Comment on proposed FY 2006 budget

This response confirms our desire for renewal of funding in FY06 for project 199501300. While the budget identified ($183,561) is consistent with the previously approved budget, it is not sufficient in that it continues to fall short of project needs to fully implement the full scope of work (all work elements). Additional funding of $26,044 is needed, for a total requested budget of $209,605 which was sought via the Within-Year Budget Request process (for a second consecutive year) but after a prolonged period no funding was forthcoming. These funds are necessary to offset increasing costs of doing business including equipment repair costs (most project equipment is over five years old so frequent major repairs are required in addition to routine maintenance), significantly higher fuel prices (and travel-related costs), materials costs (fish for stocking, gravel for road repair), and normal increases in personnel-associated costs and indirect costs (costs that project-level management has no control over). The increases requested using the prescribed process the past two years are reasonable and not extraneous, but necessary to keep this project fully functional, stocking and maintaining important fisheries, maintaining sites and equipment, in order to provide harvest opportunities for tribal members.

Accomplishments since the last review

The Resident Fish Substitution Program in its current O&M mode maintained important fishery opportunities during 2003 and 2004 to the present on the Nez Perce Reservation. The trout fisheries managed by the project at three ponds serve as partial mitigation for the lost anadromous fisheries that resulted from the construction of Dworshak Dam on the North Fork Clearwater River. The project continued routine activities of stocking fish to maintain the fishery, monitoring water quality, fish health, and harvest, and site maintenance work including access road repair and site facility maintenance, cattle exclusionary fence inspection and repair, as well as equipment maintenance.

FY 2006 goals and anticipated accomplishments

The FY 2006 project goals are to maintain the three trout pond fisheries on the Nez Perce Reservation and thereby provide quality harvest opportunities for tribal members. Goals include accomplishing activities that maximize fishery harvest including stocking fish to maintain the fisheries, monitoring water quality, fish health, and harvest, and site maintenance work including access road repair and site facility maintenance, cattle exclusionary fence inspection and repair, as well as equipment maintenance.

Subbasin planning

How is this project consistent with subbasin plans?

NPT Resident Fish Substitution Program is consistent with and implements activities that are within the general scope of the objectives and strategies in the Clearwater Subbasin Management Plan (November 2003). Council staff recommended adoption of the plan, along with December 2004 revisions, as a draft program amendment, which was then released for public review. In a letter dated January 12, 2005 the Nez Perce Tribe emphasized the lack of an explicit context for the Resident Fish Substitution Program as well as other programs and recommended specific language to address the issues. In a decision memorandum dated February 8, 2005, Council staff responded by noting that the implementation activities related to resident fish substitution are within the general scope of the objectives and strategies in the plan and may be pursued, if desired, in future project selection processes. Furthermore, the activities of this project are delineated in detail in the Nez Perce HGMP, draft Clearwater Subbasin Summary, Appendix H, section 2.1 in particular where mitigation aspects of this project are aligned with concepts and policies contained in NPPC 99-15. In addition, the original program language in measures 10.8D.1 and 10.8D.2 of the Council’s 1995 Fish and Wildlife Program provides a basis for utilizing consumptive resident fisheries as a partial substitute to compensate for lost anadromous fisheries.

How do goals match subbasin plan priorities?

As indicated in the preceding consistency section resident fish substitution activities are within the general scope of objectives and strategies of the subbasin plan and therefore the work conducted by the NPT Resident Fish Substitution Program is a priority. In addition, in the vision statement that serves as the underlying guiding principle for the plan the first principle listed spells out the respect and recognition required in order to honor treaty-reserved rights, which include the fisheries harvest of the Nez Perce Tribe and in cases where this has been negatively impacted, as in the North Fork Clearwater River salmonid harvest due to the construction of Dworshak Dam, the mitigation efforts, such as resident fish substitution, used to alleviate the lost opportunities.

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