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PNUCC 



PACIFIC NORTHWEST UTILITIES CONFERENCE COMMITTEE 



August 13, 1993 



Mr. Stephen L. Crow 

 Northwest Power PUnning Council 

 8S1 SW 6th Avenue, #1100 

 Portland, Oi^on 97204-134« 



Dear Mr. Crow: 



PNUCC appreciates the opportunity to comment on the proposed Phase IV Resident Fish and Wildlife 

 Amendments. Phase IV gives the region a unique oppommity to carefully evaluate the scope and 

 direction of the program as a whole. We are providing comment.^ on the *big picture' as well as on 

 individual measures. 



When we looked at the 'big picture,' we found there were several overriding issues which must be 

 addressed before the program can be truly successfiil. Throughout the last decade, you have consistently 

 promoted the principles of adaptive management. Now it is time to apply these principles to your 

 program. 



In other words, we ask the Council to 'Just Say Wboa!' 



•k Defer final mlemaUng on Phase FV until the region has resolved the fimdamental questions and 

 issues raised by the Scientiiic Review Group in the Critical Uncertainties Paper and has developed 

 biologically sound program goals with measurable objectives. 



•k Proceed with caution. Make essentia] programmatic decisions and then ask the Bonneville 

 Power Administration (BPA) to ftmd only those measures which meet the region's overall goals 

 and priorities aitd which directly address hydropower-related losses. 



•k Require biological and fiscal responsibility and accountability m all aspects of die program. 



•k Ddcte aD of the Resident Fish implementation projects from Phase rv. When you wrote the 

 drift wildlife section, you made a conscious decision to limit Phase IV wildlife amendments to 

 policy issues. We agree with the decision and ask that you demonstrate the same leadership in 

 tite resident fish «TtMKv<nv»rm Please ask BPA to use the Implementation Planning Process (D>P) 

 to carefully evahiate the technical merits and d>e applicability to the overall program goals of all 

 of the existing and new resident fish and wildlife projea proposals. 



We are not asking you to stop the ptogtam or to stop fimding what b already in the program. We are 

 asking you to make some critical programmatic decisions before you add more projects. And, we are 

 asking you to stick with the process developed by BPA and CBFWA - the Ioq)Ien>eiitation Planning 

 Process. 



PNUCC • ONE AVMN flACE. ■ 101 SW MAIN STREET, SUITE 810 • POBTIAND, 0« 97204-3216 • (503) 223-9343 • FAX (503) !94-125( 



