BPA’s Pisces Wildlife Crediting Ledger Bonneville Power Administration February 17, 2010

Overview Basis of the Pisces crediting report. What the crediting report shows. Recent updates and changes. What the crediting report doesn’t show. Thoughts on next steps to fill in the ledger.

Basis of the Pisces Crediting Report Based on program amendments depicting wildlife losses and gains due to FCRPS dam construction and inundation –HUs come from HEP reports and minimum irreducible estimates

What the Ledger Shows Completed mitigation to date –Excludes Libby, Hungry Horse, and Dworshak Includes HUs for both habitat protection (acquisition) and enhancements Recent changes in percent of completed mitigation resulted from adding new HEPs

Why BPA Takes Protection Credit NW Power Act: BPA shall “protect” wildlife habitat Program: “It is clear that Bonneville should receive some credit for protection of existing habitat.” 1992 Council letter to BPA: BPA and managers should reach “a mutually agreeable resolution of the crediting issue” and that could take place “as part of negotiations leading to agreements.” Crediting agreements: “Full credit means one HU credit for each HU acquired.”

What the Ledger Doesn’t Yet Show Baseline HUs based on HEPs for all acquisitions Updated HU values for habitat enhancements Stacking and habitat substitution issues corrected through follow-up surveys Pre-Act mitigation HUs from fish habitat mitigation projects –Acquisitions and Riparian Fencing Construction and inundation HU gains Doesn’t resolve over-mitigation

Ongoing Effort to Update HEPs Use baseline and updated HEPs to document actual HU values Ongoing mitigation status reports offer the opportunity to stack mitigation credit consistent with loss assessments –Equal compensation/equal tradeoff model offers the most principled way to resolve stacking problems Replace minimum irreducible HUs with actual baseline HEPs

Pre-Act Mitigation Prior to 1980 the COE, BOR, and USFWS received appropriations to mitigate FCRPS dams. Loss assessments reflect impacts from all project purposes through 2000 Programs: Pre-Act mitigation may be satisfactory full mitigation in some circumstances. 1992: Customers and resource managers all agree “that some credit is due” for pre-Act mitigation. 1994: Council calls on region to “determine the amount of credit to be given for existing wildlife mitigation….”

Pre-Act Mitigation Examples LSRCP: Council recognizes l:l credit for Corps project lands protected for wildlife and with adequate O&M. LSRCP loss assessments amended into the program showing only remaining unmitigated HUs. USF&WS 1991 Geiger report: recognizes pre- Act mitigation for lower 4 mainstem dams. Program accepted principle of “pre-act mitigation.” Only questions were “when and how” to credit.

Credit for Fish Habitat Projects Program directs resource managers and BPA to find way to credit wildlife ledger with HUs from fish mitigation projects. Beginning in 2000, the Council “revised its approach, treating a given habitat as an ecosystem that includes both fish and wildlife.” Managers propose, Council recommends, and BPA funds fish habitat projects that mitigate wildlife.

Fish Habitat Credit Examples Wagner Ranch/Pine Creek MOA: “BPA shall receive full credit for all HUs achieved through protection or improvement activities.” Red River-Little Ponderosa Ranch MOA: BPA received wildlife credit in proportion to its funding.

Construction and Inundation Gains Programs: “[C]onsider the net effects on wildlife associated with hydroelectric development.” Out of place/out of kind mitigation prevalent throughout program An HU is an HU –Program began with in-kind approach but evolved into equal trade off –HEP’s equal trade off compensation model offers consistent way to address construction gains

Over-Mitigation Mitigation agreements assure BPA “full credit” Council, managers, and BPA agreed to pursue out of place/out of kind mitigation Equal trade off compensation model supports an HU for an HU Not reassigning over-mitigated HUs understates completed mitigation

Completing the Ledger Next steps to fill in the ledger –Continue follow-up HEPs Use species appropriate to mitigation sites Use matrix with number of species and habitats as in loss assessments –Employ stacking consistent with loss assessments Northern and Southern Idaho South central Washington –Willamette Resolve inability to credit like other areas in the basin –Prioritize HEPs on fish habitat projects –Quantify pre-Act mitigation –Tradeoff construction and inundation gains –Tradeoff over-mitigation