658 



The Strategy for Salmon is not sufficient to remedy these serious institutional problems. 

 The principals from the states, tribes, and federal government must recognize and address these 

 and other related problems to fulfill the promises of the Northwest Power Act. 



One of the most serious weaknesses of the Strategy for Salmon is its failure to establish 

 "biological objectives" for salmon rebuilding. Using the Council's own analogy, the Strategy 

 for Salmon has added rooms to the house without describing a floor plan. The Council's failure 

 to establish biological objectives in the program is contrary to the Act, and among the chief 

 reasons that the Yakima Nation and Sierra Club Legal Defense Fund^ have urged the Ninth 

 Circuit to set aside the Strategy for Salmon. 



One of the stronger aspects of the Strategy for Salmon is the Council's request to land 

 management agencies to fully protect existing salmon habitat conditions from further degradation 

 due to such activities as road building, logging, and grazing. While well-intentioned, the 

 Council's measures do not appear to be a serious factor in regional debates addressing federal 

 land management practices. 



2) Is implementation of the Strategy for Salmon on track for timely completion? How well 

 are federal and state agencies coordinating their activities with each other and with the 

 Council to achieve timely implementation? 



Up until the field hearing, the Council and BPA were at odds with each other over BPA's 

 commitment to fund the measures in the Strategy for Salmon. Virtually on the eve of the 

 hearing, they reached an understanding allowing each to represent to the Committee that BPA 

 was fully funding the Strategy for Salmon. That view, however, is not shared by the region's 

 tribes, and state and federal fish and wildlife agencies, which were not meaningfully included 

 in the Council's policy dialogue with BPA on fish and wildlife funding. Through the Columbia 

 Basin Fish and Wildlife Authority, the fishery managers estimated that approximately $114 

 million would be necessary to fully fund the Strategy for Salmon. 



One of the mechanisms identified by the Council to improve implementation of fish 

 mitigation projects on the ground is often referred to as the "sub-regional implementation 

 process. " Sub-regional implementation was intended by the CBFWA (who recommended it to 

 the Council) and the Council as a primary means for prioritizing and coordinating salmon 

 measures at the local level. Sub-regional implementation follows logically from the sub-basin 



' On behalf of Northwest Resource Information Center (Ed Chaney), Trout Unlimited, 

 Oregon Natural Resources Council, Idaho Salmon and Steelhead Unlimited, and The Wilderness 

 Society. 



