660 



5) Are existing institutions and institutional arrangements at the state and federal level 

 adequate to implement salmon recovery plans? What improvements should be made to 

 ensure better regional coordiruuion among many federal, state, tribal, and private entities 

 that must work together to achieve salmon restoration ? In particular, the following 

 alternatives have been suggested for better implementing salmon restoration plans. 

 Please comment on each: 



a) Providing additional public involvement in existing federal processes, including 

 review of annual operations; 



The Pacific Northwest Coordination Agreement (PNCA), a private contract among three 

 federal agencies and a variety of Northwest public and private utilities, is the dominant 

 mechanism for coordinating operations of Columbia and Snake River storage projects both in 

 the United States and Canada. Since its inception in 1964, the PNCA has not provided for 

 public involvement. Rather, the each signatory assumed the responsibility for representing non- 

 power constraints at its individual projects (e.g. salmon needs) to the others during the process. 

 However, as Congress recognized in the Northwest Power Act, the needs of salmon depend 

 upon coordinated operations of the entire system. The PNCA did not anticipate such "system 

 requirements," and is inadequately structured to fully integrate salmon needs with system 

 operations. 



The tribes, none of which are signatories to the PNCA, are best able to represent their 

 interests in the Columbia Basin's salmon resources. Relying on the Bureau of Reclamation, 

 BPA or the Corps of Engineers to represent the tribes' viewpoints is unsatisfactory. At a 

 minimum, the PNCA must be restructured so that the tribes have a direct voice in planning 

 operation of the Columbia Basin hydrosystem. 



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



As you know, the Act does not provide for any direct representation of the tribes on the 

 Council. Furthermore, none of the states has appointed a tribal rqjresentative to the Council 

 since its inception. While the tribes have repeatedly called for the establishment of a 

 govemment-to-govemment relationship with the Council, the establishment of such'a dialogue 

 has been very elusive. The Council continues to primarily function as a forum for interaction 

 among the four Northwest governor's offices. 



c) Incorporating salmon recovery measures into the Pacific Northwest Coordination 

 Agreement; 



As noted above, the PNCA should be restructured to allow direct tribal representation. 

 Simply asking the existing parties to the PNCA to incorporate salmon recovery measures in their 

 planning does not ensure that the planning will acceptably reduce the risk of non-compliance 



