804(b)(1)(A)/ MDFWP. The application would modity program sectio/i 804(b)(1)(A) to limit 

 drawdown to-frooti controKpurposes.oniy at Hunqry.Horse and Libby feservoirs. and even then 

 only in years of high'runoff (about 20 percent ot all years) Bonneville has expressed concerns 

 about impacts of ihis proposed amenament o.n secondary power generation The Corps is 

 concerned that it could not meet the proposed operating constraints It interprets the existing 

 program language to allow exceeding the"drawdown limit m 20 percent ot all years tor power 

 purposes and exceeding the drawdown limit m the remaining 80 percent of all years for flood 

 control purposes The Corps current operational plan drafts Libby reservoir at least 1 10 feet (the 

 drawdown limit) m two out of three years for flood control purposes in normal to high runoff years. 

 The Corps also believes the proposal is m direct conflict with hydropower system firm power 

 capability guaranteed by the option to draft all authorized usable reservoir storage m normal runoff 

 years The Corps estimates this proposal would make the' lower 62 feet of Libby reservoir 

 drawdown, comprising 1 .200,000 acre-feet of usable storage, unavailable for power purposes. The 

 Council staff proposes rejection of this amendment application because the information m the 

 application is insufficient to support a Council determination that the proposal would protect, 

 mitigate and enhance fish and wildlife while assuring the Pacific Northwest an adequate, efficient, 

 economical and reliable power supply (Seei6USC 839b(h)(5) ) 



804(e) IDFG-1 This application calls for the cons truction of an upstream resident fish ladder on 

 an existing irrigation diversion to open six to seven miles of habitat m Pntchard Creek (South Fork 

 SnaKe River) for migratory cutthroat trout The Council staff proposes to reject this amendment 

 because the project seeks to correct damage to resident fish caused by an irrigation facility As a 

 result, the amendment does not address effects of the development, operation and management of 

 the hydroelectnc system on resident fish, (See 16 U SC 839b(h)(5),) -.,■.•■■-, :■ 



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