385 



Mr. Crow 

 August 13. 1993 

 Page 3 



-te The proposed implftrwTitarion projects have not been screened, prioritized, or subjected to 

 ■ rigoroos public scrutiny. The Coundl should build a program and then look for the most 

 appropriate projects, NOT adopt a large immber of projects and then try to build a 

 program arotrnd then. BPA and the Qjuncil have developed a dear separation of lesponsibilicy 

 — (be Council iddrtssw policy- BPA's IPP deals with specific mitigation projects. The current 

 draft tnt-ntimmt documcnt includes a large number of resident fish implementation projects 

 which should be handled dirough the IPP. not in Phase IV. 



•k There arc no resident Bsh or wildlife t tueig t ud es wUdi require Cooncfl action. The Fish 

 and Wndlife Service, under the auspices of the Endangered Species Act, now has responsibility 

 for bull trout ai>d sturgeon. Further, there are projects already in the pqieline which benefit 

 lesidem fish and wildlife in all four states. > 



ir The draft amendment doamient lacks accountability and fiscal responsibility. The measures 

 which direa BPA to enter into wildlife mitigation trust agreemetits where the implementor bears 

 00 financial responsibility demonstrate a total lack of accountability and business sense. You 

 have guaranteed thai the Fbh and Wildlife Program will become an entitlement program. Utxler 

 the proposed measure, the implementors can (and will) 'just take the money and run. * At the 

 enc; of the agreement period, the ratepayers will have nothing to show for their investmem and 

 the resource will be no better off. If you are truly interested in protecting, mitigating, and 

 enhancing fish and wQdlife in the Columbia Basin, you will retpiire stria biological and fiscal 

 accountability. 



Another measure suggesting a funding level (15 percent of the budget) for resident fish and 

 wildlife mitigation is arbitrary and devoid of science or reason. It also looks very much like an 

 entitlement program. Funding for the program should be tied directly to ratepayer responsibility 

 ai>d to the biological need. The region should establish a clear mitigation goal and keep accurate 

 track of the progress toward that goal. BPA should stop ftmding residetu fish aiKl wildlife 

 projects wlien we have reached the goal. 



ir It is fiscally irresponsible to vst changes in reservoir operations as a mitigation tool for 

 resident Bsh. A number of measures limit reservoir fluctuations and therefore limit the 

 reliability and flexibility of the bydrosystem. Section 4<h)(S) of the Aa requires the Council to 

 protect, T^p" and enhance fish and wildlife while 'assuring the Pacific Northwest an adequate, 

 "fTKHi*. ectmotnical. and reliable power supply.* In addition. Section 4<hK6XC) requires the 

 rmtrn to "utilize, where equally effective alternate means of achieving the tame sound 

 bioiogical objectiye exist, tlie alternative with the minrnium ecoooinic cost.* In teal terms, these 

 two •ecdom prohibit using changes m reservoir operations as a mitigation tool. 



The measure calling for Biological Rule Curves (BRCs) is particulariy disturbing. The concept 

 of, and reservoir elevations for, the BRCs have been contitiuously evolving through SOR and 

 dming Phase IV. Final numbers are still not available. If Montana Fish, Wildlife and Parks 

 cannot defiix the rule curves, then they cannot analyze thetn- and neither can the Council. The 

 Council siKMld NOT automatically adopt a nebulous concept just because it was proposed. We 

 nggat that 0» Coondl drfer any dedsion on the BRCs imtil tiie SOR is complete and until 

 the region has thoroughly evaluated 1) the objectives of the BRCs 2) alternative means of 



PNUCC AaiBS 13, 1993 ^ DM112 



