as the baseline set of federal system operations for fi sh affected by the Columbia hydrosystem. The objectives and measures in the biological opinions represent the recommendations of the federal fi sh and 

wildlife agencies with jurisdiction under the Endangered Species Act (and the recommendations of others as well) 

concerning the appropriate biological conditions and hydrosystem operations to protect and improve the status of 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 59

the listed species spread across the mainstem, from migrating salmon in the lower parts of the Columbia and Snake 

rivers to bull trout and Kootenai River white sturgeon in the upper parts of the system. These operations also 

strongly affect non-listed anadromous and resident fi sh, largely but not always in benefi cial ways.3

Second, the mainstem amendments include a set of habitat considerations, objectives and strategies intended to 

protect, mitigate and enhance all the fi sh and wildlife of the Columbia River Basin in the mainstem, whether listed 

or not, a broader focus required of the Council by the Power Act. Because the 2000 biological opinions concern 

only the listed species (even as they affect other fi sh in the system), and because most of the listed salmon and 

steelhead spawn and rear outside of the mainstem above or below the mainstem hydroprojects, the biological opinion measures may not be complete or optimal when the broader habitat needs of a broader range of fi sh and wildlife 

are taken into account. So, based on recommendations submitted, and consistent with the basinwide vision, biological objectives and strategies in the 2000 Program, the Council adopted mainstem objectives and strategies intended 

to allow for the appropriate mainstem habitat conditions to benefi t a wide range of multiple species of salmon, 

steelhead, other anadromous fi sh, resident fi sh and wildlife affected by the hydrosystem, not just listed species.

When the strategies intended to benefi t non-listed species appear to confl ict with the measures in the biological opinions, or when the strategies intended to benefi t upriver resident fi sh, whether listed or not, appear to confl ict with the measures in the salmon and steelhead biological opinion, the Council does not mean that the federal 

operating agencies should act contrary to the biological opinions in order to implement strategies in the Council’s 

program. The Council’s intent instead is that the federal operating agencies make every effort practicable to use 

the operational fl exibility inherent in the biological opinions to meet the biological opinion requirements while 

attempting to meet the objectives and implement the other strategies in the Council’s program.

Third, the mainstem amendments include a specifi ed set of evaluations, tests and experiments related to hydrosystem operations for fi sh. Scientifi c and policy uncertainty continues to plague a number of the mainstem actions 

in the NOAA Fisheries biological opinion intended to benefi t salmon and steelhead. This leads to an inability to 

measure the extent of the benefi ts gained and to great differences of opinion as to the value of continuing these 

actions, especially as some may have adverse effects on resident fi sh and signifi cant costs to the power system. 

3 The federal district court of Oregon recently declared NOAA Fisheries’ 2000 hydrosystem biological opinion to be unlawful and remanded 

that opinion to NOAA. The court concluded that NOAA Fisheries, in determining that the combined suite of mainstem and off-site 

measures in the opinion’s reasonable and prudent alternatives would avoid jeopardy, improperly relied on the occurrence of a number of 

non-federal off-site mitigation actions that are not reasonably certain to occur, and improperly relied on the occurrence of a handful of 

federal actions that have not yet undergone an ESA Section 7 consultation, both contrary to what is required for a jeopardy analysis in 

NOAA Fisheries’ own regulations implementing the ESA. “Opinion and Order,” National Wildlife Federation v. National Marine Fisheries 

Service, CR 01-640-RE (May 7, 2003).

The court’s action in remanding the biological opinion to NOAA Fisheries does not affect the Council’s mainstem amendments. The 

Council was careful not to adopt or incorporate the two biological opinions themselves into the Council’s program. Instead, the Council 

concluded that the mainstem hydrosystem objectives and measures in the biological opinions recommended to the federal operating 

agencies would become the baseline mainstem hydrosystem objectives and measures in the Council’s program as well. These measures and 

objectives are now independently part of the Council’s program.

The Council has no reason to believe that these measures will not represent the basic core of the federal operating agencies’ operations for 

fi sh and wildlife in the near future. As noted above, the system operating agencies — the Corps of Engineers, Bureau of Reclamation and 

the Bonneville Power Administration — have executed Records of Decision identifying the hydrosystem measures in the biological opinion 

as the measures they will be implementing in the next few years. The issues that the plaintiffs raised in the biological opinion litigation 

included the adequacy of the extinction analysis used by NOAA Fisheries and the validity of relying on a suite of off-site mitigation 

measures to offset in part the jeopardy impacts of the hydrosystem. The plaintiffs did not challenge the hydrosystem measures themselves 

(except for an emergency clause that allow the operations to be curtailed under certain circumstances, and which is not part of the 

hydrosystem measures that the Council adopted); the plaintiffs did not name the operating agencies as defendants, and the court’s opinion 

does not address or fi nd fault with these mainstem measures. It may be that the plaintiffs pursue additional measures in the mainstem for 

salmon and steelhead, but no party argued that the basic hydrosystem operations already in the biological opinion are inappropriate or 

should not be implemented. These measures are the starting point or baseline for further considerations.
60 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

This is a large part of the reason the federal and state fi sh and wildlife agencies and lower river tribes have produced different plans, programs and recommendations regarding the appropriate mainstem operations for salmon 

and steelhead, including confl icting program amendment recommendations to the Council.

The Council concluded that many of the biological opinion measures must be subject to systematic and rigorous monitoring and evaluation to determine if the measures have the biological benefi ts expected and represent the 

most cost-effective actions to achieve these benefi ts. Some of the recommended strategies to benefi t resident fi sh 

in upriver reservoirs suffer from similar uncertainties and costs, and similarly need implementation and evaluation, 

often in the form of implementation through an experimental design.

For these reasons, the mainstem amendments include not only the detailed set of evaluations, tests and experiments for the hydrosystem, they also include an approach for prioritizing mainstem research as well as specifi c 

priorities for that research; and recommendations for how better to integrate research, monitoring and evaluation 

results into decisions about mainstem actions and power system operations. The Council calls for certain tests and 

experiments even when they may require implementing within a range of system operations, so as to focus on areas 

where the quantitative benefi ts from biological opinion operations require additional understanding or verifi cation, or where benefi ts to non-listed species from varied operations may be signifi cant without adverse impacts on 

listed species, or both. The Council believes this approach is consistent with the biological opinions, which allow 

considerable fl exibility to conduct necessary tests. The opinions were adopted with the recognition that as new scientifi c information is developed, actions called for in the opinions could and would be changed where appropriate. 

As information is gleaned from these evaluations and tests, the Council’s goal is to provide recommendations to the 

federal hydrosystem operating agencies and fi sh and wildlife agencies for the most biologically effective spill, fl ow 

and other mainstem operations and actions at the minimum economic cost.

In settling on this approach, the Council adopted, modifi ed or rejected the recommendations in the four categories described above in the following manner:

General Finding No. 1: Recommendations to incorporate into the program the objectives and measures in the 

biological opinions. The federal fi sh and wildlife and operating agencies submitted this recommendation, but others 

did, too. For example, incorporating the biological opinion measures into the program was the centerpiece of the recommendations from the Washington Department of Fish and Wildlife. The Council adopted these recommendations.

Also included in this category are certain recommendations the Council received for the purpose of protecting 

and improving mainstem habitat (broadly considered) for a wide range of populations and species of anadromous 

and resident fi sh and wildlife, not just listed species. These recommendations did not necessarily refer to, or have 

a basis in, the biological opinions but were not incompatible with the particular provisions of those opinions. The 

Council adopted a number of objectives and measures based on recommendations of this type, as highlighted in the 

summary of specifi c recommendations that follows this general section of the fi ndings.

General Finding No. 2: Recommendations based on a conclusion that the biological opinions did not prescribe suffi cient fl ow, spill and passage operations to benefi t listed (as well as non-listed) salmon and steelhead, 

thus calling for the Council to adopt additional or different measures for that purpose. The Council did not adopt 

recommendations that would have the Council call for the implementation of fl ow, spill and passage operations for 

salmon and steelhead that are in confl ict with what the biological opinions call for or will allow for.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 61

The category analyzed here included, for example, recommendations from the fi sh and wildlife agencies of 

Oregon and Idaho and the Columbia River Inter-Tribal Fish Commission for additional and different fl ow and 

spill measures. The Commission also recommended the breaching of the federal dams in the lower Snake River. 

These recommendations carried over into the Council program amendment process disputes these entities had with 

NOAA Fisheries in the development of the biological opinion concerning what are the appropriate measures for 

salmon and steelhead. The Save Our Wild Salmon Coalition and the Northwest Resource Information Center, Inc., 

joined in these recommendations. All of these recommendations would have additional costs to the power system 

in terms of lost energy and dollars, some would have impacts to upriver listed and unlisted resident fi sh.

By rejecting the recommendations that would have the Council call at this time for additional or different fl ow, 

spill and passage measures for salmon and steelhead, the Council does not mean or imply that it has evaluated the 

science underlying the different positions and concluded that NOAA Fisheries is correct and the Oregon and Idaho 

agencies and the Commission are incorrect, or that the Council gave greater weight to the biological judgments of 

the federal agencies and less or none to the judgments of the others. Program amendment recommendations from 

all fi sh and wildlife agencies and tribes are due special consideration by the Council under the Power Act. The 

Council recognizes that the different positions are based in legitimate differences in opinion as to the meanings 

to be drawn from imperfect scientifi c information and from different managerial perspectives and assumptions of 

risk. Time and more information may reveal that the federal agencies are correct in the decisions about what is 

needed to prevent extinction and recover listed salmon and steelhead, or that these state agencies and tribes are 

correct, or that neither is correct. The diffi culty for the Council was how to decide what the Council’s program 

should say at this time about mainstem confi guration and operations for salmon and steelhead in light of the different recommendations from the federal and state fi sh and wildlife agencies and tribes. The standards for adopting 

and rejecting recommendations in Section 4(h) of the Power Act are essentially premised on the assumption that 

the recommendations of the fi sh and wildlife agencies and tribes will coincide, and that any confl icts found in the 

recommendations will be between fi sh and wildlife managers and other river users. The standards are not well 

adapted to situations in which the federal salmon agency differs from state and tribal salmon agencies as to what 

are the appropriate measures for salmon and steelhead. One reason the Council gave at least presumptive weight 

to the federal agency recommendations, at least as the baseline or starting point for the measures in the program, is 

because the ultimate focus is on adopting a set of operations that the Council can expect the federal operating agencies to implement to benefi t salmon and steelhead. The systemwide operational measures from the federal fi sh and 

wildlife agencies with ultimate jurisdiction under the ESA for listed species carry by far the most weight with the 

federal operating agencies and, in fact, are now the basic set of hydrosystem operations that those agencies have 

adopted in their Records of Decision for operations, and thus are the operations for the Council to establish as the 

baseline for the program. The issue then has been what to do with the different or additional recommendations of 

the state and tribal managers.

The Council concluded that the hydrosystem measures in the biological opinions themselves held a key to resolving this dilemma. The biological opinions represented the culmination of a complicated multi-year process by the 

federal fi sh and operating agencies to evaluate the effects of hydrosystem operations on the listed fi sh species spread 

throughout the Columbia. That process included a thorough airing of the different scientifi c and policy views of the 

federal, state and tribal fi sh managers as well as the views of environmental groups, industry groups and others, resulting in an extensive administrative record and resolution of key issues by NOAA Fisheries and U.S. Fish and Wildlife 

Service, the agencies with ultimate responsibility to determine what are the appropriate actions to take to protect and 

improve the conditions for listed species. Most important here, the hydrosystem part of the NOAA Fisheries’ salmon 

and steelhead biological opinion recognized the uncertainties and legitimate differences in opinion. The biological 

opinion included measures and mechanisms to test key assumptions and uncertainties about fl ow, spill, passage and 
62 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

system confi guration; to monitor progress in reversing the population trends; and to adapt management prescriptions 

as more is learned about the status of the stocks and the effects of measures taken. The biological opinion measures 

thus internalized the debates and left room for the evaluation and possible implementation of precisely these recommendations of the state fi sh and wildlife agencies and tribes. The Council did not believe the region would be well 

served by having the Council adopt program amendments now calling for the federal operating agencies to engage in 

the different operations recommended rather than allowing the evaluation and adaptive management process of the 

biological opinions to work. The Council chose instead to emphasize evaluating the current extensive set of operations against a set of alternatives before fi rmly deciding on new directions.

It is true that the Council’s and the federal agencies’ responsibilities under the Power Act are different and 

broader than under the Endangered Species Act. The Power Act is concerned with protecting all fi sh and wildlife, not just listed species, from the adverse effects of the hydrosystem and with mitigating for the adverse effects 

that cannot be avoided. And while “mitigation” is not defi ned in the act, clearly it means a mitigation goal that is 

greater than just avoiding jeopardy to the continued existence of listed species and presumably greater than recovering populations just to the point of being able to delist them but derive no other benefi t. This is refl ected in the 

Vision of the 2000 Program (repeated in the mainstem amendments) of “mitigating across the basin for the adverse 

effects to fi sh and wildlife caused by the development and operation of the hydrosystem and providing the benefi ts 

from fi sh and wildlife valued by the people of the region,” including “abundant opportunities for tribal trust and 

treaty right harvest and for non-tribal harvest” as well as “allowing for the recovery of the fi sh and wildlife affected 

by the operation of the hydrosystem and listed under the Endangered Species Act.” Thus, it might be argued that 

while the measures in the biological opinions may be suffi cient to avoid jeopardy and start down the path toward 

recovery of the listed species, the different or additional fl ow, spill and passage actions in the state and tribal recommendations are necessary to provide additional improvements in the status of all salmon and steelhead populations in the system to meet the greater mitigation goals of the Power Act and the program.

The problem with this argument, however, is that the recommendations from the state agencies and tribes are 

not presented in this way, nor are the biological opinions constructed in this way. The water management and 

passage measures in the biological opinions affect and benefi t all the salmon and steelhead in the river. NOAA 

Fisheries did not adopt the hydrosystem measures with an understanding that these measures would provide a selflimited benefi t to the listed populations — up to but not above what is required to satisfy the Endangered Species 

Act — while leaving on the table a host of operational and passage measures for salmon and steelhead that could 

be implemented but that NOAA could ignore because they would provide greater protection and survival benefi ts 

than required for the ESA, or because they would benefi t only non-listed salmon, or because they would produce 

abundance for harvest opportunities beyond the requirements of the ESA. (To the contrary, an assumption throughout the biological opinion is that one purpose for the federal government’s efforts is to recover these populations 

to allow for, and even while allowing for, salmon harvest opportunities.) Instead, NOAA Fisheries included every 

reasonable and prudent hydrosystem operation and passage improvement it believed appropriate and optimal for 

salmon and steelhead (short of dam removal), and called for implementation of those that can be implemented now 

and for evaluation and implementation within a short-time period for those that were not yet ready for implementation. In the latter category, for example, the biological opinion called for “a detailed feasibility analysis of modifying current system fl ood control operations to benefi t the Columbia River ecosystem, including salmon” (RPA 

Action 35), echoing the Commission’s recommendation to the Council that a substantial rethinking of fl ood control 

is necessary to provide the more normative river hydrograph the Commission believes is necessary for salmon. 

The Council incorporated both types of measures into the program, with emphasis on points important to the state 

and tribal recommendations. These include, for example, an explicit statement by the Council in its water man-
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 63

agement strategies that the Corps of Engineers should “place a priority on conducting the further comprehensive 

review of fl ood control operations called for in the NOAA Fisheries 2000 Biological Opinion.”

Conversely, the state agencies and tribes that recommended additional or different hydrosystem actions for 

salmon and steelhead did not do so based on an analysis or explanation that the measures in the biological opinion do so based on an analysis or explanation that the measures in the biological opinion

satisfy what the populations require under the ESA, but that the additional or different measures are needed to meet 

a higher population standard under the Power Act. Instead, as noted above, these agencies and tribes simply disagree with NOAA Fisheries on what are the appropriate operations for salmon and steelhead, whether listed or not.

For just one example, the recommendations from Oregon, the Columbia River Inter-Tribal Fish Commission, and 

the Idaho Department of Fish and Game call for more spill than the biological opinion, such as 24-hour instead of 12-

hour spill at certain projects. NOAA Fisheries did not call for less spill because only that amount was needed to meet 

ESA requirements. Instead, NOAA Fisheries sought to establish optimal levels of spill for salmon survival through 

the dams. And the contrary recommending entities do not call for greater spill operations because that is needed to 

satisfy Power Act obligations beyond the ESA. These entities, too, seek to establish what they believe are optimal 

levels of spill for salmon survival. Recognizing the uncertainties and differences of opinion, the biological opinion 

measures do not call just for a certain set of spill operations. They also include an extensive set of spill assessments, 

tests, investigations, actions and evaluations to better determine optimal spill levels for salmon, including among 

many other matters an assessment of shifting to 24-hour spill. (Biological Opinion, pages 9-84 to 9-102, 9-119 to 

9-126; RPA Actions 54-57, 60, 68-72, 75, 77, 80, 82-83, 130-40.) No standard or obligation in the Power Act would 

be served by the Council calling for the operating agencies to implement different spill operations at this time on 

the basis of the recommendations of Oregon, Idaho and CRITFC, rather than recognizing and incorporating the spill 

operations and evaluation process set out in the biological opinion, which became in this forum the recommendations 

of NOAA Fisheries. Moreover, the different spill operations recommended would reduce the power output of the 

system, thereby further reducing the adequacy, reliability, effi ciency and economy of the power system, a Power Act 

concern of the Council. So the Council chose instead to add its own emphasis to the importance of an experimental 

approach for determining the optimal levels of spill. And the analysis is precisely the same for the other additional or 

different fl ow and passage measures for salmon and steelhead in the state and tribal recommendations.

If the Council ever had a sense that the hydrosystem measures for salmon and steelhead pursued by the federal agencies were suffi cient for ESA purposes but left out an obvious set of additional measures needed to meet 

requirements of the Power Act to “protect and mitigate” obligation for the same populations, separately recommended to the Council, the Council would adopt the recommendations and additional measures into the program. 

That is not the situation here. Also, the Council is always cognizant of the need to adopt additional measures to 

protect non-listed salmon and steelhead (and other) populations in those moments when even the extensive federal 

hydrosystem measures do not reach or benefi t those non-listed populations. For one of many examples, the Council called for the federal agencies, in deciding on spill operations as compared to the benefi ts of transportation, 

to give priority recognition to important although not listed populations of salmon and steelhead that cannot be 

transported or are not effectively transported, giving examples (2003 Mainstem Amendments, at 15). For another 

example, the Council called for the federal agencies to manage fl ows to benefi t the Hanford Reach fall chinook 

population on an equal basis with managing water to benefi t listed species (2003 Mainstem Amendments, at 7, 19).

For these reasons, the Council concludes that adopting the recommendations of those state agencies, tribes and 

environmental groups to call now in the program for additional or different hydrosystem fl ow, passage and spill 

objectives and measures for salmon and steelhead than those in the biological opinions would be:
64 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• less effective in protecting, mitigating and enhancing salmon and steelhead in the mainstem than adopting the 

recommendations of the federal agencies to incorporate the biological opinion measures and objectives in the 

program (which includes the measures allowing for extensive evaluation of alternative operations), see Power 

Act, § 4(h)(7)(C);

• inconsistent with the information and the comments in the record concerning the most appropriate way to 

handle the debates over appropriate salmon measures, id., § 4(h)(5), (7)(A), (C);

• inconsistent with an effort to reconcile the confl icting recommendations of all the fi sh and wildlife agencies and 

tribes in a way that deals with the river as a system, see Power Act, § 4(h)(1)(A), (6), (7), (7)(B);and

• inconsistent with the Council’s efforts to assure the region an adequate, reliable, effi cient and economical power 

supply while protecting, mitigating and enhancing fi sh and wildlife affected by the hydrosystem, id., § 4(h)(5), 

(7)(A).

General Finding No. 3: Recommendations based on a conclusion that the operations specifi ed in the biological 

opinions are not optimal or suffi cient to protect, enhance or mitigate for the adverse effects of the hydrosystem on 

resident fi sh, calling for the Council to adopt objectives and measures for that purpose that would be supplemental 

to the biological opinion operations, or would require a shift in current implementation of the biological opinions 

but within the apparent fl exibility of the opinions; or would be in confl ict with biological opinion operations. Two 

sets of recommendations best illustrate the recommendations in this category. The Spokane and Colville Tribes 

recommended reservoir elevation minimums for Lake Roosevelt to benefi t resident fi sh in the lake that would result 

in Grand Coulee operations and summer river fl ows in the lower river different from the Grand Coulee operations 

in the NOAA Fisheries 2000 Biological Opinion. And the Montana Department of Fish, Wildlife and Parks recommended summer operations at Hungry Horse and Libby dams to benefi t resident fi sh in the reservoirs and in the 

river reaches below the dams that would change operations at both projects compared to biological opinion operations and reduce summer fl ows in the lower river.

The Council defers to the judgments of these fi sh and wildlife agencies and tribes as to what would be the most 

appropriate operations to protect and mitigate the resident fi sh in the areas under their jurisdictions. And so the 

Council refl ected these recommendations in the mainstem amendments, to a certain extent. But, the operations 

recommended by these entities for resident fi sh were often inconsistent with the systemwide water management 

operations in the salmon and steelhead biological opinion and the operations recommended to the Council by the 

salmon agencies and tribes to protect and mitigate the salmon populations of the system. The comments on the 

draft amendments and the Council’s own power system analysis also indicated that implementation of the alternative operation at Grand Coulee would have signifi cantly more adverse effects on the ability of the hydrosystem to 

meet electricity demand in the region. The Council concluded, in the face of this confl ict, that it would not be an 

improvement to ignore or back away from the baseline operations recommended to the Council for salmon and 

steelhead protection in order to provide operations for resident fi sh based on other agency and tribal recommendations. And again, the Council believes the solution to this dilemma is for the Council and the other entities to work 

within the fl exibility and adaptive management principles in the hydrosystem measures of the salmon and steelhead 

biological opinion.

Thus, as noted above, the Council did include strategies to benefi t resident fi sh species, both listed and non-listed, that 

in some cases confl ict with the current implementation of the measures in the salmon and steelhead biological opinion. 

The Council does not mean by that action that the federal operating agencies should act contrary to the biological opinions in order to implement these other strategies in the Council’s program. The Council’s intent instead is that the federal 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 65

operating agencies make every effort practicable to use the operational fl exibility inherent in the biological opinions to 

meet the biological opinion requirements and implement the other strategies in the Council’s program.

For example, the Council calls for spring and summer operations at Grand Coulee consistent with biological opinion operations and with ordinary hydrosystem power operations, but then calls on the federal agencies, working with 

the tribes, the Council and others, to work toward meeting the reservoir elevations and water retention times recommended by the Lake Roosevelt area tribes when possible. The Council took an additional step with regard to summer 

operations at Hungry Horse and Libby, calling on the federal agencies to implement the operation recommended by 

Montana (limits on reservoir drafting that result in higher reservoir levels and steady outfl ows) as an experimental 

design within the adaptive management capabilities of the hydrosystem measures of the biological opinion. The 

Council called on the operating agencies to consult with a team formed from the Council, the Independent Scientifi c 

Advisory Board and others to design the experiment, with the hypothesis that the proposed operations will signifi -

cantly benefi t listed and non-listed resident fi sh in the reservoirs and in the portions of the rivers below the reservoirs 

without discernible effects on the survival of juvenile and adult anadromous fi sh when compared to ordinary operations under the biological opinions. The Council noted that little hard information exists about the relationship, if any, 

between levels of fl ow, fl ow augmentation and juvenile and adult salmon survival through the lower Columbia hydrosystem reach. The Council concluded that the experiment called for would allow for that kind of information to be 

gathered in a systematic way, while also testing the predicted benefi ts of the proposed operation to resident fi sh.

In conclusion, the Council adopted modifi ed versions of these types of recommendations for the reasons 

described here and fi nds what it adopted to be:

• consistent with an effort to reconcile the confl icting recommendations of all the fi sh and wildlife agencies and 

tribes in a way that deals with the river as a system, see Power Act, § 4(h)(1)(A), (6), (7), (7)(B);

• more effective than the original recommendations in the protection, mitigation and enhancement of all the fi sh the fish 

and wildlife affected by the hydrosystem, id., § 4(h)(7)(C); and

• consistent with the best available, if at times confl icting, scientifi c knowledge presented by different fi sh 

and wildlife agencies and tribes to support confl icting recommended operations for the fi sh species of their 

particular concern, id., § 4(h)(6)(B), (7), (7)(B), (C).

General Finding No. 4: Recommendations based on the conclusion that the biological opinions exceeded what 

is necessary in terms of fl ows and spill to benefi t listed fi sh, to the unreasonable detriment of the power supply and 

other uses of the river, and so the Council should call for scaled-back fl ow and spill operations, or at least immediate evaluations of the current operations, to determine the most biologically and economically effi cient operations 

to allocate the region’s limited resources. In this category, for example, the Columbia-Snake River Irrigators Association, Eastern Oregon Irrigators Association, Northwest Irrigation Utilities and Idaho Water Users recommended 

that the Council call for reductions in fl ow augmentation and spill compared to what is in the NOAA Fisheries 

biological opinion. Similar to recommendations based on concerns that measures in the biological opinions were 

insuffi cient (See General Finding No. 2), these recommendations carried into the Council program amendment 

process a dispute these entities have with NOAA Fisheries and the salmon managers in general as to the biological 

effi cacy and cost effectiveness of the fl ow and spill measures for salmon.

The Council declined to adopt recommendations of this type for a number of related reasons. The recommendations that would have the Council call for reduced spill and fl ow operations as not needed for salmon and steelhead 

were not supported by any of the fi sh and wildlife agencies and tribes concerned with salmon, whatever the differences among them. Moreover, statutory responsibility for deciding which hydrosystem actions to take to protect 
66 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

and improve the conditions for listed species lies with NOAA Fisheries and the U.S. Fish and Wildlife Service, not 

with private entities challenging those agencies. Except in unusual circumstances, the Council will defer under the 

Power Act to the biological judgments of the fi sh agencies and tribes on these matters. That is especially true here, 

where the biological opinions represented the culmination of a complicated multi-year process by the federal fi sh 

and operating agencies to evaluate the effects of hydrosystem operations on the listed species spread throughout the 

Columbia. As noted, that process included a thorough airing of the different views and information of all the interested entities, including the fi shery agencies and tribes, federal operating agencies, Bonneville customers and other 

industry groups, environmental groups and others, resulting in an extensive administrative record and resolution of 

the key issues by NOAA Fisheries in the fi nal salmon and steelhead biological opinion.

This does not mean that the Council considers these recommendations to raise frivolous issues. As also noted 

above, considerable scientifi c uncertainty exists as to what are the optimal levels of fl ow and spill for salmon and 

steelhead survival. A number of the recommending entities from industry — from the Public Power Council and 

the Pacifi c Northwest Generating Cooperative, for example — did not recommend that the Council adopt specifi c 

spill and fl ow operations contrary to the biological opinions, but did raise the point that some scientifi c information 

calls into question whether the extensive spill and fl ow measures in the biological opinion are required to obtain the 

levels of survival that salmon need through the hydrosystem. Moreover, these measures are costly to the region’s 

power system. And so these entities recommended that the Council place a high priority on fl ow and spill evaluations aimed at determining the most cost-effective levels of spill and fl ow. Based in part on recommendations of 

this type and on supporting information and comments submitted by Bonneville customers and industry groups, the 

Council recognized the need for aggressive testing of certain assumptions and uncertainties embedded in the biological opinion measures as they relate to spills, fl ow augmentation, reservoir drafting and other matters, in order 

to determine what are the most biologically effective spill, fl ow and other mainstem operations and actions at the 

minimum cost to the power system. And as explained above, the salmon and steelhead biological opinion allows 

for precisely these kinds of evaluations and adaptive management actions.

For these reasons, to the extent that the recommendations in the category call for the Council to adopt specifi c 

spill and fl ow actions contrary to and less than the hydrosystem measures in the biological opinions, the Council 

concludes that adopting these recommendations would be less effective in protecting, mitigating and enhancing 

salmon and steelhead in the mainstem than adopting the recommendations of the federal agencies to incorporate 

the biological opinion measures and objectives in the program (which includes the measures allowing for extensive 

evaluation of alternative operations), see Power Act, § 4(h)(7)(C), and would not be consistent with giving due 

weight to the recommendations and expertise of the fi sh and wildlife and agencies or tribes or complement their 

existing and future activities, id., § 4(h)(6), (7), (7)(B).

Regional Power System Problems

The Power Act requires the Council to adopt a fi sh and wildlife program that not only protects, mitigates and 

enhances fi sh and wildlife but also ensures that the region will continue to enjoy an adequate, effi cient, economical 

and reliable power supply. With regard to the latter, the Council evaluated current hydrosystem operations under 

the biological opinions, the recommendations for mainstem amendments and the draft and fi nal mainstem amendments to ensure that the adopted objectives and measures for mainstem hydrosystem operations are consistent with 

the Council’s power supply obligations.

Energy systems, markets and policy changed radically since the last revision of the fi sh and wildlife program in the 

mid-1990s. Federal hydrosystem operations in 2001 brought a concrete example of a problem that the Council had 

seen developing over the last half-decade — electricity demands placed on the federal hydrosystem were increasingly 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 67

greater than what the federal system could produce in a year of historically low runoff and river levels. The Bonneville Power Administration did not acquire new, long-term resources that could have closed the gap, largely due to the 

dynamics of regional and West Coast energy developments. Additional problems with West Coast power markets in 

2000 and 2001 prevented Bonneville from being able to make up the energy defi cit in those markets through power 

purchases, leading to a situation in 2001 in which the federal agencies curtailed regional load and reduced system 

operations intended to benefi t fi sh and wildlife in order to maintain the reliability of the region’s power system. Even 

with signifi cant changes to the hydropower operations specifi ed for fi sh, the system still produced inadequate energy 

to meet the region’s demands. This forced many of the region’s utilities to curtail loads while still spending large 

sums to purchase power. When surplus energy was available for purchase, it was at a cost that resulted in signifi cant 

rate increases and made it diffi cult to maintain an economical power supply in the region.

For these reasons, the Council’s analysis of the adequacy, effi ciency, economy and reliability of the region’s power 

supply, which accompanies the mainstem amendments and these fi ndings (Appendix A to the 2003 Mainstem Amendments), includes consideration of the current status of the region’s power system. The Council’s conclusion is that the 

region’s power system should be adequate and reliable for the next few years due to the development of new power 

supplies, reductions in demand and loss of loads that have occurred since early 2001. The objectives and measures to 

protect, mitigate and enhance fi sh and wildlife included in the mainstem amendments do not affect that conclusion. 

The analysis also concludes, however, that the region faces the possibility in later years of spiraling back into the 

power supply problems seen in 2001 unless measures are taken to ensure that new resources are added to the regional 

power supply in a more certain fashion. The analysis suggests possible actions by the federal agencies and others in 

the region to ensure that the federal system provides the specifi ed operations for fi sh and wildlife and meets the electricity demands in most, if not all, low-water years. The Council is reviewing and revising its 20-year power plan as 

called for by the Act. The power plan will address the region’s power supply and reliability issues in more detail.

General Finding No. 5: Given this context, the Council received a number of recommendations relating to power 

supply and power planning actions. This is unusual for a fi sh and wildlife program amendment process. These included 

recommendations from the Columbia River Inter-Tribal Fish Commission, the Columbia Basin Fish and Wildlife Authority, the State of Oregon, the Northwest Energy Coalition, the Save Our Wild Salmon coalition, and others. The thrust 

of these recommendations was that the Council should call for hydrosystem operations, system confi guration changes 

and energy resource actions that would allow the system to provide the operations needed for fi sh even in low water 

years, while also ensuring that the region has an adequate, reliable, effi cient and economical power supply. The Council 

does not disagree with the premise or goals of these recommendations. The Act calls for hydrosystem operations and 

a regional power system that provide both protection for fi sh and wildlife and for an adequate, reliable and economical 

power supply. One of the central tasks faced by the Council in the revision of the power plan is to help ensure both of 

these goals in the long run. Deferring full consideration of this matter to the power plan is appropriate, given the conclusions of the Council in the analysis of the region’s power supply and the effects of the fi sh and wildlife measures on that 

power supply, which showed resources to be adequate in the near term.

The Council also received power supply-related recommendations from Bonneville customer groups, such as 

the Public Power Council and the Pacifi c Northwest Generating Cooperative, recommending that the Council call 

for evaluations and decisionmaking processes that analyze fi sh and wildlife actions to determine their impacts on 

the region’s power supply and to search aggressively for effi ciencies and cost-effectiveness in fi sh and wildlife 

operations. The Council agreed with these recommendations, too, as described above — calling for changes in 

evaluations and decisionmaking processes to better incorporate power supply considerations and calling for rigorous evaluation of current fl ow and spill measures and alternatives to determine what levels of both are necessary to 

provide the biological benefi ts needed for fi sh at the least cost to the power system.
68 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Summary of Specifi c Recommendations and Findings

In this section, the Council sets forth its fi ndings on the specifi c mainstem recommendations. As most of the recommendations fi t into the categories analyzed above, the general fi ndings the Council made for recommendations in 

those categories apply to most of the specifi c recommendations, as explained here. The specifi c recommendations 

are briefl y summarized in this document; the recommendations in full are available as Council Document No.2001-

16, and may also be found on the Council’s website at http://www.nwcouncil.org/library/recommend/mainstem/

Default.htm. Written comments on the draft mainstem amendments and the recommendations are also posted on the 

Council’s website, at http://www.nwcouncil.org/fw/program/mainstem/2002-16Comments/default.asp.

Federal and State Fish and Wildlife Agencies and Indian Tribes, collectively

Recommendation No. 9: Columbia Basin Fish and Wildlife Authority

The Columbia Basin Fish and Wildlife Authority is the collective voice of the basin’s state and federal fi sh and 

wildlife agencies and Indian tribes. The Authority recommended that the Council’s mainstem amendments at a 

minimum must accommodate implementation of the provisions of National Marine Fisheries Service and U.S. Fish 

and Wildlife Service’s 2000 Biological Opinions. The Authority also noted that the Northwest Power Act requires 

that the Council set a broader standard than the Endangered Species Act for rebuilding the basin’s fi sh and wildlife 

resources, and thus recommended that the Council’s mainstem plan provide for more than the survival and recovery 

of listed fi sh and wildlife by being amended consistent with the management objectives and recommendations of 

the fi sh and wildlife managers regarding all fi sh and wildlife affected by the hydrosystem.

The Authority recommended that collectively the Columbia River Inter-Tribal Fish Commission tribes’ Spirit of the 

Salmon Plan, the upper Columbia tribes’ Blocked Area Management Plan and the biological opinions provide what is 

needed for listed and non-listed resident fi sh and salmon and strike a balance between fi sh and wildlife and the other 

purposes for which the system is operated, consistent with the purposes of the Northwest Power Act. Thus, the Council should adopt measures for the basin’s hydrosystem suffi cient to accommodate implementation of all the measures 

in these plans. To the extent there may be inconsistencies in fi sh and wildlife measures among these plans, the fi sh and 

wildlife managers should resolve these matters, not the Council. The Council should assist by adopting a process in 

which the managers will bring forward their resolution of inconsistencies among plans for approval by the Council.

The Authority also recommended that the Council use all of the tools available to resolve the region’s power 

supply problems, including an emphasis on conservation, alternative energy technologies and creative use of energy 

markets. This is needed to ensure that operations for fi sh and wildlife become hard constraints on the system, to prevent curtailments of fi sh operations during low water conditions, to provide for improved or additional fi sh operations 

in the future and to allow for river fl ows that more closely approximate the natural hydrograph.

As highlighted in the section containing the general fi ndings, the Council acted consistently with this recommendation in a number of ways. Among other things, the Council:

• incorporated the measures of the biological opinions as the baseline for the mainstem system operations of the 

program;

• agreed with the general point that the Power Act contains a different legal standard than the Endangered 

Species Act, encompassing a broader set of affected fi sh and wildlife and a protection and mitigation goal 

beyond preventing extinction and delisting of endangered or threatened fi sh, and agrees that the Council must 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 69

adopt program measures that give due weight to the expertise and responsibilities of the fi sh and wildlife 

managers and complement their activities;

• worked, on this basis, to accommodate the recommendations of the different agencies and tribes within the 

context of biological opinion operations, such as:

− Grand Coulee operations based on recommendations by the upper Columbia tribes to protect resident fi sh 

populations in Lake Roosevelt important to the tribes;

− experimental summer operations at Hungry Horse and Libby dams based on recommendations from the 

Montana Department of Fish, Wildlife and Parks to provide improved conditions for fi sh in the reservoirs 

and in the river reaches below the dams;

− a number of objectives and strategies to benefi t non-listed salmon and steelhead drawn from or consistent with 

the recommendations of the state agencies and the Inter-Tribal Fish Commission, including a set of mainstem 

habitat objectives and strategies; an objective to increase fall chinook spawning in the mainstem; smolt-toadult survival rate interim objectives and a process to investigate extending these objectives; objectives and 

strategies designed to shift water management over time so that patterns of fl ow more closely approximate 

natural hydrographic patterns; an objective of meeting state water quality standards; equal priority protection 

for Hanford Reach fall chinook; and spill and transport strategies that state an equal priority for protection of 

non-listed naturally spawning and hatchery populations important to the tribes and states;

• included provisions recognizing that operations to improve conditions for salmon and steelhead migration 

may confl ict with operations to protect or enhance mainstem habitat for salmon and steelhead or resident fi sh, 

and calling on the system operators and the fi sh and wildlife agencies and tribes to identify potential confl icts, 

priorities, trade-offs, and opportunities and consult with the Council, affected entities and the public on how 

best to resolve confl icting needs.

Also, as explained in General Finding No. 5, the Council agreed with the basic premise that there is a need to 

ensure that the hydrosystem can provide the specifi ed operations for fi sh and wildlife while the power supply meets 

electricity demands of the region in most if not all years. The Council’s power system analysis accompanying 

these fi ndings concluded that, because of developments since 2001, the region’s power system should be adequate 

and reliable for the next few years and not unduly vulnerable to curtailment of fl ow and spill operations for fi sh in 

low water conditions. But, the region faces the possibility of spiraling back into the power supply problems seen in 

2001 unless measures are taken to ensure that new resources are added to the regional power supply in a more certain fashion. The analysis suggests actions that federal agencies and others in the region could take to ensure that 

the federal power system provides the specifi ed operations for fi sh and wildlife and meets electricity demands even 

in low water years. The analysis also notes that the Council is revising its 20-year power plan as called for by the 

Northwest Power Act and that the power plan will address the region’s power supply and reliability issues in more 

detail. Further consideration of the power supply recommendation will be deferred to the power plan revision.

On the other hand, the Council did not adopt recommendations that would call now for implementation of spill, 

fl ow and dam modifi cation measures that clearly confl ict with or cannot be accommodated within the measures 

of the biological opinions, even if they came from the state fi sh and wildlife agencies or Indian tribes, for all the 

reasons explained in General Finding Nos. 2 and 3. Instead the Council emphasized the need for evaluations and 

experimental management, which it believes can be accommodated within the biological opinions. These evaluations and management actions will systematically review whether operations additional to or different than the biological opinions can better protect all of the multiple populations and species of salmon, steelhead and resident fi sh 

in the mainstem while providing a reliable, adequate and economical power supply for the region.
70 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Federal Fish and Wildlife, System Operation and Environmental Agencies

Recommendation No. 22: National Marine Fisheries Service, United States Fish and Wildlife

 Service, Corps of Engineers, Bureau of Reclamation

Recommendation No. 4: Bonneville Power Administration

Recommendation No. 8: National Marine Fisheries Service

The federal agencies — Bonneville, the Corps of Engineers, the National Marine Fisheries Service (now NOAA

Fisheries), the Fish and Wildlife Service and the Bureau of Reclamation — recommended that the Council adopt 

objectives and measures in its program consistent with the objectives and measures in the NMFS’ and USFWS’ 2000 

FCRPS Biological Opinions, and that the Council and its program assist in the implementation of these biological 

opinions and of the action agencies’ implementation plans derived from the biological opinions. The Council adopted 

this recommendation in that it incorporated the hydrosystem objectives and measures in those biological opinions into 

the program. General Finding No. 1.

Bonneville added a number of recommendations on specifi c issues, such as operating the system in a manner 

that focuses increasingly on the natural ecological functions that support salmon mitigation and recovery, passage and water quality (dissolved gas and water temperature) actions, performance standards for mainstem system 

operations, critical uncertainties in the mainstem, mainstem habitat and more. The Council concludes that the specifi cs of almost all of what Bonneville recommended on these points came from or were based on provisions of the 

salmon and steelhead biological opinion and are covered by the general fi nding noted above.

Both NOAA Fisheries and Bonneville recommended that the Council’s mainstem amendments consider the 

effects of conditions in the estuary, plume and near-shore ocean on salmon and the effects of hydrosystem operations on that estuary, plume and near-shore environment. The Council adopted mainstem habitat objectives and 

strategies calling for water management to allow fl ows to approximate natural hydrographic patterns more closely, 

an objective that applies to fl ows in the estuary and plume. And the Council adopted the more specifi c objective 

and strategy of identifying, protecting, enhancing, restoring and connecting ecosystem functions in the Columbia 

River estuary and nearshore ocean discharge plume as affected by actions within the Columbia River mainstem, 

calling for an evaluation of fl ow regulation and changes to estuary-area habitat and biological diversity.

Bonneville also recommended that the Council adopt a number of provisions relating to water allocation and 

water rights, including the possible effects on system operations and Bonneville funds of settlement ideas being 

discussed in the Snake River Basin Adjudication, moratoria on additional consumptive use withdrawals, and a 

possible interstate agreement to protect instream water rights. The Council did not adopt these recommendations. 

The Council did adopt, in the 2000 Program and in the 2003 Mainstem Amendments, habitat objectives and strategies for enhancing mainstem and tributary habitat, providing appropriate fl ows and working toward more natural 

hydrographic patterns as key to that habitat quality. The Council also adopted a provision in the 2000 Program for 

funding water acquisitions as one of the strategies in a habitat-based program. The Council concludes that this is 

appropriate guidance for the Council to provide on these types of issues at the system level. The states and others 

involved in water allocation and water rights matters are encouraged to manage their water allocation issues within 

this context. To the extent that specifi c areas have water quantity problems, the Council defers consideration of 

those matters to the relevant subbasin plans, including the individual mainstem reach plans, that will be prepared 

and proposed for inclusion in the program.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 71

Recommendation No. 7: United States Environmental Protection Agency

The Environmental Protection Agency recommended that the Council’s mainstem amendments refl ect or incorporate the priorities, schedules and work efforts of the joint state, EPA and tribal effort to establish state and tribal standards under the Clean Water Act for temperature and dissolved gas in the mainstem Columbia and Snake rivers. The 

Council adopted a general objective of meeting state and federal water quality standards under the Clean Water Act.
72 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

States and State Fish and Wildlife Agencies

Recommendation No. 6: Washington Department of Fish and Wildlife

The Washington Department of Fish and Wildlife recommended a number of strategies and ecosystem objectives, including:

• include the elements of the biological opinions as the base for mainstem operations and hydrosystem 

confi guration to address ESA-listed fi sh;

• because the Council has the responsibility to provide additional actions to accommodate non-listed species and 

the broader mitigation objectives under the Power Act, integrate into the program elements of such plans as 

the draft Chelan/Douglas Public Utility District Habitat Conservation Plan, the Vernita Bar Agreement, and the 

Grant Public Utility District Spill Memorandum of Agreement;

• improve the health of the estuary and the river below Bonneville Dam;

• protect the limited amount of mainstem spawning habitat for salmon and sturgeon below Bonneville Dam;

• mitigate for the coastal and nearshore fi sh and wildlife losses due to hydrosystem-induced changes to the 

Columbia River plume;

• improve upstream and downstream migration survival rates through the hydro system; improve the 

operational reliability of juvenile and adult fi sh passage facilities, in particular the reliability of adult 

attraction water supplies;

• maintain the ecological integrity of the Hanford Reach, particularly by addressing the negative impacts of 

slumping at the White Bluffs; take further actions to limit fry stranding and entrapment of Hanford Reach 

fall chinook;

• preserve and enhance white sturgeon populations throughout the mainstem, including the discontinuous 

populations above Bonneville Dam;

• in blocked areas such as Lake Roosevelt, support efforts to maintain the resident fi sh communities that serve as 

ecological, cultural and economic substitutes for lost anadromous populations;

• manage predator populations that have benefi ted from ecosystem alterations (such as the Northern Pikeminnow, 

spiny rays, cormorants and Caspian Terns), and whose predation rates on native fi sh populations are 

considerably elevated over historical levels, to minimize negative impacts on salmon;

• continue mitigation for hydrosystem operational impacts on currently established riparian zones, 

while recognizing that mitigation for construction losses to inundated riparian zones has been largely 

accomplished;

• develop a coordinated information system — efforts currently underway through the Regional Assessment 

Advisory Committee should help frame that need.

The Council adopted provisions consistent with the bulk of the department’s recommendations, including provisions that:

• incorporate the elements of the biological opinions as the program’s base for mainstem operations and 

hydrosystem confi guration;

• recognize the responsibility for accommodating non-listed species and the broader mitigation objectives under 

the Power Act as described above;
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 73

• call for priority protection for the Hanford Reach habitat and protection of and improvements in spawning and 

rearing fl ows for fi sh that spawn there;

• call for protecting and increasing the limited amount of other spawning habitat in the mainstem;

• allow for review and the possibility of endorsement of habitat conservation plans;

• include objectives and strategies for protecting and improving habitat conditions in the estuary and near-shore 

area, especially as related to hydrosystem-induced changes to the Columbia River plume;

• emphasize the need for improvements in upstream and downstream migration survival rates through the hydro 

system, including the need to improve the overall effectiveness of the adult fi sh passage facilities;

• include objectives and strategies for protecting and enhancing abundance and productivity of white sturgeon 

populations throughout the mainstem, including the discontinuous populations above Bonneville;

• support the efforts in Lake Roosevelt to protect and increase important resident fi sh communities as substitution 

for lost anadromous populations; and

• call for protection and improvements in riparian habitat to increase the survival and production of wildlife 

species in the mainstem affected by the development, operation, and management of the hydrosystem.

The department’s recommendation did not call for specifi c operations for salmon and steelhead (or for resident 

fi sh) that would be in confl ict with the operations that are called for, or are possible to accommodate, under the biological opinions. In the event the department’s recommendations could be interpreted to call implicitly for operations beyond the biological opinions, that way, the Council did not adopt that approach, for the reasons given in 

General Finding Nos. 2 and 3.

The department also recommended that the Council take action to help resolve the power supply problems that led 

to curtailment of fi sh operations in 2001, so that fi sh operations become a hard constraint on system operations and 

curtailments of fi sh operations are not used in lieu of establishing an adequate and reliable power supply. General 

Finding No. 5 (and see the accompanying discussion of the power supply issue) and the discussion in response to the 

similar recommendation of the Columbia Basin Fish and Wildlife Authority respond to this recommendation..

Recommendation No. 5: State of Oregon

Recommendation No. 14: Idaho Department of Fish and Game

The State of Oregon, through the Oregon Department of Fish and Wildlife, submitted extensive recommendations in all mainstem areas, including a signifi cant set of water management, fl ow and spill measures for salmon 

and steelhead, many of them different from NOAA Fisheries’ biological opinion.

Recommendations in this latter category included increased spring and summer fl ow objectives at Lower Granite 

Dam and increased fall/winter fl ow objectives at Bonneville; increased summer drafts from storage projects under certain 

conditions; additional water out of the upper Snake and out of the Canadian part of the Columbia; implementation of the 

VARQ fl ood control modifi cation at Libby and Hungry Horse only under certain conditions; increased spill at The Dalles 

and the Snake projects; and a juvenile transportation operation that would reduce juvenile transportation under low fl ow 

conditions. The Council did not adopt these recommendations, as explained in General Finding No. 2.

On the other hand, Oregon recommended a number of measures for salmon and steelhead consistent with the biological opinions, and the Council adopted these provisions by incorporating the measures of the opinions into the pro-
74 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

gram and in some cases by adopting or emphasizing provisions of interest to Oregon, if not always as detailed. This 

includes recommendations and program amendments calling for:

• systemwide review of fl ood control;

• fl ow and spill operations that match the biological opinion measures;

• a program objective to meet state and federal water quality standards under the Clean Water Act, refl ecting 

specifi c Oregon recommendations for long-term actions to meet temperature, gas and toxic standards;

• objectives and strategies to protect biodiversity and favor fi sh passage methods that are consistent with natural 

fi sh migration and river processes;

• continued support for the “spread-the-risk” transportation approach and the concept of improving in-river 

conditions to reduce the need to rely on transportation;

• recognition that spillway passage continues to be an effective inriver passage route, more benign in general than 

juvenile bypass systems;

• dam modifi cations and passage improvements such as spillbay defl ectors, removable spillway weirs, and 

surface bypass collectors, as well as improvements in turbine design and operation;

• necessary planning and evaluations to ensure that alternative actions including breaching of Snake River dams 

can be implemented on a timely basis if non-breach alternatives fail to meet ESA performance standards for 

the listed Snake River populations (Oregon recommended that such an action is consistent with the NOAA

Fisheries biological opinion; the Council stated that its policy on breaching is consistent with the approach of 

NOAA Fisheries); and

• improvements in annual and in-season decisionmaking on hydrosystem operations by constructing a hydro 

operations decisionmaking forum that includes state, tribal and federal management expertise in both biological 

and power system issues.

Oregon also recommended a set of amendments relating to white sturgeon, bull trout, resident fi sh in general, 

and wildlife. The Council adopted provisions consistent with these recommendations, if often not as detailed. For 

example, Oregon recommended a set of objectives and actions to benefi t white sturgeon, including a particular 

McNary operation to optimize spawning. The Council adopted an objective of enhancing the abundance and productivity of white sturgeon to rebuild and sustain naturally spawning populations and harvest, including operating 

the hydrosystem to maximize spawning and rearing success. For wildlife, Oregon recommended protecting and 

improving riverine and riparian habitats and reducing limiting factors to wildlife in the mainstem; the Council 

adopted an objective to that end.

Finally, Oregon recommended improvements in the way the power system is developed and managed so that 

hydrosystem operations to meet fi sh and wildlife needs are viewed as minimum environmental compliance standards for the hydropower system, just as air quality standards are minimums for fossil fuel power plants. The 

region’s power supply system should be designed and operated to meet power needs while ensuring that appropriate hydro system operations for fi sh and wildlife recovery are provided in all years. General Finding No. 5, the 

accompanying discussion of the power supply issue, and the discussion in response to the similar recommendation 

of the Columbia Basin Fish and Wildlife Authority respond to this recommendation.

The Idaho Department of Fish and Game recommended a set of amendments similar to Oregon’s in approach, 

if not as extensive and with some differences in detail. The explanation as to how the Council addressed Oregon’s 

recommendations applies here as well. For example, the department recommended a few operations for salmon 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 75

and steelhead additional to or different from the biological opinion (such as 24-hour spill to higher gas caps in certain instances) that the Council did not accept, for the reasons explained in General Finding No.2. On the other 

hand, the department emphasized a set of salmon and steelhead provisions that are consistent with how the Council understands the biological opinions, such as fl ood control evaluations; measures to reduce water temperatures; 

juvenile transportation operations and evaluations; general principles regarding passage; adult passage improvements; and more. The Council adopted provisions consistent with the recommendations. Finally, the department 

recommended smolt-to-adult survival rates that the Council adopted as an interim objective.

Recommendation No. 12: Montana Department of Fish, Wildlife and Parks

The Montana Department of Fish, Wildlife and Parks recommended a set of objectives and strategies intended 

to improve habitat conditions for listed and non-listed resident fi sh in the headwater storage reservoirs and the 

stretches of river below their dams, especially Hungry Horse and Libby dams in Montana, and for wildlife in the 

areas affected by the headwater reservoirs. These recommendations include:

• restore populations of native fi sh and wildlife to self-sustaining levels capable of supporting harvest;

• restore normative conditions in the seasonal pattern and stability of river discharges and reservoir conditions;

• operate dams to provide reservoir operations that are consistent with VARQ and IRC concepts by 2002;

• reduce the frequency of refi ll failure (to within fi ve feet of full pool) at Hungry Horse and Libby Reservoirs as 

compared to historic operations;

• implement seasonal fl ow windows and fl ow ramping rates in the Flathead and Kootenai Rivers downstream of 

the storage reservoirs; establish a gradual ramp-down of river fl ows after the spring runoff to maintain stable 

discharges, especially during the biologically productive summer months, to benefi t native species;

• mitigate impacts in the rivers below Libby and Hungry Horse Dams by planning a steady draft from July 

through September; the standard should be a 10-foot draft, not 20;

• maintain minimum fl ows in the Flathead and Kootenai Rivers;

• reduce runoff forecasting error by increasing the number of snow monitoring sites and improved remotesensing technology;

• re-vegetate the top 20 feet of the varial zone in Hungry Horse and Libby reservoirs (where possible in low 

gradient areas);

• protect, restore, and enhance riparian/wetland habitat above and below Hungry Horse and Libby Dams, meeting 

the annual goals set forth in management and mitigation plans;

• restore in-channel habitat structure, function, and complexity;

• restore riparian and wetland habitats and fl oodplain function;

• complete an operational impact assessment and develop plans to mitigate for any impacts that the operations 

of Hungry Horse and Libby Dams may cause to the development and successional trends of riparian wildlife 

habitats and their associated aquatic components, in cooperation with ongoing fi sheries mitigation activities;

• maintain temperatures within the tolerance range of native fi sh species;

• operate selective withdrawal devices at Hungry Horse and Libby Dams to mimic the natural thermal regime in 

the rivers downstream;

• improve riparian and in-stream habitat using stream channel and riparian habitat restoration methods;

• meet the federal Clean Water Act TMDL (Total Maximum Daily Load) goal for reduction in phosphorus;
76 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• support new techniques for bank stabilization as alternatives to the standard riprap material (these new 

techniques would serve as demonstration models for the reduction of sediment to the mainstem and lakes);

• protect critical wetland and riparian habitats through acquisition or conservation easements; identify and rank 

all high priority areas and establish purchase/protection mechanisms; and

• work with the Focus Watershed Coordination projects in the Flathead and Kootenai drainages to identify sitespecifi c wetland/riparian restoration projects and coordinate with landowners, agencies and other funding sources.

The Council adopted mainstem amendments largely consistent with these recommendations, at least with respect to:

• general objectives and strategies for mainstem habitat;

• general objectives and strategies regarding riparian, wetland and fl oodplain habitat for fi sh and wildlife affected 

by the hydrosystem;

• objectives and strategies toward more natural hydrograph patterns, which include matching seasonal patterns 

and the stability of river discharges and reservoir conditions;

• the VARQ fl ood control strategy implementation, which is in the biological opinions;

• the minimum fl ow regimes for sturgeon and bull trout, consistent with the Fish and Wildlife Service’s 

biological opinion and these recommendations; and

• a general objective of meeting Clean Water Act water quality standards, which would include a TMDL for 

phosphorus. 

The summer operation recommended for Hungry Horse and Libby is not consistent with the current summer operation for those dams under the salmon and steelhead biological opinion. For that reason, the Council did not adopt the 

recommendation in the sense of simply calling for its implementation. However, the Council believes it is possible to 

test these operations under the biological opinions, calling for their implementation as an experiment with the hypothesis that the proposed operations will signifi cantly benefi t listed and non-listed resident fi sh in the reservoirs and in the 

portions of the rivers below the reservoirs without discernible effects on the survival of juvenile and adult anadromous 

fi sh when compared to ordinary operations under the biological opinions. General Finding No 3; see also General 

Finding No. 2.

Finally, the department’s recommendation contained a number of specifi c habitat actions in the areas affected by 

the existence and operation of Hungry Horse and Libby dams. These would be more appropriate to consider as part 

of the subbasin plans for those areas.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 77

Indian Tribes

Recommendation No. 1: Columbia River Inter-Tribal Fish Commission

The Columbia River Inter-Tribal Fish Commission (CRITFC) provided by far the most extensive set of mainstem 

recommendations. The recommendations included a set of new objectives and measures, as well as an edited version 

of the mainstem sections from the 1994 program, retaining much of the detail. The summary here is intended to capture the range of topics included in the recommendations, with special emphasis on what is new and on the topics the 

Commission itself emphasized; the full details of the Commission’s recommendations are on the Council’s website 

at http://www.nwcouncil.org/library/recommend/mainstem/01.htm. Scientifi c reports and other documents submitted 

by the Commission in support of the recommendations can be found in the bound volumes of the recommendations, 

Council Document No. 2001-16, Vol. 1.

Mainstem habitat

As a general matter, all of the recommendations of the Commission were intended to improve habitat conditions in 

the mainstem for salmon and steelhead and other species that spawn, rear, rest or migrate through the mainstem Columbia and Snake rivers. Recommendations specifi cally focused on systemwide water management and on migration passage are addressed further below; in this section the focus is on recommendations that either generally concerned habitat 

conditions and population responses or that were specifi cally focused on protecting and increasing mainstem spawning 

and rearing habitat. A summary of the recommendations for mainstem habitat objectives and strategies includes:

• emphasize healthy rivers and watersheds with abundant and diverse species assemblages and their management, 

maintenance and restoration, with particular attention to ecosystem diversity, productivity and stability;

• emphasize natural production of fi sh provided by such rivers and watersheds;

• reintroduce and restore anadromous fi sh to the rivers and streams that historically supported them, in numbers 

suffi cient to provide for the needs of the ecosystem and people, in perpetuity;

• protect critical estuary habitat and restore former estuary habitat; restrict new dredging and improve existing 

dredging management practices;

• confi gure and operate the hydrosystem to:

− maximize inriver juvenile anadromous fi sh survival and health consistent with fl ows and dam and reservoir 

operations established in the CRITFC 2000 and 2002 River Operations Plans;

− maximize adult anadromous fi sh health, survival and spawning capacity;

− maintain, protect and enhance currently healthy natural riverine conditions and habitat;

− restore, rebuild and reclaim such conditions and habitat where they have been altered or destroyed;

• increase smolt-to-adult return rates to 4-6 percent for Snake River and upper Columbia salmon and steelhead 

by 2008;

• reduce pre-spawning mortality by 50 percent by 2006;

• improve water quality in the mainstem Columbia and Snake rivers by:

− meeting the gas supersaturation and temperature standards under the Clean Water Act;

− reducing or eliminating toxic pollution sources and other contaminant discharges in compliance with 

applicable water quality criteria (at a minimum);

• protect the Hanford Reach — re-establish normative river conditions in the Hanford Reach and designate the 

reach under the federal Wild and Scenic Rivers Act;
78 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• passage behind barriers — develop juvenile and adult anadromous fi sh passage capabilities, employing any and 

all possible biological, engineering/technological, legal, political and societal means, to circumvent the current 

artifi cial barriers to anadromous fi sh migration at Chief Joseph and Grand Coulee dams, Dworshak Dam and 

the Hells Canyon Complex (Hells Canyon, Oxbow and Brownlee dams);

• restore normative river conditions to provide spawning, resting and rearing habitat for salmon and steelhead in 

the mainstem of the Columbia and Snake rivers by 2006;

• provide a mainstem hydrograph that resembles the shape of the normative hydrograph;

• provide 9,000 acres of spawning habitat for Snake River fall chinook by 2006; and

• provide 40 miles of fl uvial spawning habitat for mid-Columbia fall chinook core populations identifi ed by the 

Independent Scientifi c Group in Return to the River 2000 (Council Document 2000-12) by 2008.

The Council adopted a signifi cant set of objectives and strategies to identify, protect, restore and extend 

mainstem habitat, consistent with and in signifi cant part based on the recommendations of the Commission. These 

provisions focused on protecting, restoring and enhancing the river’s ecological functions for spawning, rearing, resting and migrating salmon and steelhead to sustain abundant, productive and diverse populations and communities. 

Consistent with the recommendations summarized above, these habitat provisions emphasized such matters as:

• managing the water through the system to more closely approximate natural hydrographic patterns;

• an emphasis on allowing biological diversity to increase among and within populations and species to increase 

ecological resilience to environmental variability;

• protecting, enhancing, restoring and connecting ecosystem functions in the Columbia River estuary;

• meeting state and federal water quality standards under the Clean Water Act, including actions to reduce 

toxic contaminants;

• an interim objective pending further consultations of contributing to achieve smolt-to-adult return rates in the 2-

6 percent range;

• an objective to “increase the amount of spawning habitat for fall chinook core populations in the lower and 

mid-Columbia area and in the lower Snake area,” which recognized the Commission’s recommended numerical 

target but then called for consultation with others before considering actual adoption of numerical objectives;

• specifi c protection for the Hanford Reach (the Council did not call for designation of the reach under the Wild 

and Scenic Rivers Act, as that is out of the reach of the federal operating agencies to whom the program is 

primarily addressed); and

• restoration of anadromous fi sh into mainstem areas currently blocked by dams, where feasible.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 79

Water Management

Moving the system back to a natural hydrograph was the keystone to the Commission’s overall objective of creating the appropriate habitat conditions for salmon and steelhead and other fi sh in the Columbia. The Commission 

recommended:

Overarching objectives of water management

Manage water resources to mimic more closely the natural, historic river hydrograph (for example, through 

improved utilization of water from Canadian storage, Banks Lake and various irrigation projects) but maintain, to the 

maximum extent practicable, full, stable water levels in Lake Roosevelt and in Libby, Dworshak and Hungry Horse 

reservoirs according to their Integrated Rule Curves and consistent with the Council’s fi sh and wildlife program:

• restore normative river conditions to provide spawning, resting and rearing habitat for salmon and steelhead in 

the mainstem of the Columbia and Snake Rivers by 2006;

• provide a mainstem hydrograph that resembles the shape of the normative hydrograph;

• improve conditions for salmonid production by increasing fl ow and water velocity, decreasing downstream 

migration time for anadromous fi sh and decreasing the quantity of habitat for predatory and competing fi sh 

species while endeavoring to provide inriver conditions to maximize adult fi sh survival between dams, and 

while providing reservoir and river conditions to protect resident fi sh;

• manage storage and fl ood control to provide fl ood peaks and fl oodplain habitat; and

• manage water to eliminate stranding and other problems associated with the use of the hydrosystem especially 

for peaking purposes.

Natural hydrograph strategy and fl ow targets

• Modify the current fl ow management strategy in which seasonal targets have not been met on a seasonal, 

weekly or daily basis. Also, the existing operating strategy of seasonal, fl at-target fl ows fails to protect salmon 

in early portions of emergence and migration periods before April 10 and after the planning date of August 31. 

The planning dates for the salmon migration should be modifi ed to begin on March 20 and end on September 

30; over 80 percent of the adults migrate through the mainstem after August 31.

• Reshape river runoff to a normative hydrograph. Use state-of-the-art forecasting tools and sliding scales 

appropriate for the runoff year, with a peak that is timed to that of predevelopment runoff at each one of the three 

major river points — Lower Granite, Priest Rapids and The Dalles. Table 1 specifi es peak fl ow levels at the three 

major index sites for low, medium and high fl ow years, based on January-July runoff:

Table 1. Sliding Scale Normative Hydrograph Peak Flows

Index Site Low (52-84 maf) Medium (85-105 maf) High (>106 maf)

The Dalles 336 kcfs 420 kcfs 504 kcfs

Priest Rapids 249kcfs 300 kcfs 360 kcfs

Lower Granite 90 kcfs 120 kcfs 156 kcfs

• Use fl ow augmentation, changes in fl ood control and other actions as needed, implemented through fi rm power 

planning, to meet sliding-scale fl ow augmentation targets at The Dalles, Priest Rapids and Lower Granite 

dams, based on the January-July runoff volume forecast on April 1. Achieve a peak hydrograph of at least 420 
80 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

kcfs at The Dalles in average water years and a sliding scale based on the January-July runoff at The Dalles in 

other water years. Achieve peak hydrographs at Lower Granite and Priest Rapids dams. For average volume 

forecasts, use normative fl ow values shown in Table 2, below. For above-average volume forecasts, use 120 

percent of the normative fl ows (130 percent for Lower Granite Dam). For below-average volume forecasts, 

use 80 percent (The Dalles), 83 percent (Priest Rapids), or 75 percent (Lower Granite) of the normative fl ows. 

Table 2 shows the recommended fl ows (in kcfs) for an average water year to create a normative hydrograph:

Flow (kcfs) Lower Granite Priest Rapids The Dalles

January 30 70 125

February 40 70 125

March 1-15 40 70 130

March 16-31 50 90 150

April 1-15 70 140 220

April 16-30 80 170 270

May 1-15 100 240 370

May 16-31 120 260 390

June 1-15 110 300 420

June 16-30 90 275 380

July 1-15 50 240 300

July 16-31 45 195 250

August 1-15 40 175 220

August 16-31 40 150 195

Sept.1-15 35 130 170

Sept.16-30 30 95 130

October 20 80 110

November 30 70 125

December 30 70 125

• Limit chum spawning, incubation and early emergence fl ows below Bonneville Dam to 125 kcfs.

• Maintain fl ows at the Hanford Reach at no more than 70 kcfs during daylight hours and nighttime moonlight 

hours of the adult bright fall chinook spawning period (approximately October 20- November 22). Ensure, 

with the assistance of the Mid-Columbia public utility districts, that Hanford Reach fall chinook fry are 

provided with an increasing hydrograph from March 15- June 20 as measured on a daily basis.

• Make available, on a real-time basis, runoff, reservoir storage, hydrological and system operating model 

results to tribes and federal and state fi sh and wildlife agencies to enable timely and informed fi sh migration 

operational decisions.

• Once the normative hydrograph is established in any particular year, the federal operators should meet 

recommended fl ow regimes on at least a weekly basis.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 81

Specifi c strategies to achieve fl ow objectives

Flood control:

• Modify fl ood control to provide for fi sh fl ows, reservoir refi lls and energy production. The Corps of 

Engineers should relax and seek fl exibility in rigid, overly conservative fl ood control rule curves to recreate 

normative hydrographs, reclaim mainstem and estuarine fl oodplain habitat and ensure that storage reservoirs 

meet biological criteria. Flood peaks and fl oodplain habitat are key factors in regulating the existence and 

productivity of fi sh populations. 1-3.5 million acre feet of water could be made available for spring and 

summer salmon migrations basinwide by incorporating more fl exible fl ood control management:

- Use state-of-the-art forecasting tools to implement necessary fl ood control fl exibility to meet reservoir 

elevation objectives and normative hydrograph index points described above to meet at least a 420 kcfs peak 

at The Dalles in early June for all runoff years.

- Seek fl exibility in fl ood control in storage reservoirs basinwide.

- Manage late fall and winter fl ood control releases of Bureau of Reclamation storage in upper Snake 

reservoirs during late August and September to augment fl ows for adult fall chinook and steelhead. Data 

from the Bureau of Reclamation indicate that many upper Snake River reservoirs are near full during the 

late summer and fall months and must be evacuated for fl ood control in the winter.

- BPA shall purchase at least 0.5-1 MAF of fl ood control storage space from Canadian entities to store 

water to create the normative hydrograph and to ensure that storage reservoirs meet IRC and other 

biological criteria.

- In the long term, complete and implement a basin-wide review of fl ood control focusing on additional fl ood 

control fl exibility.

Reservoir Storage and Flow Augmentation:

• Develop a coordinated plan of operation for fl ow augmentation as part of effort in meeting fl ow targets.

• Reservoir storage should be managed to meet normative hydrograph objectives, IRCs and other biological criteria.

• Grand Coulee, Libby and Hungry Horse dams:

- The normative river concept calls for stabilizing upstream storage reservoirs by using integrated rule curves 

and other biological curves established for Libby, Hungry Horse and Grand Coulee dams consistent with the 

fi ndings of the ISAB.

- The order of priority for releasing water from Columbia upstream reservoirs for fl ow augmentation should 

be Grand Coulee, Libby and Hungry Horse dams.

- Operate Libby and Hungry Horse to integrated rule curves and stabilize Lake Roosevelt to elevation 1283 

during August and September. In order to assure these criteria, at least 500 kaf of water intended for Banks 

Lake should remain in Lake Roosevelt.

- Do not fi ll Lake Roosevelt above elevation 1283 during September, but pass all infl ows to the lower 

Columbia.

- Complete gas abatement structural designs to reduce total dissolved gas from Grand Coulee Dam to meet 

water quality standards. Investigate alternatives that can result in temperature control as well as gas 

abatement. Seek funding to implement the alternative that best meets both temperature and gas standards by 

December 2005.
82 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• Dworshak Dam:

- Normative river concept calls for stabilizing upstream storage reservoirs by utilizing integrated rule curves 

and other biological curves established for Dworshak consistent with the fi ndings of the Independent 

Scientifi c Advisory Board.

- Follow the Nez Perce Tribe and State of Idaho Management Plan. Flexibility is needed in the timing of 

Dworshak fl ood control evacuations. There should be water for a spring and August peak of 14 kcfs. 

During spring keep the reservoir near full in order to sustain the 14 kcfs fl ows. In augmenting fl ow 

for Snake River spring migrants, limit outfl ow to 12 kcfs unless temporary gas variances and approval 

have been obtained from the Nez Perce Tribe and the State of Idaho. The reservoir should be fi lled to 

elevation 1600 by early June. Keep Dworshak full until August 1 unless water quality concerns force 

earlier evacuation. Flows for the fi rst half of September should be 12 kcfs to support adult passage in the 

Clearwater and fl ush remaining juveniles.

- The Corps of Engineers shall operate Dworshak to elevation 1600 by August 1.

- Allow Dworshak to draft to elevation 1,520 feet by the end of September, if needed to assist in meeting the 

summer basin fl ow and velocity objectives. Concurrence by the Nez Perce Tribe and the State of Idaho is 

necessary to use storage below elevation 1520 feet. Seek funding assistance for necessary modifi cations to 

recreational and commercial facilities to allow Dworshak Reservoir to operate at reduced levels to improve 

survival of fall chinook.

- Continue to evaluate whether releasing cool water from both Dworshak Dam and the Hells Canyon 

Complex during August and September improves adult fall chinook survival.

• Brownlee Dam:

- FERC should require Idaho Power Company to use upper Snake water to keep the Brownlee reservoir near 

elevation 2058 and pass all additional fl ow. Brownlee should remain near full pool until storage is needed to 

augment fi sh fl ows.

- As needed to meet operational fl ow or temperature objectives, operate Brownlee Dam to provide up to 

110,000 acre-feet of water in the spring for fl ow augmentation. Pass infl ow in June (do not refi ll). Draft 

Brownlee to a minimum of elevation 2,067 to provide up to 137,000 acre-feet in July. Pass through the 

full complement of upper Snake water provided by the Bureau of Reclamation in June, July and August. 

Provide at least 100,000 acre-feet in September.

- Continue to evaluate whether releasing cool water from both Dworshak Dam and the Hells Canyon 

Complex during August and September improves adult fall chinook survival.

- Investigate and implement operations and confi gurations to reduce total dissolved gas from the Hells 

Canyon Complex as necessary to meet water quality standards.

• Additional water — Snake and Columbia:

- The Bureau of Reclamation, Bonneville and the states to provide: By 2002, an additional 500,000 acre-feet 

of water from the Snake River Basin; by 2003 a further 500,000 acre-feet; and by 2005 a further 500,000 

acre feet (for a total of 1,500,000 acre-feet over and above the 427,000 acre-feet currently called for) to 

augment fl ows in the lower Snake River in the April 10 through the September 30 time period. All water 

should be used to benefi t both Snake and Columbia river migrants, with no corresponding reduction in 

Columbia River fl ows unless the Columbia River fl ow/velocity objective is being met. This water may 

be obtained through willing seller/buyer transactions, other non-structural approaches, new storage or a 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 83

combination of such alternatives. The states should cooperate to ensure that this water will be allowed to 

move freely downstream, undiminished by diversion.

- Reclamation to secure an additional 0.5 maf from Banks Lake and/or the Columbia Basin Project to enhance 

fl ows and reservoir storage requirements.

- Bonneville shall purchase an additional 1 maf from Canadian storage.

Seasonal Drawdowns:

• Implement an experimental drawdown of Lower Granite Reservoir to elevation 723 by June 20 to augment 

the declining Snake River hydrograph and to improve critical rearing habitat and passage for subyearling fall 

chinook. Do not fi ll the reservoir until October 31, after adult migrants have passed upstream of the reservoir. 

Operate the remaining Lower Snake reservoirs at Minimum Operating Pool until November 1.

• Drawdown and maintain John Day and McNary reservoirs to plus or minus 1.5 feet of minimum operating pool 

from March 20-October 31.

Power peaking, ramp fl ows, stranding and other problems associated with fl uctuations of the hydroelectric system

• Manage water to eliminate stranding and other problems associated with the use of the hydrosystem, especially 

for peaking purposes.

• To prevent stranding of juvenile migrants and to maintain riparian community integrity, Dworshak releases 

should be ramped at a rate of 6 inches per hour as measured at the Clearwater gauge below Dworshak Dam. 

Adjust Dworshak release temperatures to meet the 68-degree water quality standard at Lower Granite Dam.

• In the Hanford Reach, for naturally spawning fall chinook, reduce power peaking from federal projects 

upstream to ramp fl ows at a rate of no more than 2 inches per hour during the early emergence of Hanford fry 

(March 20-April 20). Comply with the spawning and emergence fl ow plan for Vernita Bar incorporated into 

the FERC license for Priest Rapids Dam. Annually implement a fl ow plan that reduces fl uctuations to no more 

than plus or minus 10 percent of daily average fl ows for the previous 24-hour fl ow period from the time of 

emergence to the time that Hanford fry have migrated from shoreline areas, as determined by tribes and fi shery 

agencies. Consider amending the Vernita Bar Agreement to include the stranding fl ow plan; continue to fund 

fi shery agency and tribal monitoring of juvenile stranding in the Hanford Reach; expand funding to increase the 

robustness of loss estimates.

• At the Hells Canyon Complex, limit all fl ow reductions by ramping rates of no more than 6 inches per hour 

as measured at Lime Point. Such impacts have caused fi shery managers to invoke ramping rate criteria to 

limit power peaking activities in tributaries to less than a two-inch per hour change to shoreline areas. Modify 

operation of the Hells Canyon Complex to provide coordinated fall and spring fl ows below Hells Canyon Dam 

to maintain fall chinook spawning, incubation and emergence. Evaluate options for providing more water 

from Brownlee, including substantially improved ability to shape water from Snake River Basin for spring and 

summer migrants, and mechanisms for selected cool water releases.

The Council adopted a number of provisions that are consistent with, if far from as detailed as, key elements of the 

Commission’s water management recommendations. The Council’s central strategy for water management, consistent 

with the Commission’s approach, is to manage water so that patterns of fl ow more closely approximate the natural hydrographic patterns and are directed at re-establishing natural river processes where possible. Particular ways in which the 

adopted amendments refl ect the Commission’s recommended principles is shown in this detail from the program:
84 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• Manage water through the hydrosystem so that patterns of fl ow more closely approximate the natural 

hydrographic patterns and are directed at re-establishing natural river processes where feasible, and produce the 

highest possible survival rates for a broad range of affected fi sh within the physical limitations of the multiple 

purposes of the region’s storage reservoirs and hydrosystem. Ensure that any changes in water management are 

premised on, and proportionate to, fi sh and wildlife benefi ts, while assuring the region an adequate, effi cient, 

economical, and reliable power supply. Elements of this general strategy for water management include:

1) Frame habitat restoration in the context of measured trends in water quantity and quality.

2) Allow for seasonal fl uctuations in fl ow, including fl oods. Reduce large and rapid short-term fl uctuations. 

Reduce or eliminate stranding and other problems associated with fl uctuation of the hydroelectric system.

3) Increase the correspondence between water temperatures and the naturally occurring regimes of 

temperatures throughout the basin. To the extent possible, use stored water to manage water temperatures 

below the storage reservoirs where temperature benefi ts from releases can be shown to provide improved 

fi sh survival.

4) Identify, protect, and restore ecosystem functions in the Columbia River estuary and nearshore ocean 

discharge plume as affected by actions within the Columbia River hydrosystem. This includes evaluating 

fl ow effects, river operations and estuary-area habitat changes, as well as local effects from activities such as 

dredging and pollution from urban areas, to better understand and improve the relationship between estuary 

and near-shore plume characteristics and the productivity, abundance and diversity of salmon and steelhead 

populations.

• Systemwide water management, including fl ow augmentation from storage reservoirs, should attempt to meet the 

needs of anadromous and resident fi sh species in the river and upstream storage reservoirs so that actions taken to 

benefi t one species do not unnecessarily come at the expense of other species. Flow augmentation is defi ned as 

the intentional release or drafting of water from storage reservoirs for the purpose of increasing fl ows to enhance 

migratory conditions for juvenile and adult life-stages of salmon and steelhead through the reach of the lower river 

hydroelectric dams. The federal system operators, NOAA Fisheries and the U.S. Fish and Wildlife Service should 

identify potential confl icts and seek recommendations from the Council, fi sh and wildlife agencies, tribes, and 

other affected entities on how best to balance the different needs prior to the implementation of fl ow actions.

Also consistent with the Commission’s recommendations, the Council’s mainstem amendments attempt to stabilize the reservoir levels and the hydrograph out of the upstream storage reservoirs to protect and enhance resident 

fi sh in the reservoirs and in the river stretches below, through such mechanisms as the integrated rule curve operations for Hungry Horse and Libby and the Idaho management plan at Dworshak. The Council also calls for priority 

protection of the conditions for the Hanford Reach population, by calling for the system operators to:

Manage fl ows, while maintaining consistency with this mainstem plan’s fl ow and reservoir operations, to 

protect, improve, and expand spawning, rearing, and resting habitat in the mainstem and estuary. In particular, the federal and non-federal project operators should provide suitable and stable fl ows to establish 

and protect the habitat conditions necessary for spawning and rearing in the Hanford Reach on an equal 

basis with managing water to support the migration of listed species. This includes providing the fl ows 

required by the Vernita Bar agreement and by subsequent agreements to extend stable fl ows to reduce or 

prevent stranding problems in the reach. It also includes the need for the Bureau of Reclamation, as the 

operator of Grand Coulee Dam, and the operators of the mid-Columbia projects to take the steps necessary, separately and together, to further reduce fl ow fl uctuations through the reach that affect spawning 

and rearing.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 85

The Commission recognized that to implement its approach fully — to achieve a more natural hydrograph and 

higher fl ows in spring and summer for salmon while protecting reservoir values in spring and especially summer 

and providing the other fl ow benefi ts called for through the year — ultimately would require a signifi cant re-thinking of fl ood control operations, so as not to draft the reservoirs too deep for fl ood control and allow more water to 

fl ow through the system at its normative time and not be captured, while still providing the fl ood protection needed 

for the health and safety of the river’s residents. The Council followed the Commission’s recommendation in the 

sense of calling for the Corps of Engineers to “place a priority on conducting the further comprehensive review of 

fl ood control operations called for in the NOAA Fisheries 2000 Biological Opinion.”

The Council did not adopt other elements of the Commission’s water management recommendations, especially the 

recommendations for fl ow targets in the lower river and at Priest Rapids Dam and for the management of the current 

storage (pending further fl ood control changes) to meet those targets that are different from and greater than what are 

called for in the objectives and measures in the biological opinions. The reasons the Council rejected these recommendations are given in General Finding No. 2. As noted just above, the Council agreed with the Commission in terms 

of the general principles that should guide planning and decisions for water management, especially in the long term. 

And the Council reiterates that rejecting these recommendations does not mean the Council has evaluated the science 

underlying the different positions and concluded that NOAA Fisheries is correct and the Commission is incorrect in what 

current operations best meet these principles. Nor does it mean that the Council gave greater weight to the biological 

judgments of the federal agencies and less or none to the judgments of the tribes. The Power Act requires the Council to 

give special consideration to program amendment recommendations from these tribes, and the Council recognizes that 

recommendations of the tribes are based in legitimate interpretations and meanings to be drawn from imperfect scientifi c 

information (if different from the interpretations of the federal agency) and from different managerial perspectives and 

assumptions of risk. Time and more information may reveal that NOAA Fisheries is not correct and the Commission is 

correct in the conclusions about what operations are needed for salmon and steelhead. But the evaluation and adaptive 

management framework embedded in the biological opinion measures is the framework in which to pursue these issues.

Passage (spill, bypass systems, transportation, dam breaching)

Here again the Commission presented the Council with an extensive and well articulated set of recommendations. A summary of the Commission’s passage recommendations includes:

Basic approach/general passage objectives and strategies

• two biological principles in particular should guide decisions about how to meet standards for fi sh passage 

through the hydrosystem:

- protect biodiversity — passage solutions must be designed to benefi t the range of species, stocks and lifehistory types in the river, which may require multiple passage solutions at a project

- favor passage solutions that best fi t natural behavior patterns and river processes — the best passage 

solutions are those that take into account and work with the behavior and ecology of the species and lifehistory types using the river system, that mimic the natural situations and processes that migrating salmonids 

encountered in their evolutionary history;

• ensure 80 percent fi sh passage effi ciency between 2001 and 2004, and 90 percent fi sh passage effi ciency after 

2004 (fi sh passage effi ciency (FPE) is defi ned as passage through a hydroelectric project by non-power house 

routes) — achieve 80 percent fi sh passage effi ciency at each Snake River project from April 15 to September 30 

and at each Columbia River project from May 1 to September 30, while keeping dissolved gas levels within the 

limits of federal and state water quality standards and ensuring a high degree of adult passage success;
86 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• in coordination with the tribes and state and federal fi shery agencies, investigate comparative and relative direct 

and delayed mortality of fi sh through screens, turbines and spill at each dam; report to the Council;

• until investigations are completed, spread the risk to juvenile migrants by removing half of the turbine intake 

screens from all Corps mainstem projects, and provide the necessary spill to achieve a 90-percent FPE.

Transportation

• Transportation should not be used as a device to delay substantial improvements in inriver survival conditions.

• Adopt an interim strategy that substantially reduces and leads to the elimination of the number of fi sh transported.

• In-season transportation decisions should be made by the fi sh managers; in the case of stocks listed under the 

ESA, these decisions will be made by NOAA Fisheries in consultation with other fi sh managers.

Spill

• For mainstem projects operated by the Corps of Engineers on the Columbia and Snake rivers, provide spill 

to achieve 80-90 percent fi sh passage effi ciency at each Snake River project from approximately April 10 to 

September 30, and at each Columbia River project from approximately April 10 to September 30, or as near as 

possible within the total dissolved gas guidelines established by federal and state water quality agencies:

- spill to the total dissolved gas waiver level at each mainstem dam for 24 hours a day;

- limited spill (about 3-5 kcfs per dam) for adult downstream passage should continue until adult salmon and 

steelhead cease to pass the dams;

- spill levels can be modifi ed based upon real-time monitoring of physical and biological parameters at the 

discretion of the tribes and fi sh and wildlife management agencies.

• Until investigations are completed, spread the risk to juvenile migrants by removing half of the turbine intake 

screens from all Corps mainstem projects, and provide the necessary spill to achieve a 90-percent FPE; 

implement water temperature and total dissolved gas reduction and abatement suffi cient to comply with the 

federal Clean Water Act.

• Continue to evaluate and modify mainstem projects to reduce dissolved gas levels during spill operations and to 

increase spill effi ciency (with specifi c details).

Bypass systems

• Ensure a 98-percent or greater salmon survival rate in all bypass and collection facilities from the defl ector 

screens or surface bypass system entrances to the end of the bypass system outfall.

• Increase survival of smolts in the area below the bypass release points by removing fi sh predators, protecting 

migrants from predation by birds, providing alternative release sites, and/or modifying project operations to 

reduce predation.

• Explore promising new approaches to fi sh bypass technologies, including development and prototype testing of 

surface bypass systems, surface spill and behavioral guidance devices, such as the use of curtains to divert fi sh 

from turbines; provide annual reports to the Council by October of each year.

• At Bonneville Dam:

- expedite evaluation of fi sh passage effi ciency at the First Powerhouse and report to the Council 

modifi cations that may be needed to meet standards above;
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 87

- by April 2003, install modifi cations to allow operation of the Bonneville Second Powerhouse surface 

bypass sluiceway;

- by October 2004, complete design and environmental components to install a surface bypass system at the 

First Powerhouse.

• At Ice Harbor and The Dalles dams:

- develop and implement a coordinated permanent juvenile passage plan, in consultation with the fi sh and 

wildlife agencies and tribes, consisting of a schedule for design and installation of surface bypass systems at 

Ice Harbor and The Dalles dams.

• At The Dalles and Lower Granite dams:

- complete prototype testing of a surface fl ow juvenile bypass system.

• At McNary Dam:

- continue studies to evaluate fi sh spill effi ciency and modifi cation to meet temperature standards in fi sh 

passage facilities; complete by 2003.

Turbine operations and improvements

• Operate turbines within 1 percent of peak effi ciency from April 10 through September 30, and especially during 

peak migration periods; plan and coordinate deviations from the 1-percent peak effi ciency criterion with the 

fi shery agencies and tribes.

• Complete the turbine index testing program for each individual turbine unit at all mainstem dams; record 

deviations from the 1 percent criterion and provide the report to the agencies, tribes and the Council.

• Reduce water level fl uctuations from power peaking operations.

• Pursue new and/or improved turbine technology and effi ciency.

• Expedite rehabilitation of old generating units.

Adult passage

• As determined by the fi sh passage committee, the Corps should continue to upgrade existing adult fi sh passage 

facilities (with a number of details).

• Conduct adult telemetry evaluations, capable of tracking individual fi sh to spawning areas for comparison of 

spawner success and distribution with the populations at large.

• Conduct temperature and hydraulic studies at each dam fi shway.

• Note problem areas identifi ed by telemetry, temperature and hydraulic studies and implement structural 

remedies at all dams by 2005.

• Additional adult fi sh ladders: new designs and structural improvements to existing ladders and improved 

maintenance of existing ladders.

• Restrict new dredging and improve existing dredging management practices.

• Implement 24-hour video or automatic fi sh counting.

• Evaluate the effects of increased spill on adult passage.

• Evaluate the extent and identify the causes of interdam adult salmon losses, including non-dam losses, and take 

action to address these causes, as necessary.
88 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Control of predators and invasive fi sh (reducing competition)

• Reduce pikeminnow population by more than 20 percent in the Snake and Columbia rivers with the expectation 

that this will result in more than a 50 percent reduction in the present consumption of juvenile salmonids (with 

details on management, evaluation, and research).

• Develop programs to eliminate shad from the Columbia System above Bonneville Dam, including evaluation 

of alternative upstream passage designs for preventing the upstream passage of shad while allowing salmon and 

steelhead to pass (with a number of other action and research details).

• Reduce numbers of non-native fi sh wherever they exist with listed species or weak runs, using any measures 

practicable, and curtail recruitment of non-native fi sh into the habitats of listed species and weak runs (with 

details for action, evaluation and research).

• Monitor and assess predation by birds and identify non-lethal methods of control; continue with moving tern 

colonies out of the Columbia River estuary.

• Develop a protocol for marine mammal predation control for immediate implementation in the event that 

evidence indicates control is needed to support listed species’ recovery (with details for action and research).

Dam breaching

• Modify Snake River dams to natural river conditions to restore approximately 9,000 acres of spawning habitat 

for Snake River fall chinook and improve migration survival for juvenile and adult salmon and steelhead and 

lower water temperatures:

- restore natural river levels, conditions and habitat by removing earthen embankments at Ice Harbor, Lower 

Monumental, Little Goose and Lower Granite dams by 2006;

- beginning immediately, and concluding not later than December 31, 2004, complete all design, engineering 

and environmental review of facility and operating changes necessary to operate Lower Granite, Little 

Goose, Lower Monumental, and Ice Harbor at natural river level year-round; include all requirements and 

impacts relating to power production, fl ood control, navigation, irrigation and other river uses (with details 

on planning and coordination);

- mitigate for the economic and other short-term impacts that will occur;

- draw down Lower Granite reservoir to 710 feet (spillway crest) until embankment removal is accomplished.

• Draw down the reservoir behind John Day Dam to Minimum Operating Pool (MOP) immediately, and to 

spillway crest or natural river level by 2008, on a year-round basis to restore approximately 40 miles of 

spawning habitat for Columbia River fall chinook and also improve migration survival for juvenile and 

adult salmon and steelhead and reduce water temperatures. Apply for Congressional funding for 

implementation of Phase II of the John Day drawdown analysis. If funds are secured, implement the analysis 

following the recommendations and input from the state and federal fi shery agencies and affected tribes by 

December, 2004.

Mid-Columbia passage — spill and passage

• At Rock Island Dam:

- provide spill to protect 95 percent of the juvenile migrations at a 90-percent FPE level;

- seek and implement recommendations of the Mid-Columbia Coordinating Committee, including adult 

passage investigations and passage modifi cations and structural changes, to bring the project into 

compliance with water quality standards.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 89

• At Rocky Reach Dam:

- provide interim spill to protect 95 percent of the juvenile migrations at a 90-percent FPE level;

- make structural repairs to the spillway so the spillbays closest to the powerhouse can operate independently;

- complete design and prototype to install a sluiceway through Unit 1 by 2004;

- implement recommended studies by the tribes and fi shery agencies necessary for the relicensing proceeding, 

and incorporate them into the draft relicensing application;

- seek and implement recommendations of the Mid-Columbia Coordinating Committee, including adult passage 

investigations and structural changes to bring the project into compliance with water quality standards.

• At Wanapum and Priest Rapids dams:

- following the 2000 Spill Settlement Memorandum of Agreement, provide an increased level of spill 

at both Wanapum and Priest Rapids dams to improve fi sh passage and survival for 95 percent of both 

the spring and summer salmon migrants, at a 90-percent FPE level while avoiding dissolved gas 

supersaturation problems; Mid-Columbia Coordinating Committee will have the responsibility to govern 

the timing and distribution of spill;

- explore promising new approaches to juvenile fi sh bypass technology, including the use of surface bypass 

systems, by 2003;

- seek and implement recommendations of the Mid-Columbia Coordinating Committee, including adult 

passage investigations and structural changes, to bring the projects into compliance with water quality 

standards;

- based on results of adult fi sh passage research and in consultation with the Mid-Columbia Coordinating 

Committee, identify and correct all adult fi shway defi ciencies by 2003 at both dams;

- install state-of-the-art fi sh counting facilities at both dams by April 2002;

- in consultation with the Mid-Columbia Coordinating Committee, design prototype structural improvements 

to the Priest Rapids junction pool by April 2003.

• at Wells Dam:

- subject to Federal Energy Regulatory Commission approval, ensure that the installed juvenile fi sh bypass 

system tailored to the unique features of Wells Dam continues to operate effectively and in accordance with 

the terms and conditions of the 1990 Wells Settlement Agreement;

- continue to provide mitigation for unavoidable losses, including sockeye, using the recommendations of the 

agencies and tribes in the Wells Coordinating Committee;

- monitor and evaluate water quality parameters and implement operational and structural remedies.

• Working with the Mid-Columbia Coordinating Committee and the Independent Scientifi c Group’s technical 

group, Bonneville should determine the steps necessary to install PIT-tag detectors on projects in the midColumbia.

The Council’s response to the Commission’s passage recommendations is similar to its response to the water 

management recommendations. The Council adopted a set of basic principles, objectives and measures for passage 

consistent with the Commission’s recommendations, including the two core biological principles to guide decisions about passage (protecting biodiversity and favoring passage solutions that best fi t natural behavior patterns 

and river processes), which originated in a 1999 Council review and report on the Corps of Engineers’ juvenile fi sh 
90 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

mitigation program and which NOAA Fisheries later incorporated into its 2000 Biological Opinion. The Council 

also adopted strategies calling for:

• spill and transportation decisions to take into account as a priority the important non-listed populations of 

salmon and steelhead in the middle part of the river that cannot be transported;

• transportation to remain a spread-the-risk strategy at the call of the fi sh and wildlife managers;

• improvements in turbine operations;

• adult fi sh passage improvements of the types called for in the Commission’s recommendations;

• continued recognition of spill as an effective inriver passage route; and more.

Incorporating the hydrosystem measures of the two biological opinions into the Council’s program included an 

extensive set of passage modifi cations, gas abatement improvements, predator control measures, and so forth, consistent with much of the detail in the Commission’s recommendations.

On the other hand, where the Commission recommended specifi c spill, transport and passage objectives and measures that are different from the spill, transport and passage measures in the biological opinions incorporated into the 

program, including dam removal, the Council did not adopt those recommendations for all the reasons given in General Finding No. 2 and reiterated above. The dam modifi cations and the tests and evaluations called for in the biological opinions will be an appropriate forum for further evolution of optimal passage methods and operations.

Institutional arrangements; annual and in-season decisionmaking; research, monitoring 

and evaluation

The Commission’s recommendations included a host of provisions concerning the procedures and institutional 

arrangements for making decisions on mainstem actions, for monitoring and evaluating mainstem actions and for 

mainstem research. Most of these recommendations came in the form simply of continued provisions from the 

Council’s 1994 program. The research, monitoring and evaluation provisions relate largely to the habitat, water 

management and passage objectives and measures discussed above (some of which are explicitly noted) and also 

addressed in the responses above. Many if not most have been integrated into the biological opinion measures, 

and/or are a large part of the ongoing mainstem programs and projects funded and implemented by the federal 

agencies in consultation and with assistance from the states and tribes. Institutional arrangements include matters 

such as the organization, oversight and use of the Independent Scientifi c Advisory Board, addressed in the 2000 

Program in a manner consistent with the recommendations here.

Regarding annual and in-season decisionmaking, the Commission recommended that the Council reconstitute 

the Fish Operations Executive Committee, a group to be appointed by the Council and affected tribes and made 

up of senior management representatives of the Council, as well as power and fi shery interests. The FOEC would 

then oversee an annual policy and technical process to make the needed annual and in-season plans and decisions 

on matters such as reservoir operations, fl ow and temperature regimes, spill, transportation, system confi guration 

investments, water quality investments and the reconciliation of mainstem measures designed to benefi t various 

populations throughout the system. The recommendations then included detail on how this process would work. 

According to the Commission, re-establishing FOEC in this way is necessary because of problems with the current 

forums created by NOAA Fisheries, including an inability to foster regional participation, a lack of proper policylevel input and authority focused only on listed stocks.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 91

The Council did not re-establish FOEC, but it adopted a provision otherwise consistent with this recommendation. 

Recognizing the problems with the current mainstem implementation forum, the Council recommended that the forum 

be jointly sponsored by the Council and the federal agencies to allow for consideration of broader fi sh and wildlife 

and power system concerns and for effective participation in these considerations by the relevant federal agencies, the 

Council and states, the tribes of the Columbia River Basin and other affected entities in a highly public forum.

Finally, the Commission recommended the continuation of the Fish Passage Center with the functions and 

arrangements described in the 1994-95 program amendments, plus additional funds to establish two fi sh passage 

manager positions, one designated by the federal and state fi sh and wildlife agencies and one designated by the 

Columbia River Basin Indian tribes. The Council continued the operation and basic functions of the Fish Passage 

Center as subordinate to the Executive Director of the Columbia Basin Fish and Wildlife Authority and the fi sh 

managers. Responding in part to concerns outside the fi sh managers about the transparency and accountability 

of the Center (including recommendations in the 2000 amendment process and the current one, as well, to substantially change the nature of the Center), the Council in the 2000 Program amendments established an oversight 

board for the Center with representation from the Council, NOAA Fisheries, state fi sh and wildlife agencies, tribes 

and others. The purpose of the oversight board is to provide policy guidance for the Center and to ensure that the 

Center carries out its functions in a way that assures regional accountability and compatibility with the regional 

data management system. The Council clarifi ed the responsibilities of the oversight board in these amendments. 

The Council did not call for the funding of a second fi sh passage manager; in a time of tight budgets and the need 

to avoid further fragmentation of our institutional arrangements, the Council concluded that the proposal for 

another manager was not persuasive.

Power system changes

The Commission attached to its recommendations what it called its “Energy Vision for the Columbia River,” a 

“diversifi ed energy portfolio intended to meet the region’s energy needs and restore Columbia River salmon.” The 

vision included a set of strategies to meet peak loads at less cost, to distribute generation to avoid large new transmission investments and to use various trading and fi nancial mechanisms to bring more fi nancial stability. The 

overarching purpose was to ensure that normative fl ows for salmon are implemented even in low runoff and high 

energy-cost cycles. Details include matters such as funding 100 megawatts of distributed generation in the next 

two years; acquiring 1,000 megawatts of peak-load reduction resources in the next 10 years; Bonneville establishing a Conservation Business Line; rates and power pricing that refl ect true fi sh costs and market conditions; fi sh 

operations as hard constraints in annual power system planning, and more.

As discussed above in General Finding No. 5, the Council agreed with the basic premise that there is a need to 

ensure that the hydrosystem can provide the specifi ed operations for fi sh and wildlife while the region’s power supply 

meets the electricity demands of the region. The Council’s power system analysis that accompanies these fi ndings 

concluded that, because of developments since 2001, the region’s power system should be adequate and reliable for 

the next few years and not unduly vulnerable to curtailment of fl ow and spill operations for fi sh in low water conditions or adverse power markets. But, the region faces the possibility of spiraling back into the power supply problems 

seen in 2001 unless measures are taken to ensure that new resources are added to the regional power supply in a more 

certain fashion. The analysis suggests actions that the federal agencies and others in the region could take to ensure 

that the federal system provides the specifi ed operations for fi sh and wildlife and meets the electricity demands in 

most, if not all, low water years. The analysis also notes that the Council is revising its 20-year power plan as called 

for by the Northwest Power Act, and that the power plan will address the region’s power supply and reliability issues 

in more detail. Further consideration of the power supply recommendation here will be deferred to the power plan 

revision; all of the specifi c strategies recommended by the Commission will be under active consideration.
92 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Recommendation No. 13: Spokane Tribe

The Spokane Tribe recommended a set of objectives and strategies largely focused on providing the appropriate 

habitat conditions for fi sh in Lake Roosevelt. These objectives and strategies would establish a balance between 

operations, actions and funding for salmon and steelhead to protect and improve resident fi sh as mitigation by substitution for the loss of anadromous fi sh in blocked areas. The recommendations include:

• Systemwide water management, including fl ow augmentation from storage reservoirs, must balance needs of 

anadromous species with those of resident fi sh species in upstream reservoirs so that actions to advantage one 

species do not unnecessarily come at the expense of other species.

• To protect spawning and rearing habitat for fi sh and wildlife in and adjacent to Lake Roosevelt, maintain the 

minimum elevation and water retention time operating conditions from Section 10.8B of the 1994-95 Program, 

until data from a fi sheries evaluation program indicate the criteria should be changed:

Month Minimum Elevations Water Retention Times:

January 1270’ 45 days

February: 1260’ 40 days

Mar-Apr15: 1250’ 30 days

Apr16: 1255’ 30 days

May: 1265’ 35 days

June-Dec: 1288’ 40-60 days, or maximum

 historically achievable/month

• Continue the Lake Roosevelt monitoring and evaluation program. As more is learned about impacts of 

reservoir operations, Grand Coulee operations should be adjusted in response to minimize impacts on the tribe’s 

resources. Also, the wealth of information being collected should serve as the basis for Integrated Rule Curves 

for Grand Coulee operations. Adaptive management is needed to update Grand Coulee operations criteria in 

response to information from the Lake Roosevelt Fisheries Evaluation Program, to a systemwide fl ood control 

alternatives study, and to cultural resource surveys.

• Consistent with the 2000 biological opinions, the Corps of Engineers should fund appropriate studies of the 

potential for reconfi guration of the federal hydrosystem facilities and/or operating strategies to manage better 

for fl ood control with reduced impacts on fi sh and wildlife. Adjust operations as knowledge is gained through 

these studies.

• If necessary, mitigate for operations to implement the biological opinions that adversely affect fi sh and wildlife 

in the Blocked Area.

• Initiate as soon as possible the “long-term planning study to include consideration of reconfi guration and 

operational alternatives that could provide benefi ts for fi sh and wildlife on a broad scale” described in the 

hydrosystem strategy titled “Longer-term Planning Perspectives” in the 2000 Fish and Wildlife Program.

• Habitat restoration: Rebuild populations by protecting and restoring habitats. Provide habitat suitable to recover 

Columbia River white sturgeon. Manage riparian areas to protect the aquatic system and form transition zones 

to fl oodplain terrestrial areas. Protect low-elevation winter range habitat for wildlife. Encourage development 

of ecological connectivity between major habitat types. Require and fund creation of littoral habitat and fi sh 

structure along shores of Lake Roosevelt to diversify food available to fi sh and provide additional juvenile 

fi sh rearing habitat. Immediately and fully fund the remainder of unmitigated wildlife habitat losses, enabling 

managers to acquire promptly the management authority necessary to restore and protect core habitat areas.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 93

• Until drastic habitat alterations in the connected mainstem habitats of the Columbia and Spokane Rivers are 

addressed, support native fi sh recovery efforts focused on tributary habitats to maintain genetic integrity of 

native assemblages. Recognize that drastically altered habitats currently available largely favor non-native 

species and stocks, which have been substituted successfully for recreational fi sheries but have not addressed 

tribal subsistence losses.

• Use Spokane Tribal Water Quality Standards as targets for Lake Roosevelt water quality.

• Restore passage of anadromous fi sh into the blocked area ecosystem. Reestablishing anadromous passage 

at artifi cial barriers should include passage into the vast habitat upstream of Grand Coulee Dam. Approve 

funding for the sequence described in the Upper Columbia United Tribes’ recommendations for the 2000 

Program Framework — that is, feasibility and engineering studies and eventual facility investments to restore 

anadromous fi sh passage above Chief Joseph and Grand Coulee dams.

• Recognize tribal water rights.

• Remain focused on a participatory process to coordinate decisionmaking, rather than locking into a fi xed 

operational strategy for the hydrosystem. The current system operations decision processes are inadequate. 

The Council should enhance the regional process to be broader than ESA, and involve state and tribal fi sh and 

wildlife managers in focused discussions with NOAA Fisheries and the Fish and Wildlife Service to reconcile 

specifi c measures, with the goal of having the two agencies declare that federal operating agencies can avoid 

jeopardy by complying with the Council’s Fish and Wildlife Program. Revive and support the Columbia Basin 

Forum (previously known as the Three Sovereigns) as the template for a workable solution.

• Adopt a defi nite fi sh and wildlife budget that provides adequate funds, ensures equitable distribution of funds 

and provides participation as well as project funds. The fi sh and wildlife managers should be given the 

opportunity to participate, beginning in the early stages of the development of this budget.

The Council adopted a number of mainstem amendments consistent with the Spokane Tribe’s recommendations, 

including:

• the basic principle that systemwide water management must balance the needs of anadromous and resident fi sh 

affected by the hydrosystem;

• a set of consistent mainstem habitat objectives and strategies in general and for the Lake Roosevelt area in 

particular;

• an emphasis on having the federal agencies conduct the systemwide fl ood control review called for in the 

biological opinion;

• a call to pursue restoration of anadromous fi sh in mainstem areas blocked by dams where feasible;

• a recommendation to sponsor jointly the regional hydrosystem decisionmaking forum to broaden participation 

and incorporate factors such as those expressed in the tribe’s recommendations;

• an objective of meeting water quality standards under the Clean Water Act;

• an objective and strategy to stabilize and improve white sturgeon populations; and

• a wildlife habitat objective consistent with the wildlife mitigation objectives and strategies in the 2000 Program.

Also, a number of these recommendations were already addressed in the basinwide provisions of the 2000 Program amendments, including:

• he continuation of the resident fi sh substitution policy in the areas blocked to salmon and steelhead;
94 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

• the strong preference for the use of native species, with the recognition that proposals to use non-native species 

to match signifi cantly altered habitats may overcome that strong presumption;

• recognition and protection of water rights, including tribal water rights (also part of the Power Act itself); and

• the principles of program implementation, project funding and project review and funding.

The specifi c details of implementation projects and funding allocations are more appropriately addressed in the 

project review and funding processes.

The Council adopted operating criteria for Lake Roosevelt to protect resident fi sh consistent with and based on 

the underlying principles of the tribe’s recommended criteria, although not precisely the same. But, the Council 

did so in the context of also incorporating the measures of the biological opinion operations into the program as 

the baseline of operations. So, the Council called for spring and summer operations at Grand Coulee Dam consistent with biological opinion operations and with ordinary hydrosystem power operations, but then also called on 

the federal agencies, working with the tribes, the Council and others, to attempt where possible to meet the reservoir elevations and water retention times preferred by the Lake Roosevelt area tribes. Thus the Council adopted a 

revised form of this recommendation, as explained in General Finding No. 3; see also General Finding No. 2.

Recommendation No. 10: Colville Confederated Tribes

The Colville Tribes submitted recommendations that cover much of the same subject matter as the Spokane 

Tribe, including:

• recognition of the importance of the resident fi sh substitution policy to mitigate for the blockage of salmon and 

the need for system operations that provide the appropriate habitat conditions for these fi sh in Lake Roosevelt;

• the need to include measures to protect, mitigate and enhance all resident fi sh in hydropower system storage 

projects to the fullest extent practicable from negative impacts associated with basinwide water management;

• an overall goal and set of strategies to support tribal and non-tribal harvest and cultural and economic practices 

as well as the long-term sustainability of native fi sh and wildlife species in native habitats where possible, while 

recognizing that where impacts have irrevocably changed the ecosystem, there is a need to protect and enhance 

the habitat and species assemblages that remain;

• the need for a comprehensive review of the current fl ood control program to determine if fl ood control rule 

curves could be relaxed in order to provide additional water;

• investigation of the feasibility of reintroducing anadromous fi sh above Chief Joseph and Grand Coulee dams;

• investigation of measures to improve mainstem spawning and rearing habitat conditions throughout the 

Columbia River, including in the tailrace of Chief Joseph Dam;

• development of a plan to improve water quality in the Upper Columbia River mainstem, in that both 

temperature and total dissolved gas concentrations exceed acceptable water quality standards; and

• an initiative to stabilize populations of white sturgeon in the mainstem Columbia River above Grand Coulee 

Dam and prevent further declines and possible extinction.

The Council adopted a set of amendments consistent with, although less detailed than, these recommendations, 

as partly explained above in the response to the Spokane Tribe’s recommendations. The Colville Tribes included a 

recommendation calling for the continued development and implementation of a fi sh entrainment deterrent system 

at Grand Coulee Dam. The Council did not include a provision quite that detailed, but agrees that this is one of 
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 95

the implementation actions necessary to investigate consistent with the stated objective of providing the conditions 

needed to protect and build the fi sh populations in the lake to levels capable of supporting harvest consistent with the 

goals of the Colville and Spokane Tribes.
96 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Environmental, Fishing and Conservation Groups

Recommendation No. 3: Save Our Wild Salmon

Recommendation No. 21: Northwest Resource Information Center, Inc.

The Save Our Wild Salmon coalition and the Northwest Resource Information Center, Inc., recommended that the 

Council call for a series of fl ow, spill and dam modifi cation measures for salmon more extensive than called for in the 

biological opinions. The recommendations included adopting the fl ow and spill recommendations of Oregon and the 

Idaho fi sh and wildlife departments, such as additional water volumes to meet modifi ed fl ow targets and 24-hour spill 

at all projects. The Northwest Resource Information Center, Inc. also recommended that the Council call now for the 

breaching of the four lower Snake dams; Save Our Wild Salmon recommend that the Council plan for breaching the 

lower Snake River dams if non-breach options fail to meet ESA requirements, by calling for the necessary planning 

and evaluations to ensure that alternative actions including breaching of the dams can be implemented on a timely 

basis if non-breach alternatives fail to meet rebuilding objectives. To the extent these groups recommended that the 

Council include fl ow, spill and dam breaching recommendations to benefi t listed salmon beyond what is called for in 

the biological opinions — which is the essence of these recommendations — the Council did not adopt these recommendations for the reasons explained in General Finding No. 2.

Recommendation No. 11: Northwest Energy Coalition

Recommendation No. 3: Save Our Wild Salmon

The Northwest Energy Coalition and Save Our Wild Salmon recommended a series of strategies for power system 

operation, energy resource acquisition and Bonneville fi nancial management to ensure the region has adequate and 

reliable generating capacity and reserves to meet regional load requirements even in low water conditions. This 

would ensure that there are no power system reasons for the operating agencies to fail to provide the specifi ed fl ow 

and spill operations for fi sh even in low water conditions. As explained in General Finding No. 5, the Council 

agreed with the objective of these recommendations concerning the need to ensure that the hydrosystem provides the 

specifi ed operations for fi sh and wildlife while the region’s power supply meets the electricity demands of the region 

in most if not all years. The Council’s power system analysis that accompanies these fi ndings concluded that, because 

of developments since 2001, the region’s power system should be adequate and reliable for the next few years and not 

unduly vulnerable to curtailment of fl ow and spill operations for fi sh in low water conditions. But, the region faces 

the possibility of spiraling back into the power supply problems seen in 2001 unless measures are taken to ensure that 

new resources are added to the regional power supply in a more certain fashion. The analysis suggests actions that the 

federal agencies and others in the region could take to ensure that the federal system provides the specifi ed operations 

for fi sh and wildlife and meets the electricity demands in most, if not all, low water years. The analysis also notes that 

the Council is revising its 20-year power plan as called for by the Northwest Power Act and that the power plan will 

address the region’s power supply and reliability issues in more detail. Further consideration of the power supply recommendations herxe will be deferred to the power plan revision.
2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 97

Utility, Irrigation and Industry Groups

Recommendation No. 17: Columbia-Snake River Irrigators Association, Eastern Oregon 

Irrigators Association, Northwest Irrigation Utilities

Recommendation No. 19: Idaho Water Users

The irrigation and water user associations recommended various ways in which the Council should call for a shift 

in current water management operations and fl ow augmentation away from what is in the biological opinions and past 

Council programs. The recommendations included elimination of fl ow targets, specifi ed volumes of storage allocated 

to spring and summer fl ows, elimination of upper Snake fl ow augmentation, and development of additional off-stream 

and tributary storage (using hydropower revenues gained by reducing mainstem fl ows to develop tributary water projects). The recommendations also included focusing juvenile passage on those actions that are the most biologically 

effective and cost-effective, not on strategies that provide conditions that most closely approximate natural conditions, with an emphasis on a full smolt transportation regime, particularly during low fl ow years, as well as priority for 

research on improvements in transportation effectiveness.

The Council called for additional priority studies on transportation, but otherwise did not adopt these recommendations for the reasons explained in General Finding No. 4.

Recommendation No. 2: Public Power Council

Recommendation No. 15: Pacifi c Northwest Generating Cooperative

Recommendation No. 18: Nespelem Valley Electric Cooperative

These entities did not recommend that the Council adopt specifi c fl ow and spill operations contrary to the biological opinions; in fact, the Public Power Council recommended that the Council tailor its mainstem amendments so 

that they effectively contribute to federal implementation of the 2000 biological opinions while assuring the region of 

an adequate, economic, effi cient and reliable power supply. But these entities were concerned about the costs to the 

power system and the region of mainstem system operations for fi sh, and about the scientifi c uncertainty underlying 

many of these measures. Thus they recommended that the Council place a high priority on:

• a comprehensive review of the fl ow and spill measures;

• monitoring and evaluation aimed at determining what tangible biological benefi ts are really being attained from 

fl ows and spill; and

• determining the real impacts of fl ows and spill on the adequacy, reliability and economy of the power supply, 

with the goal of determining the most cost-effective levels of spill and fl ow. This information would assist in 

sound policy development.

The entities also recommended that the Council resist calls for additional fl ow and spill measures until it is demonstrated that these will improve survival and why, at what costs, and that less costly alternatives for achieving the same 

objectives are not available.

To the extent that these recommendations would have had the Council not incorporate the biological opinion measures into the program prior to a new comprehensive review of their scientifi c and economic soundness, the Council did 

not take that approach, for the reasons described in General Findings Nos. 2, 4 and 5. And to the extent that the Pacifi c 

Northwest Generating Cooperative recommended that the Council subject proposed measures to a cost-benefi t analysis, 

the Power Act does not authorize the Council to use that particular type of analysis to decide on or reject program measures. Northwest Resource Information Center, Inc. v. Northwest Power Planning Council, 35 F3d 1371, 1393-95 (9th

Cir. 1994). Otherwise, the Council adopted review, evaluation and adaptive management measures consistent with the 

substance of these recommendations, as described in the same general fi ndings.
98 2003 Mainstem Amendments to the Columbia River Basin Fish and Wildlife Program 

Others

Recommendation No. 16: Voith Siemens Hydropower Generation, Inc.

Voith Siemens recommended that the Council pursue advances in the mechanical and operational characteristics 

of generating turbines to increase fi sh survival through the turbines, and thus reduce the need for spill, and increase 

fl ow rates through the turbines, both of which would increase generation. The Council called for continued study 

and modifi cations of turbines and turbine operations to improve fi sh survival.

Recommendation No. 20: Allan Vernon: Minor

Mr. Vernon: Minor recommended a “water wall fi sh fence” along both sides of the Columbia to increase salmon 

spawning. The Council did not adopt this specifi c recommendation. The Council did adopt a set of objectives and 

general strategies to increase the extent, diversity, complexity and productivity of mainstem habitat for spawning 

and rearing, leaving for implementation processes to analyze specifi c proposals. The Council concludes this was 

a more effective path to protecting, mitigating and enhancing salmon and steelhead in the mainstem than adopting 

the specifi c recommendation from Mr. Vernon: Minor, see Power Act, § 4(h)(7)(C).