PACIFIC ENVIRONMENTAL ADVOCACY
CENTER ( I hate all caps )
10015 S.W. Terwilliger Boulevard
Portland, Oregon 97219
phone: 503-768-6727 fax: 503-768-6642
VIA CERTIFIED MAIL
April 19, 2001
Re: Notice of Intent to Sue for Violations of the Endangered Species Act
Dear Sirs and Madames:
On behalf of Trout Unlimited, Pacific Coast Federation of Fishermen’s Associations,
Institute for Fisheries Resources, and Idaho Rivers United, this letter serves to notify you that you must take prompt action to correct ongoing violations of the Endangered Species Act ("ESA"), 16U.S.C. §§ 1531-1544.
As discussed below, the Bureau of Reclamation’s (the "BOR") 11
projects in the upper
Snake River basin ("the BOR’s Snake River Projects" or "the
Snake River Projects") are being
operated in violation of the ESA. Specifically, the BOR’s actions contribute
to low stream flow
conditions in the Snake and Columbia Rivers that have harmed and will continue
to harm listed
anadromous fish. Failing to modify operations to augment flows during the 2001
migration season
to levels necessary to avoid jeopardizing listed salmon and steelhead (e.g., to
meet the flow targets
established in the 2000 Biological Opinion on the Federal Columbia River Power
System) violates
Sections 7(a)(2), 7(d), and 9 of the ESA.
I. Listed Snake River Salmon and Steelhead
And on and on and on