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The draft BO assumes that habitat restoration "is the primary focus for land <br />management activities." [dB0 pp. 317, 193]. <br />Under the June 14-15 Agreement, preferred segments for land management <br />include those with habitat that can be most reasonably improved, those with <br />existing habitat that is not already being protected and is likely to be lost, and <br />those that do not currently have any protected habitat. The draft BO <br />assumptions are more restrictive than the negotiated criteria under the Land <br />Management Plan. <br />Instead of hardwiring the "restoration" assumption, the BO should recognize <br />that restoration focus has no benefit if it means passing up protection of land <br />that is suitable habitat now but likely will be lost if not protected - it is just a <br />higher cost means of providing the same amount of habitat. No land can be <br />acquired by the Program without the vote of the FWS. Neither the states nor <br />any of the other participants have an interest in spending money in ways that <br />provide no benefit. The BO should assume that land acquisitions will be <br />beneficial either by increasing available habitat or preventing habitat loss. <br />Whether they are "restoration" or "protection" is irrelevant. <br />4. EA mana eg ment. <br />The draft BO assumes that activities controlled by the Program, Central or <br />NPPD will not interfere with the management of the EA. Specifically <br />identified activities that may not interfere with the EA are IMRP activities of <br />pulse releases and inspections, maintenance and repair of hydro facilities not <br />necessary for public safety or structural integrity. [dB0 p. 194, item h]. <br />Nothing in the Program supports this assumption, nor have revisions to secure <br />such a change been suggested in negotiations. This is clearly an example of <br />using draft BO assumptions to impose terms both within and outside the scope <br />of the Program in the guise of "defining" Program details. To the extent this <br />assumption refers to operations of Central and NPPD, it is inconsistent with <br />the settlement of their FERC proceeding and should be removed from the BO. <br />To the extent this assumption refers to the activities of the IMRP, it is <br />disturbing to the states that FWS views the IMRP to be in potential conflict <br />with the EA manager's role. The IMRP is (or will be) a GC document, <br />expressly approved by the FWS representative on the GC. It is a matter of <br />deep concern to the states that the EA manager could have the discretion to <br />interfere with implementation of the GC's IMRP; EA releases and the IMRP <br />investigations must be coordinated to achieve useful results for adaptive <br />management decisions. <br />B. Program Adaptive Management. <br />999999nn(A9756i c Z ?7 <br />. /