the apphcations-discussed in Part 2 of"lhe"QDCumeni do not meet these standards The Council 

 welcomes comment on the proposed rejections as well 



2. Five-Year Action Plan 



In Section 1504, the Council staff proposes revisions to the five-year action plan The action 

 plan is a scheduling section indicating wtiich of the hundreds of program measures should be 

 implemented, m whole or m part, between 1987 and the end of 1991- It indicates the Councils 

 expectations of the Bonneville Power Administration, Bureau of Reclamation, Corps of Engineers, 

 and Federal Energy Regulatory Commission, the federal agencies given responsibilities by 

 Congress m sections 4(h)(l0) and 4(h)(11) of the Northwest Power Act. to help make the Councils 

 program work Some action items also are included tor the fish and wildlife agencies and Indian 

 tribes and for the Council 



Tne Council asks that commentors focus special attention on the proposed five-year action 

 plan and provide their views on these questions a) Does the proposed action plan reflect 

 reasonaoie expectations of effort by each of the four agencies'^ b) If not, what alternative action 

 packages would be more reasonable for each agency^ 



3. Bonneville Budget 



In Action Item 39,2, the Council asks that Bonneville provide fish and wildlife program work 

 and expenditure plans to the Council by September 15 of each year, for the subsequent fiscal year. 

 However, receipt of plans on September 15 for a fiscal year starting October l leaves no time for 

 the Council and Bonneville to engage in a meaningful public dialogue on a reasonable amount for 

 Bonneville's total annual fish and wildlife budget or on the allocation of the total among various 

 spending categories Nor does it allow for a discussion and determination of reasonable levels of 

 effort and pace of spending over the entire five-year action plan and beyond The Council would 

 appreciate comment on how it can work more closely with Bonneville and others to use the 

 Bonneville budgeting process as a means for publicly setting a fiscal pace for program 

 implementation Suggestions on ways to improve the annual work planning process also are 

 welcome 



4. Funding of Resident Fish Substitutions in Idaho 



In section 206 of the draft, the Council recognizes that some areas in the basm where salmon 

 and steelhead once were produced have been blocked by hydropower projects that make salmon 

 and steelhead production mfeasible. In those "blocked areas." resident fish "substitutions" appear 

 to be the best means for addressing the salmon and steelhead losses. As a result, the Council has 

 proDOsed a resident fish substitutions policy focusing on the major blocked areas above Chief 

 Joseph'Grand Coulee and Hells Canyon dams It al so proposes criteria to ensure that only well- 

 consioered substitutions projects are funded by hydropower ratepayers 



In response to the Councils proposed policy, five groups submitted a total of 1 amendment 

 applications to add resident fish substitution projects to the program. Of those 10 applications, 

 four are for projects above Chief Joseph Dam. to be funded by Bonneville on the ground that 

 federal projects clearly were primarily responsible for the blockage. The Council staff has reviewed 

 those applications, found them to satisfy the substitutions criteria, and proposed them for 

 Bonneville funding, with some modifications, m draft section 804(g)(1), 



-VIII- 



