From: Sent: To: CC: Subject: Attachments

From: Puckett, Kathryn J
Sent: Saturday, July 25, 2009 4:58 PM

To: 'Ritchie.Graves@noaa.gov'; MECHAM, DUANE; 'Howell, Coby (USAOR)'
Cc: Bodi,Lorri - A-SEATTLE; rock.d.peters@usace.army.mil; Chris.Toole@noaa.gov; 'Lynne
Krasnow'
Subject: RE: Revised Contingency Plan documents
Attachments: Contingencies Draft Document 072409_Master with RJG edits3kp.docx
Attorney client privilege/preliminary work product

This is a vast improvement ‐ great job Ritchie. I think we still have some areas that I'm
unsure how to handle ‐ marked them in the text. I'll defer to Rock and Lorri if our comments
conflict (for now). I don't have comments on the charts at this time. Thanks again.

‐‐‐‐‐Original Message‐‐‐‐‐
From: Ritchie.Graves@noaa.gov [mailto:Ritchie.Graves@noaa.gov]
Sent: Saturday, July 25, 2009 3:32 PM
To: Ritchie.Graves@noaa.gov
Cc: Puckett, Kathryn J; Bodi,Lorri ‐ A‐SEATTLE; rock.d.peters@usace.army.mil;
Chris.Toole@noaa.gov; 'Lynne Krasnow'
Subject: Revised Contingency Plan documents

Privileged and Confidential Pre‐Decisional Documents ‐ Do Not Distribute

Please find attached my efforts for the day. Because of the extensive nature of the rewrite,
I took out the track changes. I also found it necessary to make slight modifications of both
the BOR general and NOAA specific flow charts.

Call if you have any questions. I'll have my work phone nearby ‐ 503‐
523‐8774
My home number is 503‐493‐8148.
I'll try to address the comments / edits tomorrow.

Best wishes,
Ritchie
BR014
Privileged and Confidential – PREPARED FOR LITIGATION PURPOSES – Do Not Distribute
DRAFT dated July 23, 2009 1:30 PM
Contingency Planning and RM&E

Note: a number of these options are provided for consideration by the regional executives and
their legal counsel. NOAA and Action Agency staff have not determined whether they all should
be included in the document filed with the Court on August 14th.
1. Introduction
During the remand collaboration process, a contingency plan framework was developed,
triggering work on additional actions if there is a significant decline in listed species. The
framework incorporated into the FCRPS BiOp includes biological triggers at the ESU level for
implementing contingencies and an “All H Diagnosis” to determine appropriate contingency
actions. It is supported by a research and monitoring program, a transparent process for progress
reporting, and full involvement of the sovereigns’ Regional Implementation Oversight Group
(RIOG). This contingency plan was built upon the adaptive management platform that is
described in the 2007 FCRPS BA (Adaptive Management; pp. 2-1 through 2-16) and is
referenced in the RPA for the 2008 FCRPS Biological Opinion (actions 1-3 and 50-73). The
adaptive management process in the FCRPS BA defines what steps the Action Agencies will
take if performance standards are not met [Attachments 1 and 2].
The new administration thoroughly considered this framework in the context of the BiOp, the
available science on which it was based, the issues raised by the litigants and independent
scientists, and the Court’s letter of May 18, 2009. Its review highlighted a number of important
questions regarding the implementation of contingencies, centered on precautionary
implementation and rapid response to indications of declining fish status. What conditions are
we monitoring? How rapidly would the Action Agencies and NOAA be able to respond to a
precipitous decline in a listed species? What if climate change leads to extreme swings in habitat
and fish status? Are available mitigation actions that might have immediate fish survival
benefits -- such as more aggressive control of predators or invasive species, harvest reductions,
and re-establishment of extirpated populations -- getting sufficient attention and could they be
quickly implemented? The administration leadership has concluded that implementation of the
contingency framework in the BiOp would benefit from more structure and detail, so that these
questions can be more fully answered.
In response, the Action Agencies, with the full support of NOAA and the administration
leadership, are proposing the following additional structure and details for the BiOp contingency
framework. Through adaptive management, we are clarifying and committing to the Court and
to the region how we will plan for and implement contingencies for all interior Columbia Basin
ESUs/DPSs within the BiOp framework (see Figure X, General FCRPS/BA Adaptive
Management Framework). Including the newly proposed modifications, the
adaptive management framework would generally consist of:
• Continuing and/or enhancing Research, Monitoring, and Evaluation (RM&E) programs;

• Continuing BA/BiOp performance standard monitoring (Hydro, Habitat, Hatchery, and
Predation) and implementating additional actions, if necessary, to achieve these standards;
Formatted: Font: 9 pt
Privileged and Confidential—Do Not Disclose New actions not currently funded. Some action may be outside
agency authorities. 1
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• Continuing the BA/BiOp contingency process (2013 and 2016 Comprehensive Reports and
All-H Diagnostics);
• Developing Rapid Response Plans (for use in the event that 2013 and 2016 Comprehensive
Analysis, Early Warning, or Unexpected Decline triggers are tripped;
• Developing longer term Contingency Plans (for use in the event that Rapid Response actions
prove insufficient); andAdding Early Warning and Unexpected Decline triggers (designed to
enhance the BiOps potential to respond to unexpected declines in fish numbers or natural
disasters)
•
The addition of the Early Warning and Unexpected Decline triggers, will ensure precautionary
implementation of the BiOp and increase its responsiveness to emerging climate change
information. Most importantly, together with the Rapid Response and Contingency Plans, they
will ensure that there is a rapid response by the Federal agencies collectively in the event of a
precipitous fish decline and/or extreme habitat disturbance.
Figure Y (Contingency Plan Flow Chart) displays the expanded Diagnostic and Contingency
Planning process. The following sections provide further detail regarding each element
(numbered boxed and yes/no decision points) in the Contingency Plan Flow Chart.
2. Research, Monitoring and Evaluation

This section proposed by NOAA. Scope and funding are still being discussed.
THIS SECTION WOULD BE THE NEW SECTION 2
Box 1. Research, Monitoring, and Evaluation (RM&E) is an essential component of the adaptive
management framework in the Biological Opinion (and proposed contingency planning
enhancements). RM&E is necessary for developing (and updating) both the Rapid Response
Plans (Box 2) and Long Term Contingency Plans (Box 3) as well as for evaluating ongoing
productivity, biological, and environmental metrics (Box 4) throughout the 10-year time frame of
the BiOp. RM&E is also important as it will enhance our scientific understanding for decision-
making beyond the 10-year time frame of the BiOp.
The existing BiOp already includes a large RM&E commitment from the Action Agencies,
(including status monitoring, effectiveness monitoring such as Intensively Monitored Watersheds
(IMWs), and critical uncertainties research). NOAA also has a major RM&E program linked to
the ESA. NOAA and the Action Agencies are jointly reviewing existing federal RM&E efforts
to identify and address critical gaps in, or potential enhancements to, these programs, if any,
regarding:
• Faster, more efficient reporting of annual adult returns (at population and MGP level)
• Expanded habitat status and trend monitoring (e.g., flow, temperature, sediment, channel
complexity, riparian area/composition, floodplain connectivity, habitat access, land use
conversion, etc.)
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• Relationships between habitat quality and fish response (e.g., stream/watershed- and
population-scale estimates of juvenile outmigrants per adult spawner; size and condition of
juveniles; etc.)
• Effects of non-native predator/competitor species in mainstem reaches and tributaries:
- Develop quantitative descriptions of interactions with salmon and steelhead (productivity,
smolt size and condition, food web, etc.)
- Expand capabilities of COMPASS model to incorporate predation impacts
- Evaluate impacts of non-native species and develop and test potential control measures
• Effects of interactions between species and populations
• Effects of hydrology, avian predation, fish predation, etc. on mainstem survival (expand the
capabilities of the COMPASS model)
• Greater coverage of geographic and hydrologic systems in the Columbia basin in the
Intensively Monitored Watersheds program
• Greater coverage of the stream flow/temperature gauge network
• Locations and sizes of cold water refugia (shallow groundwater, springs, and seeps) and
interactions with surface streams
• Research to determine the feasibility, risks, and benefits of modifying the magnitude or
timing of releases from individual interior Columbia hatchery programs as a function of
ocean conditions.
The Action Agencies and NOAA will work together to jointly fund and address these gaps over
time. Are funding and resources really available (even over time)? Suggest identifying that we
don’t have current funding for this if we don’t.
2.1 Climate Change RM&E
The FCRPS BiOp includes a commitment from the Action Agencies to report annually in their
progress reports on climate change research. The Federal agencies would expand and strengthen
this approach through joint NOAA and Action Agency review of climate change information,
with reporting of this information to the RIOG and the public in the annual and cumulative
progress reports.
• RPA Action 2 requires inclusion of new, pertinent climate change or research in the
Action Agencies’ Annual Progress Reports. To ensure that this will be accomplished,
each year, by June 1, NOAA Fisheries will provide to the Action Agencies a survey of
any new climate change studies, scientific papers or modeling work relevant to BiOp
implementation and fish status (has NWFSC agreed to do this?).
• RPA Actions 35 and 37 require that new climate change information be used to guide
tributary and estuary habitat project selection and prioritization and other aspects of
adaptive management. The NOAA Fisheries review described above will also be used
for this purpose.
• RPA Action 7 requires that new climate change information be used to update forecasting
and modeling of the hydrology and operations of the FCRPS. The Action Agencies have
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made significant progress on this task and are incorporating climate change modeling
from the University of Washington’s Climate Change Impacts Group in developing the
data sets that will be used for the agencies’ longer term water resources planning.
• As required by RPA Action 1, management changes resulting from new climate change
information will be documented in the Action Agencies’ BiOp Implementation Plans,
which are expected to cover three year periods of BiOp implementation. However, the
Action Agencies commit to making adaptive management changes within those three
year planning periods if new information suggests a change would be beneficial.
In addition to the requirements of the RPA, the Federal agencies collectively will coordinate an
inventory of existing, ongoing and planned climate change studies and develop a strategy to “fill
in” information missing from other existing or planned studies. This might include, by way of
illustration:
• Improved system wide coordination and modeling of existing information from

monitoring of fish status and habitat conditions (flow, temperature, refugia). It would be
important to ensure that target areas and indicators are sensitive to climate change effects,
looking at both the ESU/watershed level and basin level.
• Better linkage between the Action Agency and NOAA Intensively Monitored Watersheds
and collection of tributary climate change information, including flow and temperature
monitoring and fish-in/fish-out information (i.e., censusing adult spawners and
subsequent juvenile migrants).
• Improved monitoring of estuary and marine habitat conditions that may be affected by
climate change and their effects on fish response.
This review will be completed by when? and will be used to prioritize federal agencies’ climate
change research funding.
3. Development of Rapid Response and Long-Term Contingency Plans

3.1 Rapid Response Plans (Immediate to 1-year)
Box 2. Rapid Response Plans for each interior Columbia Basin species will be developed by the
Action Agencies, NOAA and FWS in consultation with the RIOG by 2011. The Rapid Response
Plans would consist of a "menu" of potential actions and a decision-making process for selecting
appropriate Rapid Response Actions (for the ESU/DPS/population in question) and for
implementing these actions within 12 months. Most if not all actions included in the rapid
response plans will be temporary in nature.
These plans will identify a menu of mitigation actions that would immediately improve fish
survival and for which the needed regulatory process is already largely in place. In other words,
Rapid Response Plans will consist of menu’s of actions that could be implemented relatively
quickly (within 1 year) and provide immediate survival benefits, if the evaluations of
productivity, biological, and environmental metrics (Box 4) indicates that triggers have been met
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(Boxes 5 - 8). The Rapid Response Plans would be held at the ready, and implemented, if
necessary (Box 9).
Deleted: The Rapid Response Plans would be

consist of a "menu" of potential actions and a
The following are examples (by categories) of actions that could be included in the Rapid decision-making process for selecting appropriate
Response Plans: Rapid Response Actions (for the
ESU/DPS/population in question) and for
implementing these actions within 12 months.
• Predator Control: The Action Agencies, in combination with the U.S. Fish and Most if not all actions included in the rapid
response plans will be temporary in nature.¶
Wildlife Service and the States, could implement more aggressive, targeted efforts to
control and eradicate predatory fish, avian predators, and invasive species to increase
survival of listed fish. The Rapid Response Plan would describe the specific steps
and milestones needed to define and implement any such reductions within six to 12
months of the trigger.
• Harvest: NOAA Fisheries could start the process to reduce harvest for several
species by considering whether to reinitiate tributary harvest biological opinions and
revising associated Section 10 and 4(d) permits; considering whether to reinitiate the
PFMC biological opinion to reduce SR fall Chinook ocean harvest; negotiating the
Pacific Salmon Treaty to seek further reductions in Canadian fisheries; and initiating
negotiations with US v. Oregon parties (under Court supervision) to seek emergency
reductions in the harvest rates below the lowest rates provided for in the current long-
term agreement. The Rapid Response Plan would describe the specific steps and
milestones needed to define and implement any such reductions within six to 12
months of the trigger.
• Hydro Actions: The Action Agencies could implement, within the adaptive
management framework of the BiOp, additional hydrosystem actions that would
increase the survival of the ESU/DPS. This would be based on the most recent data
available and might include targeted spill and additional use of fish transportation
based on recent survival data. The Rapid Response Plan would describe the specific
steps and milestones needed to define and implement any such reductions within six
to 12 months of the trigger.
• Hatchery Reforms that Could Increase Listed Fish Survival:
o NOAA Fisheries could require in biological opinions currently being prepared
(and associated Section 10 permits and 4(d) authorizations) that:
1. Hatchery operators intercept spawners they produced if a threshold proportion Comment [k1]: We don’t ID how things would
of hatchery-origin spawners were exceeded. In this case, NOAA Fisheries be funded anywhere else and at this point I don’t
think decisions have been made about who would do
would need to consult on the placement and operation of temporary weirs, the what nor have funds been identified yet. Not sure
construction of new acclimation facilities to increase returning adult fish how to handle this but I just added a footnote saying
new actions are not funded at this time.
homing fidelity, and additional monitoring to confirm how many, where, and Alternatively we could mark the funding statements
when hatchery fish are spawning naturally. NOAA Fisheries may need to in yellow to indicate “areas for further discussion.”
initiate negotiations with the US v. Oregon parties under Court supervision. Deleted: The FCRPS Action Agencies could
provide funding to hatchery operators for temporary
The Rapid Response Plan would describe the specific steps and milestones weirs, acclimation ponds, and new monitoring and
needed to define and implement any such reductions within six to 12 months evaluation. NOAA Fisheries could also reinitiate
consultation on existing biological opinions to
of the trigger. implement this contingency if needed.
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2. Hatchery operators improve hatchery fish fitness in nature by only using

broodstock from the same population that is being supplemented and by
increasing the proportion of natural fish in the hatchery broodstock. The Deleted: The FCRPS Action Agencies could
provide funding for broodstock collection facilities.
Rapid Response Plan would describe the specific steps and milestones needed
to define and implement any such reductions within six to 12 months of the
trigger.
3. Hatchery operators restore adult and juvenile fish access to spawning and
rearing areas blocked by hatchery facilities. The Rapid Response Plan would Deleted: The FCRPS Action Agencies could
provide funding for the removal of barriers and for
describe the specific steps and milestones needed to define and implement any new water sources to support the hatchery.
such reductions within six to 12 months of the trigger.
4. Hatchery water diversions meet current criteria to protect fish from
entrainment or injury. Deleted: The FCRPS Action Agencies could
provide funding for the construction or modification
of water diversion screens.¶
•Safety Net Hatchery Programs That Could Reduce Short-Term Extinction Risk:
NOAA Fisheries could prepare or modify biological opinions and permits to allow
hatchery operators to identify:
1. Existing facilities and modifications to existing facilities,
2. Mitchell Act funded hatchery programs and modifications to such programs, Comment [k2]: Would this be a NOAA or FWS
action; AAs wouldn’t be involved in this ??
and
3. New facilities that would be needed to accommodate new hatchery
supplementation including captive broodstock programs. NOAA Fisheries
might need to initiate negotiations with the US v. Oregon parties under Court
supervision. Deleted: The FCRPS Action Agencies could
provide funding for these actions.¶
These may be followed by an All-H Diagnosis (Box 11, described below) and implementation of
longer-term Contingency Actions (Box 3) if warranted.
3.2 Contingency Plans (Greater Than One Year to Implement)
Box 3. Long-Term Contingency Plans would be developed by the Action Agencies, NOAA, and
FWS in consultation with the RIOG by early 2013. Contingency Plans would also consist of a
"menu" of potential actions and a decision-making process for selecting appropriate Contingency
Actions (for the ESU/DPS/population in question). However, unlike the Rapid Response actions
(Box 2), Contingency Actions would be longer-term actions (that would be considered and the
best actions implemented - Box 11) that could be implemented in the event that the Rapid
Response Actions (Box 9) are determined to be insufficient (Box 10) for addressing the
condition which triggered the initial Rapid Response Actions (Boxes 5-8).
The potential longer-term Contingency Actions described below could include negotiations,
regulatory compliance, and administrative planning for actions (e.g., changes in harvest
agreements or dam breaching studies, see below, etc.) that require permits and approvals,
environmental review, changes to existing legal agreements with other parties, the need to seek
additional authorities, and potentially additional ESA consultation or re-consultation.
3.2.1 Longer Term Contingency Actions for Each ESU/DPS Formatted: Font: 9 pt
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The following actions have been identified by the Action Agencies and NOAA to provide a
menu of potential actions that would be considered if a combination of fish status and habitat
conditions leads to an All-H Diagnosis (described in section 3, below) and development of
ESU/DPS-specific contingency plans for actual implementation.
Again, emphasis would be on contingency actions that would significantly improve fish survival.
Examples of actions for Contingency Plan development could include:
• Reintroduction: The Action Agencies could pursue the re-establishment of salmon Deleted: fund
populations that are functionally extirpated to increase the diversity and abundance of an
ESU overall.
• Predator Control: The Action Agencies, in combination with the U.S. Fish and
Wildlife Service and the States could pursue more aggressive efforts than those described Deleted: fund
as short-term actions (section 2.1.2)—i.e., those that require regulatory or administrative

changes, to control and eradicate predatory fish, avian predators, and invasive species to
increase survival of listed fish.
• Dam Breaching: The Action Agencies could pursue the authority to breach Snake River
dams, assuming Snake River stocks are declining, though this could have negative near-
term consequences (see Dam Breaching Studies, below)
• John Day MOP: The Action Agencies could pursue operating John Day at MOP,
assuming survival benefits and economic mitigation are confirmed.
• Phase II Hydro Actions: The Action Agencies could implement additional hydro
system actions (i.e., management plans already being developed under the FCRPS BiOp
in the form of Phase II actions).
• Expansion of Safety Net Hatchery Programs: NOAA could prepare or modify
existing biological opinions and permits to allow hatchery operators to implement longer-
term projects (than those in the Rapid Response Plan), such as constructing new facilities
where appropriate. The Action Agencies could provide funding for these actions.
Ultimately, the choice of a contingency for implementation will depend on the specific science
analysis of the circumstances, options, and limiting factors for the ESUs in question, as described
below. As noted above, not all of these actions fall within the authorities of the Action Agencies,
so support for implementation, if triggered, will be provided from NOAA and U.S. Fish and
Wildlife Service.
3.2.2 Dam Breaching Studies
In 2002, the Corps completed a comprehensive analysis and report on dam breaching and other
alternative actions, associated with the lower Snake River dams, in an effort to improve ESA
listed salmon and steelhead survival. This evaluation was initiated in 1995.
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In that report, the Corps recommended the implementation of a set of structural juvenile fish
passage actions (including surface passage technology) and improved operational measures.
These improvements were not only intended to reduce direct mortality associated with dam
passage, but also to reduce stress on juvenile fish, reduce total dissolved gas, and improve
operational reliability. Many of these measures have been or are currently being implemented.
The completed report explained the rationale for selecting this alternative and explained why
dam breaching and the other alternatives evaluated were not selected. The 2002 report provided
a thorough analysis of the biological, socio-economic, and other environmental effects of the
various alternatives.
The 2002 report confirmed the implementation of breaching would require additional
Congressional authorization, since the Corps has no authority to significantly reduce or eliminate
any of the existing purposes of these dams. To seek authorizations requires a comprehensive
analysis done in compliance with all environmental laws. The report also indicated dam
breaching would take many years to implement (up to 9-years once authorization and
appropriations are in place).
Contingency Options. As part of a BiOp contingency plan, the Corps (in cooperation with
other Federal agencies) shall be prepared to reevaluate dam breaching. Because dam breaching
takes many years to implement, it is considered to be a long-term contingency action. Therefore,
it would not be responsive to an emergency situation trigger (e.g., a catastrophic event such as
earthquake/volcanic eruption). There are three levels of reevaluation that can be pursued:
1) Study Plan. Prepare a detailed study plan to layout the scope, schedule and budget for
the overall reevaluation.
2) Technical Studies. Update the appropriate technical studies from the 2002 dam
breaching analysis with current information. Studies would update impacts to all
resources and uses that have significantly changed or where gaps exist in the previous
analysis. These studies would include, but would not be limited to: a) aquatic ecosystem
effects (A-Fish biological effects); b) socio-economic effects (e.g. hydropower
replacement, transportation, recreation, etc); c) other environmental effects (sediment,
water quality, air quality, etc); d) additional engineering analysis (turbine modification
modeling, rock source explorations for rip rap, and additional modeling of the by-pass
channel); and, e) implementation cost estimates. These studies would require
approximately two years to complete. The CRFM program would be used to fund these
studies and would require diverting funds from other BiOp required actions. It should be
noted that these studies will have a shelf life of approximately five years.
3) Congressional Authorization. An overall reevaluation study and supplemental EIS

would be prepared and used as a vehicle to seek Congressional authorization for dam
breaching – if warranted. This would include a comprehensive public and agency
involvement program.
From the above levels of analysis (Study Plan, Technical Studies, and Congressional
Authorization), three specific reevaluation options were developed for further consideration.
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Option A. Under this option, the Corps would immediately develop an overall study plan. This
would expedite the start of technical studies, as soon as the applicable trigger indicated they are
necessary. The actual dam breaching technical studies (as described above) would be initiated
only based on the appropriate trigger (e.g. 2013/2016 Comprehensive Evaluation, 4 year
abundance). Based on the results of the updated technical studies and biological triggers, the
RIOG could (if warranted) make a recommendation to the Corps to seek Congressional authority
for dam breaching. This would then require the Corps to complete an overall reevaluation study
and supplemental EIS.
Option B. This option would immediately initiate studies to reevaluate the short-term A-Fish
biological effects of dam breaching, focused on the sediment resuspension analysis included in
the Corps 2002 report. This option is under consideration because the BiOp independent science
review identified some uncertainty that the short-term effect of sediment could over shadow the
long-term benefits of breaching. In addition to high volumes of sediment re-suspension, chemical
contaminants contained in the reservoir sediments would also be resuspended. Total DDT,
dioxin, manganese, and un-ionized ammonia are chemicals of concern. The Corps would update
the sediment and water quality effects analysis associated with dam breaching, to better assess
the short-term biological impacts. This information would then be incorporated into the
Cumulative Risk Initiative (CRI) analysis. In addition, the Corps would develop a study plan that
would layout the scope, schedule and budget for the remaining dam breaching technical studies
(socio-economic, other environmental, engineering, etc). These remaining studies would be
initiated only based on the appropriate trigger. If warranted, Congressional authorization studies
could then be initiated, as described in Option A.
Option C. This option would immediately prepare an overall study plan and initiate updates of
previous dam breaching technical studies. This would preposition the Corps to quickly seek
Congressional authorization, if warranted, as described in Option A. Knowing these technical
studies will have a 5-year shelf life and depending on when the triggers take effect, these studies
may need to be updated again prior to seeking Congressional authorization.
4. Evaluations and Contingency Triggers and Responses

4.1 Evaluation of Ongoing Productivity, Biological, and Environmental Metrics
Box 4. RM&E results relating to productivity, biological, and environmental metrics will be
evaluated at appropriate intervals (depending upon the type of data - e.g., ESU-level adult
returns, population abundance estimates, knowledge natural disasters, etc.) to determine if Early
Warning (Box 5), Unexpected Declines (Box 7), or decreases in ESU populations (Box 8)
metrics have been triggered.
The Action Agencies and NOAA have developed/are developing more detailed triggers for
implementing contingency plans for interior basin listed fish, based on measures of fish status
and measures of habitat condition. In addition to the trigger provided in the BA/BiOp (Box 8),
two additional triggers are proposed as a further refinement of the BA/BiOp adaptive
management process to further ensure precautionary implementation of the BiOp. These
additional triggers are described in the following sections. Formatted: Font: 9 pt
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4.1 Early Warning Trigger
Box 5. The Early Warning Trigger is intended to be sensitive to a "likely" decline in status of a
population/MGP/ESU based on a combination of adult returns (2 years) and preliminary
biological or environmental indicators that would suggest that very low abundance would be
expected in the next two years OR a natural disaster has occurred which would be expected to
dramatically reduce the productivity of the population/MGP/ESU in question over the next two
or more years (metrics considered periodically in Box 4). This indicator would be evaluated as
information becomes available.
Box 6. This step in the process provides further consideration by the Action Agencies and
NOAA in consultation with the RIOG of the information triggering the Early Warning process
(Box 5) to assess if the event was of sufficient magnitude or of sufficient concern to warrant the
implementation of Rapid Response Actions (Box 9).
Examples of preliminary biological or environmental indicators are provided below. Additional

indicators are being examined and are likely to be added in the future.
Preliminary Biological Indicators
Examples of preliminary biological indicators could include:

• Extremely low jack counts which would indicate a likely decline in adult numbers the
following year;
• Extremely low numbers of migrating juvenile smolts indicating that productivity has
been reduced in freshwater habitat;
Preliminary Environmental Indicators
Examples of preliminary environmental indicators could include:

• Freshwater Hydrology Indicators could include reasonable expectations (based on
forecasting, etc.) that severe droughts would occur for several years,
• Ocean Ecosystem Indicators could include estimates of low prey abundance, high predator
abundance, low juvenile salmonid densities, or other ocean factors indicative that ocean
productivity is very low and will likely result in substantially reduced adult returns in
future years,
• Natural Disasters Indicators could include large forest fires, volcanic eruptions, disease
outbreaks, landslides (blocking access to spawning habitat), etc., that would be reasonably
expected to substantially reduce the productivity of freshwater habitat in future years.
Additional Potential Indicators
Indicators could also include additional factors such as unusual outbreaks of pathogens or
increased virulence of same pathogens, the ratio of hatchery- to natural-origin fish on the
spawning grounds, juvenile fish size, etc. The Action Agencies and NOAA could gather
baseline data for this purpose (see RM&E, below), so there would be a basis for comparison and Formatted: Font: 9 pt
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an estimate of natural variability. Much of this information is not widely available at the current
time, although it is currently planned for certain watersheds/populations.
4.2 Unexpected Decline Trigger
Box 7. The Unexpected Decline is intended to be sensitive to unexpectedly low abundance (four
year rolling average, nth % exceedence of last 20-25 years of data) for either an ESU or 30-50%
of its populations as assessed in the evaluation of productivity, biological, and environmental
metrics (Box 4). Triggering of the Unexpected Decline metric would lead to implementation of
Rapid Response Actions (Box 9). This indicator would be evaluated annually for each interior
basin ESU.
By FY2010?, the Action Agencies and NOAA, in consultation with the RIOG, would develop an
objective indicator and threshold for each interior basin ESU and DPS that would signal a Comment [RG3]: May be able to generate this
trigger in early August - without much RIOG
substantial, unexpected decline in the number of wild adults returning to individual ESUs1 (or to consultation.
30-50% of the populations within the ESUs), triggering implementation of Rapid Response
Actions.
4.3 BiOp / BA Trigger (Decline in 30-50% of the Populations in an ESU)
Box 8. The BiOp / BA Trigger was intended to assure that the majority of populations are not
decreasing at the time of the 2013 and 2016 Comprehensive Evaluations. Decreasing abundance
in 30% to 50% of an ESUs populations (as indicated by evaluations of R/S, Lambda, etc. as part
of the evaluation of productivity, biological, and environmental metrics - Box 4), would trigger
implementation of Rapid Response Actions (Box 9). This indicator would be evaluated annually
for each interior basin ESU.
This indicator is already included in the BiOp / BA. Additional details regarding this trigger can
be found in (cite locations in the BiOp / BA).
4.4 Implementation and Evaluation of Rapid Response Actions
Box 9. The Rapid Response Planning and Implementation Process will be engaged following
the triggering of Early Warning (Box 5 and 6), Unexpected Decline (Box 7), and BiOp / BA
decreasing abundance (Box 8) metrics. This process will be targeted at the appropriate scale
(population, MGP, or ESU), identify actions from the Rapid Response Plans (Box 2) that are
most likely to be effective at improving survival / productivity, and implement these actions as
soon as possible (e.g., < 12 months) depending upon the nature of the actions.
Box 10. An evaluation to determine if the implemented Rapid Response Actions (Box 9) are
likely sufficient to address the metric which initially triggered the Early Warning (Box 5),
Unexpected Decline (Box 7) or BiOp / BA (Box 8) triggers will be conducted as soon as the
available information allows (generally within 6-12 months of actions being implemented). If it
is determined that the actions have likely been sufficient to address the metric(s) in question, Comment [RG4]: by the AAs, NOAA and
RIOG?
1
Will need to determine if in-season preliminary counts and/or post-season final counts would be used. Formatted: Font: 9 pt
BR025
evaluations of ongoing productivity, biological, and environmental metrics (Box 4) will be used
to continue assessing the triggering mechanisms for additional actions. If it is determined that the Comment [RG5]: by the AAs, NOAA and
RIOG?
actions have NOT likely been sufficient to address the metric(s) in question, the Tier 2 Diagnosis
and the All-H process will be engaged (Box 11).
Need some text for describing process in more detail. Want to check with team if the above looks
right - Also, do you have suggestions for additional text?
5. All-H Diagnosis and Contingency Implementation
Box 11. The Tier 2 Diagnosis and All H Process (which includes life-cycle and life-stage
modeling) will evaluate alternative longer term Contingency Actions (Box 3) and determine
which action, or suite of actions, is likely best suited to address the downward abundance trends
that the Rapid Response Actions (Box 9) were unable to address (Box 10).
In addition, triggering of the Tier 2 Diagnosis and All H Process would require NOAA to
simultaneously begin its reinitiation review process for the FCRPS, Upper Snake, and US v
Oregon BiOps.
Following adoption of Contingency Actions via the All H Process, the Action Agencies and
NOAA would immediately engage in all necessary processes and actions to implement the
adopted Contingency Actions as soon as possible.
Box 12. Following implementation of Contingency Actions, an evaluation to determine if the

implemented Rapid Response Actions (Box 9) are likely sufficient to address the reduced
productivity of the ESU/MPG/populations in question which triggered the Tier 2 Diagnosis and
All H Process (Box 11) Early Warning (Box 5), Unexpected Decline (Box 7) or BiOp / BA (Box
8) triggers will be conducted as soon as the available information allows (this would likely take
several years after the actions were implemented). If it is determined that the actions have likely Comment [RG6]: by the AAs, NOAA and
RIOG?
been sufficient to address the metric(s) in question, evaluations of ongoing productivity,
biological, and environmental metrics (Box 4) will be used to continue assessing the triggering
mechanisms for additional actions. If it is determined that the actions have NOT likely been Comment [RG7]: by the AAs, NOAA and
RIOG?
sufficient to address the metric(s) in question, additional actions would need to be identified or
NOAA and the Action Agencies would need to reinitiate consultation (Box 13)
When it has been determined that Rapid Actions have been insufficient to address factors that
either have led (Unexpected Decline or BiOp / BA Triggers) or are likely to lead (Early Warning
Trigger) to reduced abundance and productivity of pertinent populations/MPGs/ESUs, the
Action Agencies and NOAA, in consultation with the RIOG, will engage in a rapid lifecycle and
life stage analysis. An “All-H Diagnosis” would be used to determine both likely causes of
decline and which of the predetermined potential mitigation actions (Developed in the
Contingency Plans) should be implemented to improve fish survival to improve productivity and
abundance of the affected population/MPG/ESU.
BR026
• Available mitigation actions will include those that are predetermined (Section 3.2
above), but could include other effective actions as well
• Specific actions would be chosen based on the best available information on fish survival
benefits, costs and other potential implications
• A scientific Rapid Response Team including independent scientists could be convened to
assist this effort
The ESU/DPS-level contingency plans would consider the potential for positive or negative
effects of actions on other listed species (including those managed by the Fish and Wildlife
Service) and unlisted species that are Tribal trust resources.
Additional descriptions of the Tier 2 Diagnosis and All H Process can be found in (cite BiOp and
BA sections).
6. Additional Actions OR Reinitiation of Consultation
Box 13. The identification and implementation of additional actions (including NOAA entering
negotiations and/or requiring reinitiation of consultation on other Biological Opinions, if
necessary to implement actions) could occur if it is determined that Contingency Actions (Box
11) are not likely sufficient to address the factors leading to the decreased abundance and
productivity of the populations/MPGs/ESUs in question.
OR
NOAA Fisheries and the Action Agencies will Reinitiate Consultation on the FCRPS, Upper
Snake, and US v Oregon biological opinions.
Failure to address declining abundance and productivity after implementing Contingency

Actions would result in either additional actions - and regulatory mechanisms that allow them -
to be identified and implemented that would reverse this trend, or that reinitiation of consultation
is required for the FCRPS, Upper Snake, and US v. Oregon biological opinions.
BR027

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Sent: Saturday, July 25, 2009 4:58 PM

Contingency Planning and RM&E

• Continuing and/or enhancing Research, Monitoring, and Evaluation (RM&E) programs;

2. Research, Monitoring and Evaluation

2.1 Climate Change RM&E

• Improved system wide coordination and modeling of existing information from

3. Development of Rapid Response and Long-Term Contingency Plans

Deleted: The Rapid Response Plans would be

2. Hatchery operators improve hatchery fish fitness in nature by only using

3.2 Contingency Plans (Greater Than One Year to Implement)

as short-term actions (section 2.1.2)—i.e., those that require regulatory or administrative

3.2.2 Dam Breaching Studies

3) Congressional Authorization. An overall reevaluation study and supplemental EIS

4. Evaluations and Contingency Triggers and Responses

4.1 Early Warning Trigger

Examples of preliminary biological or environmental indicators are provided below. Additional

Preliminary Biological Indicators

Examples of preliminary biological indicators could include:

Preliminary Environmental Indicators

Examples of preliminary environmental indicators could include:

Additional Potential Indicators

4.2 Unexpected Decline Trigger

4.3 BiOp / BA Trigger (Decline in 30-50% of the Populations in an ESU)

4.4 Implementation and Evaluation of Rapid Response Actions

5. All-H Diagnosis and Contingency Implementation

Box 12. Following implementation of Contingency Actions, an evaluation to determine if the

6. Additional Actions OR Reinitiation of Consultation

Failure to address declining abundance and productivity after implementing Contingency

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