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the Pacific Northwest Coordination Agreement plan annual hydropower 

 operations behind doors closed not only to the public, but to federal and 

 state fish and wildlife agencies, and the Native American TWbes. While 

 excluded from these key proceedings, the public is invited to participate in 

 a bewildering array of segmented, separate, overlapping, and relatively 

 meaningless processes. 



b) Changing the membership, structure, or authorities of the Council; 



The Council has suffered from divisions among its members, and has 

 routinely failed to meet its mandates under the Northwest Power Planning 

 Act. However, neither the Congress nor changes in the Council's 

 membership or structure can guarantee the qualifications of, or the 

 performance by, the four governors' appointments. If the BPA and the Corps 

 continue to refuse to implement the Council's fish and wildlife program "to 

 the maximum extent practicable," if the agencies continue to view the 

 Council's regional power plan and the Columbia Basin fish and wildlife 

 program as advisory and /or discretionary, the Congress must give new 

 authorities to the Council. 



c) Incorporating salmon recovery measures into the Pacific Northwest 

 Coordinating Agreement; 



The PNCA signatories claim that they already incorporate salmon recovery 

 measures as "hard constraints." In addition, hydropower operations change 

 from water year to water year. Therefore, the PNCA should expand to 

 include as full-fledged signatories all federal fish and wildlife agencies, all 

 state fish and wildSfe agencies, and all sovereign Native American Tribes in 

 the Columbia Basin. 



d) Adopting a new agreement or creating a new regional entity among BPA, 

 the Corps of Engineers, the Bureau of Reclamation, the Council and others 

 to administer annual river operations; 



The Council established a Fish Operations Executive Committee for this 

 purpose, which unfortunately put the fox in charge of guarding the chicken 

 coop. Any such entity must include all federal fish and wildlife agencies, all 

 state fish and wildlife agencies, and all sovereign Native American Tribes in 

 the Columbia Basin. If such an entity has firticipation by the utility industry, 

 it must also seat public-interest representatives. 



e) Transferring a lump sum in fish and wildltfe funds from BPA to fish and 

 wildlife agencies to be administered separately by those agencies for sabnon 

 recovery, while providing accountability for the results of the work funded; 



Because it would eliminate BPA discretion and decision-making in fish and 

 wildlife mitigation programs, this proposal has considerable merit. With 



Sierra Club — Page 13 



