BPA’s Pisces Wildlife Crediting Ledger

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

2. 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.

3. 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

4. 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

5. Why BPA Takes Protection Credit • NW Power Act: BPA shall “protect” wildlife habitat. • 1995 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.”

6. 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

7. 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

8. 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. • 1982 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….”

9. 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.

10. 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.

11. 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.

12. Construction and Inundation Gains • 1982-2009 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

13. 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

15. 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