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Subbasin Planning: What Happens After the May 28 Deadline? by Barry Espenson Columbia Basin Bulletin - January 16, 2004

With efforts across the Columbia River basin steamrolling toward a May 28 subbasin plan submittal deadline, participants at the grass-roots level are beginning to wonder about the hereafter -- whether they'll have a role in any customizing of those plans and in the implementation of the plans' fish and wildlife management strategies.

Likewise, NOAA Fisheries says it would like to see a "credible fix-it loop" established as the more than 50 plans move from draft to final to assure they meet Endangered Species Act-related needs. A recent NOAA findings letter judging the implementation progress of that agency's 2000 Federal Columbia River Power System biological opinion also "recommends the support and development of a coherent implementation framework for subbasin plans."

Right now, no such accommodations exist in the nearly 2-year-old process being carried out through the Northwest Power and Conservation Council's fish and wildlife program at a cost of $15.2 million. The 90 or so contracts let at the regional, state and local level expire May 28 -- the deadline for subbasin plan submittals.

The plans will, officially, be considered as recommended amendments to the fish and wildlife program, created by the Council under Northwest Power Act mandates. The program is funded, currently at $139 million annually, by the Bonneville Power Administration as mitigation for impacts to fish and wildlife from construction and operation of the federal hydrosystem. As a federal "action agency," the federal power marketing entity also has an obligation to further the goals of the NOAA BiOp, which says hydrosystem operations threaten the survival of eight listed salmon and steelhead species.

The NPCC process now calls for technical review of the subbasin plans between June 1 and Aug. 12 by its Independent Scientific Review Panel. A schedule approved by the Council sets the public comment period from June 1 through Sept. 30. It is envisioned that the Council and staff will put together draft amendments after reviewing comments, offer the drafts for comment and then put together final versions for adoption in December or January, according to NPCC senior counsel John Ogan.

Any reaction to the ISRP reviews by the local groups that shaped the plans would have to come during that Aug. 12 to Sept. 30 window, or during public comment on the draft. As the process now exists, there is no formal structure, or money, for those local groups as a body to respond to the ISRP's critique.

"We don't have resources for them to respond as a group to the ISRP," Ogan said of a desire expressed by statewide planning coordinators to maintain some of the infrastructure developed during the process. Participation in local planning groups has involved state, federal and tribal governments, local managers, landowners, local governments, and other stakeholders.

Of the $15.2 million allocated for the process, $13.9 million is already earmarked. And there is no guarantee that any unallocated balance at the end of the contract period could be redirected to fund the maintenance of subbasin planning infrastructure during the comment period or the plan implementation phase that will follow.

State coordinators are in accord about the need to involve those local planners as their plans are recast in response to the ISRP and other comments such as those that will likely emerge from the federal BiOp process.

"How we structure that and how we fund that is where we are all over the map," Jim Owens, Level II subbasin planning coordinator for Oregon. "If the Clearwater is any example at all, it takes a lot of time and money to meet the ISRP's expectations." An early subbasin plan for Idaho's Clearwater River subbasin was panned in many respects by the ISRP, forcing revisions that took more than half a year to complete.

A meeting has been scheduled Jan. 28 for Council staff and state coordinators to discuss post-May 28 tasks, including what work will be necessary to carry the plans forward through review and adoption. According to a Council memo, that group will also develop a proposed funding allocation for those tasks.

A problem is that the Council has very "limited budget resources," Ogan said. The Council is currently struggling to keep planned expenditures at a level that will allow the program to maintain no more than a $139 million annual average as required by BPA. Ogan and the NPCC's fish and wildlife director, Doug Marker, indicated during a Tuesday meeting of the Regional Coordinating Group that any post-May 28 subbasin planning funding requests would likely have to compete with already planned projects for the limited available funding. The RCG is a policy-level committee with of state, federal and tribal representation that gathers to try solving subbasin planning dilemmas.

"It's a matter of equity… does subbasin planning have a priority over other needs?" Marker asked rhetorically. The Council would have to make any decision about rededication of funds.

"I don't want to say it is automatic," Marker said. "If there is a fix it loop, it does not have funding" to this point.

Council Chair Judi Danielson told the RCG that she thought the Council would be reluctant to fund "a lot of administration over ground work."

Washington's subbasin planning coordinator, Tony Grover, said the local planning groups are concerned.

"They want to be involved. They are critical people to be in the fix-it loop," Grover told the RCG. He presented a statement from the Lower Columbia/Willamette ESA Salmon Recovery executive committee that asks that the infrastructure created by the subbasin process be maintained. That panel represents an area that includes 11 subbasins.

"The credibility of the entire process to date risks harm is the infrastructure were to merely 'end' on May 28 or if further involvement were not invited," according to the statement. That committee said that the "subbasin planning groups and planners are those best suited for fixing plans after ISRP review and public comment because of their intimate involvement in the creation of the plans." Grover said he had heard the same message from 11 other subbasins in his state that are home to salmon and steelhead.

Ogan pointed out that "NOAA added a new twist" to the subbasin planning infrastructure issue by suggesting in its findings letter that infrastructure be maintained both to fix technical problems noted in the subbasin plan submittals and help implement the measures called for in the plans.

"Subbasin planners must be afforded a realistic and credible opportunity to respond to technical comments and improve their plans between draft and final plans," the findings letter to the action agencies says. "This would also allow inclusion and integration of input from Technical Recovery Team projects. NOAA Fisheries also recommends the support and development of a coherent implementation framework for subbasin plans."

The TRTs were created by NOAA to develop recovery plans for the listed anadromous fish species. The federal agency has said it intends to use the subbasin plans as it develops those ESU-side (sometimes involving numerous subbasins) recovery plans. The subbasin plans are also intended to help the Council set priorities for spending within its program.

"It would be a tragedy in my mind if we dropped the support for those local efforts too early," Rob Walton, NOAA assistant regional administrator and head of its salmon recovery division. He said that potentially the ISRP or other commenters could identify flawed methodology or data within a plan that needs to be corrected and there needs to be a process for doing it.

"Somehow it has got to be fixed. We just can't say -- tough," Walton said, and expect to make the corrections later in what are described ast iterative, adaptive management plans. He did not, however, offer solutions about how that infrastructure would be funded.

Owens asked if the findings letter suggests a parallel fix-it process to correct deficiencies from an ESA perspective.

Walton insisted that was not NOAA's desire, "but if someone needs help, and the TRTs have the time, then go for it."

Likewise BPA's Lorri Bodi said her agency would act within the Council's processes.

"I don't think we view ourselves as in the driver's seat. We're not going to act unilaterally," she said, to assure the process answers BiOp needs. "Having said that, we have to deliver down the road… good projects that meet ESA objectives."

Related Sites:
NPCC: www.nwcouncil.org/
BPA: www.bpa.gov/indexmain.shtml