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One-Year BiOp Implementation Plan Due Mid-November

by Mike O'Bryant
Columbia Basin Bulletin - November 7, 2003

Federal representatives said at a multi-agency Implementation Team meeting Thursday that they would complete the fiscal year 2004 one-year Implementation Plan for salmon and steelhead recovery in mid-November, but that the plan will contain uncertainties, leaving it open to future changes.

The action agencies, consisting of the U.S. Army Corps of Engineers, the Bureau of Reclamation and the Bonneville Power Administration, are required by the NOAA Fisheries 2000 biological opinion to complete every year both a one and five year implementation plan.

The plan is to describe the actions over the year that are designed to support a range of actions called for in the BiOp's reasonable and prudent alternative.

"Much of what's in this year's plan is similar to other years," said Jim Athearn of the Corps. "Still there are a lot of uncertainties that will be addressed and dealt with later, although there will be no surprises to people who have been involved in this project."

One uncertainty is the BiOp remand by Judge James Redden in May. He said the BiOp relies improperly on actions that are not "reasonably certain to occur" and sent the BiOp back for review, which according to NOAA Fisheries will be completed in May 2004. The new BiOp will likely require changes to operations in the one-year Implementation Plan.

The second uncertainty is the Northwest Power and Conservation Council's recommendations in its so-called Mainstem Amendments.

While BPA's Suzanne Cooper said one change this year in the plan is an attempt to integrate the Northwest Power and Conservation Council's Mainstem Amendments, it does not include at this point operations proposed by the state of Montana that would alter summer spill regimes.

Cooper said the latest one-year plan builds on what the action agencies have learned after three years of implementing the 2000 BiOp and that the newest plan is different than previous years. She said the agencies are moving more to Evolutionary Significant Unit reporting and away from the programmatic RPA by RPA reporting of past plans. That is more suitable to performance-based efforts, she said.

"Implementation planning is a means by which changes are allowed within the flexibility of the BiOp," Cooper said. "Some performance standards are defined better than others. We learn and circle back around to make changes."

The action agencies had notified a wide list of potentially interested parties in June that the 2003-2007 implementation plan would serve as the draft for its 2004-2008 plan. Athearn said they received comments only from the state of Montana and from the Council. The final one-year plan will be posted without further review on the federal caucus web site,, Nov. 17.

"In essence, it's final, but it's also dynamic," Cooper said. "We know things are going on and we will be making adjustments. When we get the findings letter (from NOAA Fisheries) for the check-in (sent last month to the fisheries agency), for example, that could also change things."

BPA's Ken Barnhardt, who is in charge of putting together the five-year Implementation Plan, said it is behind schedule.

Related Sites:
Bonneville Power Administration:
U.S. Army Corps of Engineers:

Mike O'Bryant
One-Year BiOp Implementation Plan Due Mid-November
Columbia Basin Bulletin, November 7, 2003

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