333.95416

N17WMP

1988

Montana SUta

SUE PAPER

3 0864 1003 0608 6

WILDLIFE MITIGATION
PLANNING

88-10

NORTHWEST POWER PLANNING COUNCIL

September 23, 1988

MORRIS L. BRUSETT

CHAIRMAN

Moniaiu

Gcom ■
Vten<

Tunxun

^TtdHaUock
Oregon

Nonm Paului
Oregon

NORTHWEST POWER PLANNING COUNCIL

851 S.W. SIXTH AVENUE • SUITE 1100
PORTLAND, OREGON 97204-1348 • (503) 222-5161

Toll free number for Idaho, Montana & Washington: 1-800-222-3355
ToU free number for Oregon: 1-800-452-2324

TOM TRLXOM

MCE CHAIRMAN

Wuhington

R. Ted BonfCT
Washington

;<ni** A. CoU«
Idaho

Robert (Bob)Suvik

Northwest Power Planning Council
Issue Paper

Wildiif* Mitigation Planning

September 23, 1988

The purpose of this issue paper is to seek public comment on several wildlife mitigation
proposals currently under review by the Council. Those wildlife mitigation proposals are for Grand
Coulee Dam in Washington, the Willamette Basin facilities in Oregon, and Palisades, Anderson
Ranch and Black Canyon dams in Idaho. These proposals raise a number of important issues that
may need to be addressed in considering these and future wildlife mitigation proposals. To begin
the discussion, this paper reviews the background of the wildlife program contained in the
Columbia River Basin Fish and Wildlife Program and proposes several alternatives the Council may
wish to consider in its process to amend the wildlife mitigation proposals into the program.

The Council staff is not recommending a specific alternative on the wildlife mitigation
proposals in this issue paper. Rather, the paper outlines a series of issues and alternatives that
should focus attention on wildlife concerns that arise in connection with the Council's fish and
wildlife program. The Council will undertake discussions and consultations on this paper in an
effort to resolve these issues.

The alternatives the Council may wish to consider for action on the wildlife mitigation
proposals are as follows:

1 . Amend the wildlife mitigation proposals as submitted by the fish and wikjiife agencies and
tribes into the fish arxl wikjIife program.

2. Adjust the wikJIife mitigation proposals so that only a specified portion of the mitigation is
funded by the region's ratepayers. Amend the proposals into the fish and wildlife program
accordingly.

3. Defer action on the pending wildlife mitigation proposals until wildlife policy issues can be
addressed or all wildlife mitigation planning under the program is complete.

4. Define the boundaries of the wildlife program by a specified program level of effort and pace
of implementation for approved mitigation projects over an appropriate time period.

5. Develop guiding policies for wildlife mitigation decisions and amend them into the fish and
wildlife program.

The Council especially would appreciate comments on the following issues raised in this
paper:

1 . What is the relative priority that should be accorded to wildlife in the Counctl's fish arxl wildlife
program in accordance with the Northwest Power Act?

2. Should the Council better define the wildlife program by establishing policy goals and
objectives and a framework for carrying them out? If so, please comment on the areas the
policy and objectives should address. Should a separate issue paper be prepared to discuss
alternative goals arxj objectives and an implementation framework?

3. Do any of the alternatives or a combination of the alternatives discussed in this paper offer
acceptable solutions for handling the wikJIife mitigation proposals before the Council? tf so,
which one(s) and why? If not, please suggest additional alternatives.

4. What is a reasonable way to determine the portion of wildlife impacts attributable to
hydropower at multipurpose dams? Is this a question the Council needs to resolve before
adopting mitigation plans?

5. If the Council concludes that it is appropriate to take more time in making a final decision on
the pending mitigation proposals, are there any projects within these proposals that could or
shoukl proceed in the interim? If so, why?

The Council is also seeking comment on the individual wiUlife mitigation proposals. To help
commentors, the wikJIife mitigation proposals for Grand Coulee, Willamette Basin, Palisades and
Anderson Ranch/Black Canyon dams are available upon request.

The schedule for preserrtation and comment on the issue paper is as follows:

September 14-15: Staff presentation of issue paper to the Council in Boise, Maho.

Octotjer 12-13: Public comment on issue paper at the Council meeting in Montana.

November 9-10: Public comment on issue paper at the Council meeting in
Washington.

December 14-15: Public commem on issue paper at the Coundi meeting in Oregon.

January 11-12, 1989: Public comment on issue paper at the Council meeting In
klaho.^

January 13: Deadline for written comments.

W The Council meeting schedule for 1988 has not been set. Therefore, the date and
location of the January Council meeting are tentative. If the Council does not hold its
monthly meeting in Idaho, alternative arrangements will be made to accommodate
public comment in kJaho.

February 8-9: Council deliberation. If the Council were to enter a formal amendnnent
process on any or all of the wildlife mitigation proposals, a new public comment
period would follow.

Consultations will be scheduled with interested parties throughout the public comment
period.

For copies of the wildlife mitigation plans contact Judy Allender, Northwest Power Planning
Council, 851 S.W. Sixth Avenue, Suite 1100, Portland, Oregon 97204, 503-222-5161;
1-800-452-2324 (Oregon toll-free number); or 1-800-222-3355 (regional toll-free number).

INTRODUCTION

The Northwest Power Act requires the Council to develop a program to "protect, mitigate and
enhance fish and wildlife" in the Columbia River Basin. 16 U.S.C. §839b(l)(A). In the legislative
history of the Act, Representative John Dingelt (D-Mich.) stated:

. . .In developing the program, the Council and BPA should not slight wildlife needs.
The fishery needs are important. Much emphasis and consideration of this
legislation was on the anadromous and other fishery resources. However, from the
beginning of our consideration of the bill in the House, we have stressed the need
to protect, mitigate the adverse effects on, and enhance both fish and wildlife."
(Cong. Rec. p. E5105 daily ed. Dec 1, 1980).

To carry out this mandate, the Council established in its 1982 Fish and Wildlife Program a
planning process to address the impacts of hydropower development and operations on wildlife in
the Columbia River Basin. The planning process was designed to identify specific impacts to
wildlife and its associated habitat, and to recommend appropriate mitigation measures. That
process includes the following steps:

1. development of status reports on wildlife planning and mitigation programs at hydroelectric
projects in the Columbia Basin;

2. presentation of statements identifying losses of wildlife and/or wildlife habitat;

3. development of mitigation plans; and

4. the subsequent incorporation of approved mitigation plans or appropriate alternatives into
the fish and wildlife program.

In Febmary 1987, the Council incorporated wildlife mitigation plans for Montana's Hungry
Horse and Libby dams into the fish and wildlife program. These were the first and only wildlife
mitigation plans to be reviewed and approved by the Council. During that amendment process,
the Council decided that all future wildlife mitigation plans should be considered in amendment
proceedings before they are included in the program for funding.

Since that time, the fish and wildlife agencies and tribes have completed wildlife mitigation
proposals for Grand Coulee Dam in Washington, eight Willamette Basin hydroelectric facilities in
Oregon, and the Palisades, Anderson Ranch and Black Canyon dams in Idaho. These proposals
have been forwarded to the Council for review and consideration.

Prior to making a decision on whether to enter rulemaking to incorporate the proposals in the
fish and wikjiife program. Council staff believes it is important to discuss these mitigation proposals
with affected regional parties. Concurrent with discussions on the merits of each of the individual
mitigation proposals, it would be useful to discuss several broader wildlife policy issues as they
relate to the program. Specifically, the Council will be seeking comment on the need for
establishing regional goals and objectives for the wikJIife program, the potential cost of the wildlife
program and its impact on ratepayers, the allocation of responsibility for wildlife losses and the
pace (schedule) at which wikllife projects shoukj be implemented.

To aid the Council and region in focusing discussions on these issues, this issue paper
explores:

1 . the history and status of the wildlife program;

2. the development and content of the mitigation proposals before the Council;

3. issues often raised concerning the wildlife program; and

4. several alternatives the Council may wish to pursue when making a decision on the wildlife
mitigation proposals.

BACKGROUND

The Wildlife Mitigation Planning Process

The Council's wildlife program contains a series of planning measures designed to formulate
wildlife mitigation plans for each of the hydroelectric facilities^ in the Columbia River Basin. This
planning process contains the following components. (In some cases, the planning process can
be modified to combine or eliminate various steps.)

1. Mitigation Status Reports

This planning measure (Section 1003(b)(1)) provided the Council with a review and analysis
of the status of past, present and proposed wildlife planning and mitigation programs at each of the
hydroelectric facilities in the basin. The status reports documented the need to pursue further
wildlife planning at each of the hydroelectric Polities. (Copies of the reports can be obtained from
the Council's Public Involvement Division.) This measure was funded by Bonneville and was
completed by the region's agencies and tribes in 1984.

2. WlldlifS Loss Statsmsnts

Tbe second planning step (Section 1003(b)(2)) in the wildlife program calls for Bonneville to
fund the development of wildlife loss statements at each of the hydroelectric facilities identified
from the mitigation status reports. The loss statements are being developed by the appropriate
wildlife agencies and tribes. The wildlife loss statements quantify the net impacts (positive and
negative) to wildlife and/or wildlife habitat from the construction and operation of a hydroelectric

2J Qenerally this issue paper is directed towards mitigation plans at federal hydroelectric facilities.
HowsMsr, the issue of how the Council's wildlife program directs wildlife planning at non-federal
projects remains unresolved and the Council is seeking comments on how to resolve the issue
as noted below. (See page 23.)

37 Although several contracts between Bonneville and the agencies and tribes called for a
quantification of impacts from the construction and operation of hydroelectric facilities, most
loss statements and mitigation plans dealt strictly with impacts from construction, i.e.,
inundation. The agencies and tribes have stated they believe they can examine "system
operation impacts" once the planning for the individual hydroelectrk; plans are complete.

facility. In most cases, wildlife loss statements and the corresponding mitigation plans are being
developed on a hydroelectric project-by-project basis.

3. Wlldllta MNigatlon Plans

The third planning step (Section 1003(b)(3)) funded by Bonneville is the development of a
wildlife mitigation plan to address the impacts identified in the loss statements. Once mitigation
plans are completed by the appropriate agencies and tribes, they are forwarded to the Council for
review. Mitigation proposals for Grand Coulee Dam, the Willamette Basin facilities. Palisades Dam,
and Anderson Ranch and Black Canyon dams have reached this stage of the planning process.
Attachment 1 provides the status of wildlife planning at federal hydroelectric facilities in the basin.

4. Program Amendments

The final action in this four step planning process (Section 1003(b)(4)) calls for the Council to
amend the mitigation plans or appropriate alternatives into the fish and wildlife program. Council
action is needed before Bonneville or the appropriate project operator begins funding the
implementation of the mitigation plan(s). Prior to the submission of the current wildlife proposals,
the Hungry Horse and Libby wildlife mitigation plans were the only plans to have come before the
Council. Those plans were amended into the fish and wildlife program in February 1987, and
implementation is being funded by Bonneville.

WILOUFE PROGRAM IMPLEMENTATION

1 . Hungry Hors« and Ubby Dam Mitigation Plans

The Council made several significant decisions in the course of adopting the Hungry Horse
and Libby mitigation plans. First, the Council determined that ratepayers should not be held
accountable for funding 100 percent of the wildlife mitigation at these hydroelectric facilities. To
determine the hydropower (ratepayer) obligation, the Council selected the Congressional
repayment allocation (percent of invested dollars returnable to the Federal Treasury to repay
borrowed funds) as a method to determine implementation responsibilities. Using this method, the
hydropower obligation was reduced to approximately 77 percent of total mitigation costs for both
mitigation plans. The Council explicitly stated that this method should not be construed as a
precedent for future mitigation plan decisions. The Council felt at that time there had not been
sufficient discussion and analysis of the allocation issue to adopt one method for all future wildlife
mitigation plans.

Second, the Council rejected certain portions of the Hungry Horse and Ubby mitigation plans
because they proposed the conduct of additional studies to identify long-range management plans.
The Council did not believe that further study constituted effective mitigation.

AJ See Northwest Power Planning Council Issue Paper, Hungry Horse Dam: Wildlife Mitigation
Proposal (February 1986) and Columbia River Basin Fish and Wildlife Program, Appendix C, p.
20 (February 1987).

Third, the Council urged all parties to explore alternative methods, including a trust fund, for
financing the wildlife mitigation measures at these facilities. The trust fund approach involves
Bonneville Power Administration placing funds in an interest-bearing account. The implementing
wildlife agency can draw on this account to fund approved wildlife mitigation activities. In theory,
the account would be managed to produce additional funds for mitigation over time. Currently,
Bonneville and the Montana Department of Fish, Wildlife and Parks are continuing negotiations on
a trust fund for long-term implementation of measures at Hungry Horse and Libby dams. Parties
are hopeful an agreement can be reached and forwarded to the Council later this calendar year.

PENDING WILOUFE MITIQATION PROPOSALS

This section of the paper summarizes the wildlife mitigation proposals currently before the
Council. Further descriptions and analysis of the proposals occur later in this paper. Because the
proposals are lengthy, their details are summarized by the use of tables. Attachment 2 contains
maps of the study areas for each of the hydropower facilities. Attachment 3 provides a summary of
the estimated wildlife impacts (losses) identified by the agencies and tribes. Additional detail can
be found in the individual mitigation proposals available from Bonneville Power Administration or
the Council.

1. Th« Grand Coule* Proposal (Summarized from "Wildlife Protection, Mitigation and
Enhancement Planning for Grand Coulee Dam," Rnal Report, August 1986.)

Grand Coulee Dam was completed in 1941 and impounded the Columbia River to form
Franklin D. Roosevelt Reservoir, which is 151 miles long and averages 4,650 feet wide. In addition
to the Columbia River, the reservoir includes portions of the Sandpoil River, the Spokane River, the
Colville River, the Kettle River, and other tributary streams. At full pool level, the reservoir is 385
feet deep near the dam, has a surface area of about 82,270 acres, and holds approximately 5
million acre feet of water or about 10 percent of the Columbia River's average annual flow at the
Canadian border. Grand Coulee Dam, with an installed capacity of 6,180 megawatts, is a
multipurpose project and is operated and maintained by the U.S. Bureau of Reclamation (Bureau).
Congress provided no funding to mitigate the hydropower-related effects of the project on wildlife.

The wildlife mitigation proposal for Grand Coulee Dam was completed by the Washington
Department of Wildlife in late 1986 and submitted to the Council for action in January 1987. The
planning process used to develop the mitigation plan was unique in two ways. First, a detailed bss
statement (1003(b)(2)) was not completed for Grand Coulee Dam. This planning step was
bypassed at the request of the Council. The Council feit it would be better for the affected parties
to move directly into mitigation planning (1003(b)(3)) rather than spend time detiating the size of
the wildlife losses.

Second, the Grand Coulee mitigation proposal was developed under the supervision of an
oversight committee. The committee included representatives of the pertinent wildlife agencies,

5J The Pacific Nortfiwest Utilities Conference Committee has argued that a substantial amount of
wildlife mitigation has been undertaken in conjunction with the Columbia Basin Project. The
agencies and tribes argue that these mitigation activities were designed to mitigate for
irrigation development, not hydropower development

tribes, the Bureau of Reclamation, Council staff, Bonneville and the utility sector. The committee
provided guidance and direction during development of the mitigation proposal.

a. Wildlife Losses. In place of a detailed wildlife loss statement, the Washington
Department of Wildlife used a different procedure to identify and quantify impacts. Initially a
working paper outlined concerns and direction for wildlife planning. The working paper proposed
mitigation concepts and a "conceptual" goal. The goal was acquisition of lands or management
rights to lands totaling approximately 70,000 acres, and improvement and maintenance of those
lands to increase and maintain wildlife carrying capacity (the maximum number of animals an area
can sustain without suffering vegetation and other habitat damage).

Then, the Washington Department of Wildlife performed a limited study to estimate losses of
wildlife and habitat due to inundation and reservoir level fluctuations resulting from development
and operation of Grand Coulee Dam for hydropower production. Habitat losses were determined
from interpretation of pro-project aerial photographs. Indicator species were chosen to represent
general habitat types and habitat requirements of most wildlife which were known to occur in the
study area and which were likely to have been affected by the project. Losses in terms of habitat
were determined for the indicator species using a modification of the U.S. Rsh and Wildlife Service
Habitat Evaluation Procedure.

b. Mitigation Proposal. To fully replace the estimated habitat unit losses associated
with Grand Coulee development, the Washington Department of Wildlife estimated that 244,722
acres of land would need to be protected and improved for wikllife. Rather than pursue full redress
for losses, the Washington Department of Wildlife proposes to protect the same number of habitat
units as were lost (approximately 73,522 acres) due to the inundation behind Grand Coulee Dam.
As estimated by the Washington Department of Wildlife, this is less than one third of the estimated
wildlife and habitat losses caused by Grand Coulee Dam.

67 The working paper was drafted by the Washington Department of Wildlife from a meeting held
on April 2, 1985 to discuss wikjiife planning efforts. Representatives from the agencies, tribes,
utilities. Bureau, Bonneville and the Council attended the meeting. While the concept of the
"conceptual" goal was discussed, it may not have been agreed to by all parties attending the
meeting. However, no other goals were offered as alternatives.

77 Generally, wikJIife agencies and tribes in Washington, Oregon and Idaho have used a process
known as the Habitat Evaluation Procedure to evaluate habitat losses. U.S. Fish and Wildlife
Service, Division of Ecological Services, "Habitat Evaluation Procedure" (1980). Using the
process, habitat losses for each target species are represented by Habitat Units (quantity of
habitat multiplied by quality) instead of arbitrary acreages assigned for replacement purposes.
One Habitat Unit is equal to one acre of optimum habitat for an individual target species. To
compare preconstruction with replacement habitat, agencies assign habitat suitability values
for a given indicator species selected to represent a number of species using similar habitat.
The Habitat Evaluation Procedure is a modeling tool that has been used by the fish and wikJIife
agencies and tribes for several years. Like any model, its reliability rests with the quality of
data used by the agencies and tribes to estimate wildlife habitat losses and gains. To ensure
the best data was applied, the agencies and tribes utilized interagency teams of biologists to
assist in data gathering and analysis at each of the hydroelectric projects.

The final mitigation proposal is composed of the following parts, which would be divided
between the Colville Confederated Tribes, the Spokane Tribe and the State of Washington:^

• Acquisition of sufficient land or management rights to protect habitat units equivalent
to those lost Approximately 73,000 acres of land would be required. Priority parcels
are identified in the mitigation proposal. Habitat unit types include protection for
several upland game, non-game, riparian, waterfowl and big game species.

• Improvement and management of these lands to obtain and perpetuate the habitat
units. Annual operation and maintenance funds are being requested for the life of the
project

• Protection and enhancement of identified bald eagle territories and communal roosts.
Selected tree planting on protected lands, and protection and enhancement of
potential nesting habitat if warranted.

2. The Willamette Basin Proposal (Summarized from "A Wildlife Habitat Protection, Mitigation
and Enhancement Plan for Eight Federal Hydroelectric Facilities in the Willamette River Basin,"
Final Report, May 1987.)

The Willamette Basin hydroelectric facilities are located in three major drainages of the
Willamette River Basin. Cougar Dam (25 MW) is located on the South Fork McKenzie River Dexter
(15 MW), Lookout Point (120 MW) and Hills Creek (30 MW) dams are located on the Middle Fork
Willamette River; Foster Dam (20 MW) is located on the South Santiam River Qreen Peter Dam (80
MW) on the Middle Santiam River; and Big Cliff (18 MW) and Detroit (100 MW) dams on the North
Santiam River. Construction of the facilities was initiated between 1947 and 1961 with operations
commencing between 1954 and 1969. All eight dams are multipurpose facilities and are operated
and maintained by the Corps of Engineers (Corps). Congress provided no funding to mitigate the
effects on wildlife at these facilities.

The wildlife mitigation proposal for the Willamette Basin hydroelectric facilities was completed
and submitted to the Council for action in May 1987 by the Oregon Department of Fish and
Wildlife. Wildlife loss statements were completed for each of the individual hydroelectric facilities in
the Willamette Basin. The decision to develop a comprehensive mitigation plan at all projects
simultaneously was based on the limited wildlife enhancement opportunities close to the
reservoirs, the homogeneity of the affected and existing environment around the reservoirs, and
the fact that all the projects are operated arxJ maintained by the Corps.

Development of the mitigation proposal was consistent with the planning provisions outlined
in Section 1003(b) of the fish and wildlife program. The Oregon Department of Rsh and Wildlife
was the lead agency for the development of the wildlife loss statement (1003(b) (2)) and the

6J Estimated larxl needs (aaes to acquire) identified in the proposal are:

Colville Spokane State

Private/Allotted Lands 7,300 3,210 41,132

Public/Tribal Lands 4,000 7.380 10,500

corresponding mitigation proposal (1003(b)(3)). An interagency coordination team composed of
federal and state agencies and the Corps participated in the development and review of the
mitigation proposal.

a. Wildlife Losses. The method used to evaluate the net impacts to wildlife as a result qf
the Willamette facilities was a habitat-based approach utilizing the Habitat Evaluation Procedure.
Using the procedure, an interagency team of biologists selected evaluation or "target" species and
subsequently evaluated habitat conditions based on the selected species habitat criteria. The
Oregon Department of Fish and Wildlife states that only impacts attributable to hydroelectric
development, maintenance and operation were evaluated, i.e., impacts from irrigation, power lines,
roads, project operation, etc. were not addressed. The Oregon Department of Fish and Wildlife
calculated the wildlife losses attributable to hydropower by determining the percentage of project
flows required for hydropower operation. The remaining non-hydro portion of flows was used to
reduce the level of proposed mitigation so that ratepayers would fund only hydro-related
mitigation. The Oregon Department of Fish and Wildlife believes this is the best method for
determining losses attributable to hydropower.

b. Mitigation Proposal. From the loss statement, the Oregon Department of Fish and
Wildlife estimated that 20,123 acres of prime habitat (15,295 ell< habitat units) were permanently
lost as a '■esjult of the eight hydroelectric facilities. The habitat losses were grouped into three
categories: big game winter range, riparian habitat (i.e., vegetation along streams and rivers),
and old-growth forest (i.e., timber stands 200 years old or more).

The goal of the mitigation proposal is to protect sufficient habitat through purchase,
easement and enhancement to compensate for the value of the habitat directly impacted, and
regain wildlife management opportunities. This goal seeks to mitigate for the type and proportion
of the original habitat to the greatest extent possible, thus benefiting the largest number of affected
wildlife species. To address these goals, the Oregon Department of Fish and Wildlife suggests the
following mitigation approach:

• Purchase or acquire management rights for 20,000 acres of cut-over forest lands as
mitigation phmahly for big game winter range. Improve and manage these acquired
lands.

• Purchase approximately 4,400 acres of private land along the Willamette River
Greenway as mitigation for riparian habitat.

9./ See footnote 7.

10^ Essentially, the division of 20,123 acres represents "critical" big game winter range dissected
into components (i.e., 49 percent general purpose winter range, 25 percent riparian, and 26
percent old-growth). The most important reason for this approach is that, although riparian
habitat and old-growth forest are necessary to the existence of critical elk winter range, they
also have intrinsic value to many other wildlife species.

-10-

• Acquire old growth forest land according to one of the following options:

Option 1 : Purchase 3,956 acres of Douglas fir forest land with the majority of the
timber stand being at least 150 to 200 years old and possessing the attributes of true
"old-growth" forest.

Option 2: Purchase 5,934 acres of second growth forest land that is at least 40 years
old for eventual replacement of old-growth.

Option 3: Take 25 percent of the average cost of Options i and 2 (approximately $20
million) and dedicate it to partial mitigation of old-growth when the opportunity arises,
with the remaining to be spent to maximize the other mitigation opportunities m the
proposal.

• Improve and manage these acquired lands.

• Use enhancement on public lands and other options to achieve mitigation goals when
and where the opportunities exist and are consistent with the overall mitigation goal.

3. The Palisades Proposal (Summarized from "Wildlife Protection, Mitigation and
Enhancement Plan - Palisades Project," Final Report, 1986.)

Palisades Dam and Reservoir are located on the South Fork Snake River, approximately 50
miles southeast of Idaho Falls, Idaho on the Idaho/Wyoming border. Construction of Palisades
Dam began in 1951, and the dam and power plant were completed in 1957 and 1958, respectively.
Palisades Dam created a 1 5,600 surface-acre reservoir (890 acres are in the state of Wyoming)
with over 1 million acre-feet of water storage capacity. Palisades Dam (131 MW) is a multipurpose
facility and is operated and maintained by the Bureau of Reclamation. Congress provided no
funding to mitigate the impacts on wildlife.

The wildlife mitigation proposal for Palisades Dam was completed by the Idaho Department of
Fish and Game in November 1986 and submitted to the Council for action in early 1987.
Development of the wildlife mitigation proposal was consistent with the planning provisions
contained in Section 1003(b) of the fish and wildlife program. The U.S. Fish and Wildlife Service
was the lead agency for the development of the wildlife loss statement for Palisades Dam. The
Idaho Department of Fish and Game was the lead agency for the development of the

1W There was disagreement between the U.S. Fish and Wildlife Service and the Oregon
Department of Fish and Wikjiife over the level of mitigation for the old-growth component of
the proposal. The disagreement has not been resolved. Therefore, the Oregon Department
of Fish and Wikjiife provided three funding options for the Council to consider m its action on
the proposal.

12./ The Bureau has been responsive to agency requests for flow releases from Palisades
Reservoir for fish and wildlife values. However, no structural measures have been
implemented to mitigate for the loss of habitat due to the impoundment of Palisades
Reservoir or for the loss of wikJIife below the reservoir.

-11-

corresponding wildlife mitigation proposal. All affected federal and state agencies, tribes and the
project operator participated in the development and review of the mitigation proposal.

a. Wildlife Losses. The method used to evaluate the net impacts to wildlife as a result of
the Palisades project was a habitat-based approach using the Habitat Evaluation Procedure. An
interagency work group of biologists selected evaluation species to represent important species
groups or species of special concern. Impacts to evaluation species were measured in terms of
the difference between pre- and post-construction habitat units. The Idaho Department of Fish and
Game states that all project impacts are attributable to hydroelectric development since the project
was economically unfeasible without the hydropower component. Accordingly, the agency
attributes lOO percent of the wildlife impacts to hydropower development.

b. Mitigation Proposal. From the loss statement, the Idaho Department of Fish and
Game and the interagency work group agreed that a reasonable mitigation goal would be to
protect and/or enhance the same number of target species habitat units that were lost due to
inundation. Furthermore, it was agreed that wildlife should be protected and enhanced in both
Idaho and Wyoming to reflect each state's wildlife impacts. The mitigation proposal used the
estimated habitat lost (approximately 37,068 habitat units for several target species) as a guideline
for developing mitigation objectives, while also considering the needs of wildlife in the area.
Operation and maintenance funds are proposed for the life of the hydropower project. To achieve
the stated goal, the Idaho Department of Fish and Game and the interagency team suggest the
following proposals:

• Bald Eagle and nongame riparian species: Protect by easement or acquisition and
enhance 5,825 acres of riparian habitat, preferably along the South Fork and Henrys
Fork of the Snake River. Enhance bald eagle nest sites in the vicinity of Palisades
Reservoir. Establish bald eagle winter perches on the Market Lake and Mud Lake
Wildlife Management Areas.

• Big Game (Elk and Mule Deer): Protect by easement or acquisition and enhance
13,790 acres of big game winter range in eastern Idaho, preferably in Sand Creek or
Swan Valley areas.

• Waterfowl/Aquatic Furbearers: Enhance habitat in the Market Lake and Mud Lake
Wildlife Management Areas and in the upper end of the reservoir. Protect by
easement or acquisition 1 ,000 acres in the Grays Lake area.

• Ruffed Grouse: Enhance 4,928 acres of aspen forest in the Bridger-Teton National
Forest Enhancement will include prescribed burning and other methods to stimulate
aspen regeneration.

• Peregrine Falcon: Establish and maintain for at least 10 years three reintroduction
sites near the reservoir.

13./ See footnote 7.

-12-

4. Th« And«rson Ranch and Black Canyon Proposals (Summarized from "Wildlife
Protection Mitigation and Enhancement Plans - Anderson Ranch and Black Canyon Facilities,"
Final Report, 1986.)

Anderson Ranch Dam is located on the South Fork of the Boise River, about 20 air miles
north of Mountain Home, Idaho. The reservoir inundated 4,740 acres of habitat, 18.3 miles of river
channe* and 6.7 miles of tributaries. Anderson Ranch Dam (40 MW) was completed in 1950 and is
operated and maintained by the Bureau of Reclamation. Congress provided no funding to mitigate
the impacts on wildlife at the project

Black Canyon Dam is located on the Payette River near Emmett, Idaho. The reservoir, at full
pool, extends about nine miles upstream from the dam and covers about 1,100 acres. Black
Canyon Dam (8 MW) was completed in 1924 and is also operated and maintained by the Bureau.
Black Canyon Dam and upstream storage reservoirs provide a system that allows the Bureau to
optimize irrigation releases and power production. Deadwood and Cascade reservoirs were both
authorized with expectations of contributing to federal power production at Black Canyon Dam.
Congress provided no funding to mitigate the impacts on wildlife.

The wildlife mitigation proposals for Anderson Ranch and Black Canyon dams were
completed by the Idaho Department of Fish and Game in late 1986 and submitted to the Council
for action in 1987. Development of the mitigation proposals for these facilities was consistent with
the planning provisions outlined in Section 1003(b) of the Council's fish and wildlife program. The
Idaho Department of Fish and Game was the lead agency for the development of the loss
statement and mitigation proposals. All of the pertinent federal and state wildlife agencies, tribes
and the Bureau participated in the development of the mitigation proposals.

a. Wildlife Losses. Like the Palisades proposal, the method used to estimate the net
impacts to wildlife as a result of Anderson Ranch and Black Canyon dams was a habitat-based
approach using the Habitat Evaluation Procedure. An interagency work group of biologists
selected evaluation species to represent important species groups or species of special concern.
Impacts to evaluation species were measured in terms of the difference between pre- and post-
construction habitat units. The Idaho Department of Fish and Game states that only impacts
attributable to hydropower were evaluated. The agency maintains that since the projects were
economically unfeasible without the hydropower benefits, the wildlife mitigation costs should be
fully attributable to hydropower development.

147 The Bureau leased 2,300 acres to the Idaho Department of Fish and Game between 1953 and
1978 (not renewed). Project lands around the reservoir received national forest status in
1968. The Forest Service received full administrative authority for these lands in I97a

157 The upper one-third of the reservoir has silted in, causing flooding of adjacent land. The
Bureau has acquired 1 ,095 acres of these lands. These lands are managed as the Montour
Wildlife/Recreation Area under an agreement signed by the Bureau and the Waho Department
of Fish and Game in 1983. The Bureau also leases about 35 acres to the Idaho Department
of Fish and Game downstream of the dam under an agreement signed in 1981.

167 See footnote 7.

-^9'

b. Mitigation Proposals. From the loss statements, the Idaho Department of Fish and
Game and the interagency work team agreed that a reasonable goal would be to protect and/or
enhance the same number of target species' habitat units that were lost as a result ot inundation of
the reservoirs. The mitigation proposals used the estimated habitat lost (approximately 9,619
habitat units for selected target species at Anderson Ranch Dam and 2,238 habitat units for
selected target species at Black Canyon Dam) as guidelines for addressing objectives, while also
considering the needs of wildlife in the area. Because large multispecies mitigation projects are
proposed, some target species will gain more habitat units than were originally lost, and some will
gain fewer. To address the needs for wildlife in the area, the proposal suggests that some trade-
offs between extra benefits to some target species would have to occur. To achieve the goals for
both projects, the Idaho Department of Fish and Game and the interagency team suggest the
. following proposals:

Anderson Ranch

• Riparian and upland species: Protect through easement or acquisition, enhance and
maintain 6,100 acres of wetlands and uplands in the Camas Creek area; 960 acres of
Columbian Sharp-tailed Grouse habitat associated with the Nelsofi Ranch (a Nature
Conservancy Project); and 200 acres of forested wetlands on the Boise River.

• Mule deer: Enhance 15,500 acres of mule deer winter range on BLM lands in the
Bennett Hills area.

• Peregrine Falcon: Establish and maintain one reintroduction site for at least 10 years.

• Anderson Ranch Borrow Site: Rehabilitate and enhance the site that provided fill for
the dam.

Black Canyon

• Riparian and upland species: Protect by easement or acquisition, enhance and
maintain 800 acres of wetlands and uplands in the Bruneau River Valley.

• Columbian Sharp-tailed Grouse: Protect by easement or acquisition, enhance and
maintain 600 acres of habitat associated with the Nelson Ranch.

• Mule Deer: Protect by easement or acquisition, enhance and maintain 500 acres of
winter range adjacent to the Boise River Wildlife Management Area.

PROGRAM ISSUES

Over the past six years, the Columbia Basin agencies and tribes have developed wildlife
protection, mitigation and enhancement proposals for the federal hydroelectric projects in the
basin. Throughout this period, the agencies and tribes have followed the planning guidelines set
forth in the Council's fish and wildlife program. While all parties have not always agreed with the
planning process used to develop these proposals, participation by affected entities was
encouraged by the agencies and tribes (using mailings, meetings, etc.) and participant
recommendations were taken into account.

-14-

utility representatives and, to a lesser degree, the Corps of Engineers have often been critical
of the current wildlife planning process. Their dissatisfaction has centered around the following
issues: 1) the need to address impacts to wildlife utilizing a basinwide approach, rather than a
project-by-project approach; 2) disagreement with the methods used by the agencies and tribes to
determine impacts to wildlife: 3) a belief that the costs of wildlife mitigation must be allocated
among the project purposes at multipurpose facilities; and 4) a concern that the overall costs of
the mitigation proposals are too high and should be negotiated.

Disagreement between the parties (i.e., utility interests and the agencies and tribes) has led to
polarized opinions regarding wildlife mitigation planning in the basin. Since the Council's decision
on the Hungry Horse and Libby dam plans, the utility representatives have preferred not to
participate in development of the wildlife mitigation plans and generally have worked internally to
develop positions for later presentation to the Council.

To further the discussion of wildlife issues, the Council staff has developed several
alternatives for regional consideration. The staff is not suggesting that any one of these
alternatives is the best course of action for the Council, and the various interests may be able to
propose additional alternatives for consideration. Each of the alternatives offers different solutions
to some of the complex wildlife issues before the Council. StkU has also sketched the most
frequently raised issues about each alternative.

177 The Corps and the Pacific Northwest Utilities Conference Committee (PNUCC) in past years
have submitted amendment applications to the Council to revise the wildlife planning process
(Section 1003(b)). In 1984, PNUCC, the Columbia Basin Rsh and Wildlife Council and the
Montana Department of Fish, Wildlife and Parks suggested (by amendment application) the
Council clarify various Section 1003(b) planning measures. The Council adopted language
from these applications and Section 1003(b) has remained unchanged. During the same
amendment process, the Council received an amendment application from the Corps that
called for a substantial revision of the wildlife program. The Corps proposed a detailed
program for protecting selected wildlife species by establishing basinwide wildlife goals and
objectivm. While the Council found worthwhile many of the elements in the amendment, it
was rejected because the proposed process deviated too much from the wildlife planning
approach followed since 1983. See amendment applications PN/I004(b)(1), pp. 2134-2152,
CB/1004(b), pp. 2120-2133, MF/1004(b)(1), pp. 2185-2200, CE/1004 pp. 2095-2119,
Northwest Power Planning Council Applications for Amendment, Section 1000, Vol. V
(January 1984). In 1987, the Council rejected another amendment application submitted by
PNUCC calling for another revision to the Section 1003(b) planning process. This application
essentially called for negotiation of mitigation plans by the affected parties. See Columbia
River Basin Fish and Wildlife Program, Appendix C, p. 27, (February 11, 1907).

-19>

ALTERNATIVES

Alternativs 1. Amend the wildlife mitigation proposals as submitted by the wildlife agencies
and tribes into the fish and wildlife program.

Approach

The wildlife mitigation proposals for Grand Coulee, the Willamette Basin, Palisades, Anderson
Ranch and Black Canyon dams were developed by the wildlife agencies and tribes consistent with
the direction provided by the Council in Section 1003(b) of the Columbia River Basin Fish and
Wildlife Program. The Council could approve the wildlife mitigation proposals in total and amend
them into the fish and wildlife program.

Summaries of the methods used to determine impacts (losses) and the protection and
enhancement proposals to address those impacts were presented earlier in this paper.

The proposed schedule for implementation and estimated costs are summarized in the
following table. The cost figures for the proposals are the best estimates of the agencies and tribes
at this time. The agencies and tribes have indicated they are flexible on extending these schedules,
if necessary.

State/Facility
Washington
Grand Coulee

Oregon

Willamette Basin

Estimated Cost

$41 .3 million ($1 .5
million annual operation
and maintenance)

$46.3 to $106.3 million
(annual O&M costs
after implementation
are uncertain)

Proposed Implementation Schedule

10 years for initial implementation
plus annual operation and maintenance
for the life of the project

20 years for initial implementation.

Idaho

Palisades

$15.7 million
($326,900 annual O&M)

10 years for initial implementation
plus annual O&M for the life
of the project

Anderson Ranch

$4.5 million
($144,000 annual O&M)

Same as Palisades.

Blaci< Canyon

$0.8 million
($30,000 annual O&M)

Same as Palisades.

-16-

The agencies and tribes have provided the Council with a list of priority wildlife actions spread
over various implementation periods in their respective mitigation proposals. This information
could be incorporated into the Council's Rve-year Action Plan. Implementation could proceed in a
manner similar to that used tor Hungry Horse and Libby dams, where the Action Plan sets up a
schedule for advanced design (taking what are conceptual projects and designing them in greater
detail), implementation and monitoring.

Approving the full scope of the mitigation proposals obviously would be viewed positively by
the agencies and tribes. It would provide the greatest level of mitigation to the wildlife and wildlife
habitat impacted by the various dams. Approving the mitigation proposals also would reconfirm
the Council's past actions that a project-by-project approach (i.e., developing wildlife mitigation
proposals as set forth in Section l003(b)(2)-(4) of the program) is the correct method for
developing future wildlife mitigation proposals. This would give Bonneville and the agencies and
tribes the necessary direction to continue planning for the remaining hydroelectric facilities.

Issues

A decision to approve the mitigation proposals, as submitted by the agencies and tribes,
raises a number of issues. The following are the most likely to arise:

• Approval of the mitigation proposals would entail agreeing with the agencies' and tribes'
determination of the mitigation levels that should be funded by the ratepayers. While the case
made by the agencies and tribes deserves further discussion, some would argue that the
method of allocating wildlife mitigation costs is not correct and places too large a financial
obligation on the ratepayers.

• The estimated costs of the mitigation proposals are high, especially in light of Bonneville's
current wildlife budget To fully execute the pending mitigation proposals, as much as $10
million may be needed per year over the implementation period mentioned earlier. Currently,
Bonneville's wildlife budget is $1.1 million. The budget is expected to grow to $4.4 million in
Fiscal Year 1989 and is proposed at $5 million for Rscal Year 1990, or about 10 percent of the
total fish and wildlife budget. These numbers are current estimates and could change. In
addition to the costs for the new wildlife proposals, Bonneville will be funding wildlife planning
for the remainder of the federal hydroelectric facilities and will be continuing to implement
mitigation measures at Hungry Horse and Libby dams.

• Qenerally, the pending wildlife proposals stress land acquisition (by fee title purchase or
easemerrt) as the primary tool for achieving mitigation. While the agencies and tribes state
that their proposals conform to the land acquisition criteria spelled out in the program,
(Section 1003(d)(1)-(2)), large-scale land purchases raise a number of policy and institutional
issues. In particular, concerns arise about the tax impact of acquisition (i.e., would land
purchaas remove larxj from property tax rolls?). In addition, another issue likely to arise is
the responsibility for operation and maintenance costs and the management arrangements
for acquired lands (i.e., will the lands be dedicated for wildlife purposes only or will other
practices, such as cattle grazing, be permitted?).

-17-

Alternative 2. Adjust the wildlife mitigation proposals so that only a specified portion of the
mitigation is funded by the region's ratepayers. Amend the proposals into the program
accordingly.

Approach

Section 4(h)(8)(B) of the Northwest Power Act states in part that "consumers of electric
power shall bear the cost of measures designed to deal with adverse impacts caused by the
development and operation of electric power facilities and programs only." Some argue that
because most of the federal dams are multipurpose projects and most of the project features
causing impacts to fish and wildlife serve all project purposes, hydroelectric power purchasers are
not obligated to pay for all fish and wildlife impacts caused by the project but only for the
hydroelectric share of those impacts.

If the Council accepts this view and determines that the ratepayers should not be held
accountable for 100 percent of the mitigation, it could adjust the mitigation proposals by some
allocation method and amend that decision into the fish and wildlife program. This type of action
would be similar to the decision made by the Council for the Hungry Horse and Libby dams wildlife
mitigation plans.

In its decision on the Hungry Horse and Libby mitigation plans, the Council used the
Congressional repayment formula to determine the ratepayer obligation. The Council also has
used this formula as one method to determine the oercentage of basinwide salmon and steelhead
losses attributable to hydroelectric development Simply stated, the Congressional repayment
formula shows how Congress determined the cost of a dam should be repaid (in percent of total
returnable dollars from the plant investment). While several other methods for determining
ratepayer responsibility are available, most discussions have centered around the Congressional
repayment formula and the Corps/Bureau Joint Cost Allocation which uses the Separable Costs-
Remaining Benefits (separable costs) method. This separable costs method assigns project
costs to individual project purposes. The allocation is based on the costs directly attributable to an
individual project purpose (e.g., a powerhouse, which is part of the dam only in order to generate
power) plus a share of joint costs (e.g., the cost of the dam, which serves all project purposes).
The joint costs are allocated in proportion to the planned benefits of each individual project
purpose.

^8J In their estimates of salmon and steelhead losses, the Council estimated anadromous fish run
size reduction due to "dam losses." The Council multiplied the dam loss figure by the
average percent of hydropower purpose of dams to obtain a loss figure attributable to the
hydropower system. While the Council looked at several allocation methods, it concluded
that the repayment allocation method appeared appropriate as the estimate of the
percentage of dam loss attributable to the hydropower for federal projects, because this
represents the amount of the project that is being paid for by hydropower ratepayers.

197 The Allocation of Rsh and Wildlife Costs, Pacific Northwest Utilities Conference Committee,
September 1987.

-18-

The following table shows the adjustment (percentage) tor hydropower allocation using these
two methods.

Congressional Separable Costs

Project Repayment Method

Grand Coulee 91.5% 43%

Willamette Basin

Cougar 31 23

Detroit/Big Cliff 61 40.5

Green Peter/Foster 55 -41,5

Hills Creek 36 24.5

Lookout Point/Dexter 48 31

Palisades 12 7.5

Anderson Ranch 33 5

Black Canyon 33 50

Should the Council choose one of these methods, it could adjust the proposed values in the
five mitigation proposals, i.e., adjust the habitat types (acres) and/or the habitat units, which would
reduce the number of proposed projects and the overall mitigation cost.

Issues

Limiting the ratepayer responsibility for wildlife mitigation proposals by use of any of these
allocation methods would reduce significantly the overall cost of mitigation. The Council would be
agreeing that the dams are multiple purpose facilities and that the ratepayers of the region should
not be held responsible for paying 100 percent of the mitigation for losses to wildlife and wildlife
habitat.

The agencies and tribes are likely to oppose this alternative. Their position is that the
mitigation proposals estimated losses and addressed mitigation for hydro-related losses.
Therefore, the agencies and tnbes believe strongly that the ratepayers of the region should fund
the mitigation they are proposing.

Alternative 3. Defer action on the pending wildlife mitigation proposals until wildlife policy
issues can be addressed or all wildlife mitigation planning under the program is complete.

Approach

There are two variations of ihis alternative. First, the Council coukJ defer entering rulemaking-
on the pending wildlife mitigation proposals for a period of time, allowing more time for discussion
of basinwide wildlife policy issues, perhaps through development of a wildlife policy issue paper.

-19-

A short-term deferral (less than one year) could give the Council more time to analyze the
complex wildlife policy issues raised in this paper. During this time period, the Council could
sponsor a series of regional workshops, round tables or consultations with the affected parties.
The Council also could use its authority to establish a technical and/or policy-level advisory
committee to discuss and forward wildlife recommendations to the Council. In the interim, the
Council could approve priority wildlife projects identified in the mitigation proposals. Alternatively,
current mitigation proposals could be held until the wildlife policy issues are resolved.

Second, the Council could consider a longer-term deferral until all wildlife mitigation planning
for the federal hydroelectric facilities in the basin are complete. This would allow the Council to
review the full scope of the basin's wildlife proposals before taking action.

issues

Obviously, an advantage of deferring action would be to give the Council added time to
deliberate on these issues. However, there are disadvantages. First, some of the wildlife mitigation
proposals have been pending for nearly two years. Deferral of action may be interpreted as
affording wildlife mitigation a low priority.

Further, since a short-term deferral places the agencies and tribes in a holding pattern for
implementing measures at Grand Coulee, the Willamette Basin, Palisades, Anderson Ranch and
Black Canyon dams, the agencies and tribes are likely to oppose it. In addition, it is uncertain that
deferral will result in consensus on wildlife issues, as many of the issues have been debated for
some time.

Waiting until all wildlife mitigation proposals are complete before making a decision on the
pending proposals would result in a delay of at least two years. Several wildlife planning
documents (loss statements/ mitigation proposals) for other hydroelectric projects in the basin are
not scheduled to begin until late this fiscal year or next. It is possible that the time needed to
complete these proposals fully could be as much as three years. Should the Council choose to
defer action, it might be useful to provide additional guidance for the completion of the plans at the
remaining hydroelectric facilities in the basin.

Alternative 4. Define the boundaries of the wildlife program by a specified program level of
effort and pace implementation for approved mitigation proposals over an appropriate time
period.

Approach

The Council might decide to pace the implementation of wildlife mitigation projects through a
program level of effort approach. That is, the Council could determine a level of wildlife funding
that Bonneville or others "can be expected" to fund over a given number of years. Various
alternatives could be used to implement this approach:

-20-

• Approvs sp«cif1c wildlife projects and control the pace of Implementation In the Action <
Plan. '

Using this approach, the Council could approve specific wildlife projects (e.g., from the
perxjing and future wildlife mitigation proposals) and amend them into the fish and wildlife
program. Wildlife projects included in the program would have to meet the Act's general
standards in section 4(h)(5)-(6), i.e., they: protect, mitigate and enhance wildlife affected by
the development at the hydroelectric facilities; do not impact a reliable power supply;
complement activities of fish and wildlife agencies and tribes; are based on the best available
scientific knowledge; use the least expensive means of achieving a sound biological
objective; and are consistent with Indian legal rights (see Section 4(h)(5)-(6) of the Northwest
Power Act).

To pace the implementation of these wildlife projects, the Council could estimate (i.e., based
on judgment of proper funding levels comparing wildlife needs with fish needs) the levei of
effort Bonneville can be expected to fund over the next five years. The Council would include
in the Action Plan (for funding in coming five years) only those wildlife projects that it found
consistent with the funding level of effort. The Action Plan list could be amended
subsequently as needed to include new wildlife projects from future mitigation proposals or to
alter the level of effort.

• Limit the program level of effort to wildlife projects that address the greatest need for
wildlife restoration or protection and pace the Implementation In the Action Plan.

In this method, the pace of implementation and funding level of effort would remain the same (C

as the preceding approach. However, the standard for approving wildlife mitigation projects
would change. Rather than include all wildlife projects from the mitigation proposals (e.g.,
those that meet the Act's standards), the Council could limit or prioritize the program. It
might address threatened or endangered species and their habitats or projects that address
regional species of concern. Wildlife projects meeting these criteria either could be selected
from the existing and future mitigation proposals or regionally prioritized by an advisory
committee to focus mitigation in areas of greatest biological need.

issues

Should the Council wish to pursue this alternative, the following concerns may need further
discussion.

I of effbrt Obviously, choosing the right funding levei of effort will be difficult and would
need to be discussed further with the agencies, tribes, utility interests, Bonneville and other
affected parties. The dollar amount would need to tal<e into account that the Northwest Power Act
directed the Council to develop a program for both fish and wildlife; that limited funding has been
directed to wildlife mitigation thus far; and that, generally, the cost of wildlife mitigation is relatively
high.

This paper does not propose a specific level of effort. There are several alternatives that
might be used. One approach is to calculate the overall level by determining an appropriate dollar
amount per acre inundated. Hungry Horse and Libby dams might be used as an example.
Bonneville and the Montana Department of Fish, Wildlife and Parks are negotiating a settlement

-21-

using a trust fund to implement wildlife mitigation at Hungry Horse and Libby dams. Using this
approach, the cost to ratepayers may be substantially less than a conventional year-by-year
funding scheme.

Council staff estimated the cost for wildlife mitigation at Hungry Horse and Libby dams to be
approximately $16 to $20 million. These were initial 10-year costs plus annual operation and
maintenance. After adjusting the acreage figures to account for the hydropower allocation, the
mitigation cost per acre is between $400 and $500 per acre. While these are estimated numbers,
this may be an approach to use for the pending mitigation proposals.

Another approach would be to target Bonneville's wildlife budget at a specified level, say
approximately $6.5 million per year, (This is the outyear funding level estimated by Bonneville,
Council staff and the Columbia Basin Fish and Wildlife Authority in outyear budget discussions that
were conducted in 1987.) Other approaches include setting a percentage of fish and wildlife
funding that would be available for wildlife or simply negotiating the wildlife funding level among all
interested parties.

Um of trust funds. Selection of a funding level also might be considered with the use of a
trust fund(s) to implement the wildlife programs. The trust fund concept would have to be
discussed with Bonneville, but on the surface it appears to offer substantial savings to the
ratepayer. The Council may want to consider a regional trust fund or provide trust funds at the
state or state/tribal level. The Council encourages comment on any other funding mechanisms
that might appropriately be used for wildlife mitigation funding.

Alternative 5. Develop guiding policies for wildlife and amend tfiem Into ths flsft and wildlife
program.

Approach

As Stated earlier in this paper, some have argued that the wildlife program (Section 1000)
lacks specific policy direction due to the absence of program goals and objectives, i.e., goals
similar to the Council's interim goal of doubling the salmon and steelhead runs. While it could be
difficult to articulate a similar goal for wildlife, it may be appropriate to reevaluate the current wildlife
program and make some policy decisions on some of the issues that have consistently arisen
since inception of the wildlife program.

Should the Council decide it wants to develop guiding policies for the wildlife program, a
separate issue paper describing policy options in detail might be developed. Briefly, the issue
paper could analyze the following areas of concern.

Establish framework, goals and objectives. To ensure logical and consistent
implementation of target goals and objectives, the Council may wish to consider providing a
framework for making wildlife mitigation plan decisions and for implementing wildlife mitigation
measures. The purpose of the framework would be to provide a systemwide perspective on the
relationship among individual wildlife program measures. The framework could include the target
goals; policies to guide achievement of those goals; a process to plan future efforts; and a
monitoring and evaluation process to measure progress toward the goals and to provide
assurance that corrective actions coukj be taken if the goals were not being achieved.

-22-

Establish interim target goals. The Council could restructure the existing wildlife program
by establishing a specific program goal with regional wildlife mitigation objectives (program
measures) outlined in the Rve-year Action Plan. The goal could be articulated in biological terms,
e.g., the wildlife program could be limited to threatened or endangered wildlife populations and
their habitat or regional species of concern. Alternatively, wildlife projects might be prioritized
geographically, with priority given to projects in those areas that lack salmon and steelhead
rehabilitation opportunities. The Council could conceivably factor in other considerations such as
the number of resident fish substitution projects or other program measures being undertaken in a
given location. Another option would be for the Council to specify the program level of effort, e.g.,
defining the level of dollars that will be allocated to the wildlife program over a given period of time
(similar to the previous alternative). In either case, the mitigation proposals that have been
developed by the agencies and tribes could provide the basis for selecting specific objectives (high
priority program measures and action items) to meet the program goal(s).

Land acquisition. The Council may want to review the present criteria for land acquisition
(1003(d)(l)-(2)) and make changes. In particular, the Council may want to prioritize the type of
protection and enhancement actions it would emphasize during implementation of the program.
As an example, the Council may want to stress wildlife enhancement projects on public or tribal
lands over fee title acquisition of private lands.

Privata utility projects. Currently, the issue of wildlife mitigation planning and
implementation at nonfederal hydroelectric projects remains unclear in the program. The current
fish and wildlife program calls for mitigation planning activities (1003(b) planning process) to take
place at most of the nonfederal projects in the basin. However, with the exception of a few cases,
Bonneville and the private utility operators have not carried out mitigation planning and
implementation activities at non-federal dams. The Council may want to discuss this issue with the
interested parties and make clear its policy direction in the program. Additionally, in the case of
many non-federal dams, FERC has required, as a condition of the project license, that certain types
of mitigation be carried out by the project operator to offset damage to wildlife caused by
construction and operation of the project. The Council is interested in comment on the extent of
mitigation at non-federal projects and whether it is viewed as being adequate.

Hydropower allocation. As discussed earlier, this issue addresses who should pay for
mitigation. To date, several methods for allocating responsibility for funding wildlife mitigation have
been discussed. The Council may want to make a policy decision to guide future mitigation
proposals.

ISSUM

As noted earlier, if the Council decides to pursue the development of a wildlife policy for the
program, another issue paper may be written to further explore the issues. This could delay action
on the pending mitigation proposals. The Council also may want to examine the pending
mitigation proposals and select a few of the highest priority projects for earlier, limited

207 With regard to future proposals for non-federal hydroelectric projects, the Council does not
anticipate the need for Bonneville-funded mitigation planning but rather would expect the
conditions specified in program Section 1103(a)(2) to be incorporated into the Federal
Energy Regulatory Commission (FERC) licenses for these projects.

-23-

implementation while a policy is being developed. In addition, if the Council selects this alternative,
^ it might want Bonneville to delay further planning (see Attachment 1) until the Council has

established the policy that will guide the future wildlife program.

Attachments

mvax::larTy:[fw]montg wildlif* issu« papar

i)

»

-24-

r

r

c

Attachtnant 1

STATUS OF WILDLIFE MITIQATION PLANNING
(FEDERAL HYDROELECTRIC FACILITIES)

Hydro

Facility

Hungry
Horse

Ubby

Qrand
Coulee

Palisades

Status
Report

Completed

Completed

Completed

Completed

Willamette Completed

Basin

Anderson Ranch/ Completed
Black Canyon

Bonneville

Completed

Loss

Mitigation

Additional

Statement

Plan

Comments

Completed

Completed

Mitigation

. plan amended

into program

in 1987.

Completed

Completed

Mitigation

plan amended

into program

in 1987.

Completed

Completed

Mitigation
proposal sub-
mitted to Council
in 1986.

Completed

Completed

Mitigation
proposal sub-
mitted to Council
in 1987.

Completed

Completed

Mitigation

proposal for 8

hydro facilities

submitted to

Council in 1967.

Completed

Completed

Mitigation

proposal sut>-

mitted to Council

in 1987.

Started 1987

Scheduled

USFWS lead

forFY89

agency.

Boise Diversion Completed

Completed

The loss statement indicated only 60 acres of wildlife habitat were lost because of the project.
Development of a mitigation plan was not pursued for that reason.

Hydro
Fadlity

Status
Report

Loss
Statement

Mitigation
Plan

Additional
Comments

DworshaK

Completed

Started
June 1987

Proposed
forFY88

...

Albeni Falls

Completed

Started
September 1987

Completed
Fall 1988

One contract
for loss statement
& mitigation plan.

Minidoka

Completed

Proposed
forFYBS

Proposed
forFY89

...

Chief Joseph

Completed

Proposed
forFY88

Proposed
forFYBQ

One contract
for loss statement
& mitigation plan.

Lower Snake
Projects

Completed

Started

«

Proposed
forFYSQ

Loss Statement
being funded by
Corps under F/W
Coordination Act

McNary/John
Day/The Dalles

Completed

Proposed
forFYSa

Proposed
forFY90

...

((

This mitigation plan has been completed and is currently being printed by Bonnevitie.

(

Attachment 2

pGrand Coulee Project and Vicinity

CAM*0*

UNITED STATES

Washington

COLVILLE INDIAN RESERVATION

• Huntaa

Grand

Coulee^

Dam

SPOKANE INDIAN RESERVATION

Willamette River Basin
Federal Hydroelectric Proj

Portland^0

Eugene

DmtroJt/BI^ Cliff

Attachment 2

Palisades Project Area

Sand Cr««k|

^ ST. ANTHONY

Mud Li

Markat Laka*

i/Hanry'* Fork Snaka Rivar

\

South Fork Snaka Rivar
) ^^wiliow Craak fl

V PaNaadaa

Snaka Rivar)

/OAMO FALLS ^

(^— '•s.^Ja* Craak

C SWAN VALLEY /"
X /

'BLACKFi

Craak

WILSON"

Palisades
Reservoir

ALPME

rOraya Laka

Salt Rivar

Blackfoot Raaarvoir

Oroya RivarV

-3-

(

Black Canyon Reservoir and vicinity

■5-

I

Attachment 3

SUMMARY OF WILOUFE IMPACTS

Project
Grand Coulee

Acres Inundated
70,000

Habitat Units (HU) Lost

111,171 HUs for 8 indicator
species or indicator habitat plus
74 Canada Goose nest sites

Willamette Basin
Hills Creek
Cougar
Detroit
Big Cliff
Green Peter
Foster

Lookout Point
Dexter

2,710
1,280
3,580
141
3,605
1,195
4,255
1,025

64,000 HUs for 12 target species

Palisades

Anderson Ranch

16,150
4,740

37,068 HUs for 9 target species

9,619 HUs for 7 target species

Black Canyon

1.100

2,238 HUs for 8 target species