Honorable Kimberly D. Bose May 14, 2018 Secretary Federal Energy Regulatory Commission 888 1st Street N.E. Washington, D.C

Via Electronic Filing Honorable Kimberly D. Bose May 14, 2018 Secretary Federal Energy Regulatory Commission 888 1st Street N.E. Washington, D.C. 20426 Subject: Wells Hydroelectric Project FERC Project No. 2149 White Sturgeon Supplementation Plan License Article 401 (a) Dear Secretary Bose: Pursuant to Article 401(a) of the Federal Energy Regulatory Commission (FERC) license for the Wells Hydroelectric Project, the Public Utility District No. 1 of Douglas County (Douglas PUD) hereby submits a revised White Sturgeon Supplementation Plan (formally White Sturgeon Broodstock Collection and Breeding Plan) for approval. Article 401(a) required Douglas PUD to file an agency approved Sturgeon Broodstock Collection and Breeding Plan within one year of license issuance. Consistent with this requirement Douglas PUD submitted an agency approved plan to the FERC on February 13, 2013. The FERC subsequently approved this original Plan by order dated May 28, 2013. Article 401(a) requires Douglas PUD to update this plan as necessary, or at the request of the Aquatic Settlement Work Group (Aquatic SWG). Towards meeting this update requirement, Douglas PUD and the Aquatic SWG developed the White Sturgeon Supplementation Plan in early 2018. The Aquatic SWG approved this revised White Sturgeon Supplementation Plan on April 11, 2018. The new White Sturgeon Supplementation Plan, as approved by agency members serving on the Aquatic SWG is attached as Exhibit A to this letter and the consultation record that supports the development and approval of this revised document is attached as Exhibit B. Please note that the enclosed White Sturgeon Supplementation Plan, is consistent with the FERC license, the White Sturgeon Management Plan that is contained within the Aquatic Settlement Agreement and is consistent with license mandated Clean Water Act section 401 Water Quality Certification for the Wells Project. If you have any questions or require further information regarding the White Sturgeon Supplementation Plan, please feel free to contact Andrew Gingerich at (509) 881-2323, andrewg@dcpud.org.

Sincerely, Shane Bickford Natural Resources Supervisor Enclosure: 1) Exhibit A White Sturgeon Supplementation Plan 2) Exhibit B Pre-filing consultation record for the White Sturgeon Supplementation Plan Cc: Alicia Burtner, FERC Wells Aquatic Settlement Work Group Andrew Gingerich, Douglas PUD Chas Kyger, Douglas PUD

Exhibit A White Sturgeon Supplementation Plan

WHITE STURGEON SUPPLEMENTATION PLAN (formerly Broodstock Collection and Breeding Plan) Version 2 Supplementation and Program Milestones WELLS HYDROELECTRIC PROJECT FERC PROJECT NO. 2149 Public Utility District No.1 of Douglas County East Wenatchee, WA 98802 April 2018

Table of Contents 1.0 INTRODUCTION... 1 1.1 Wells Project Relicensing... 1 1.2 WSMP and WSBBP Progress... 2 1.3 2003 Wells Project White Sturgeon Population Status... 3 1.4 Post License 2015-2016 Monitoring and Evaluation... 4 1.4.1 Wild Fish Encounters During Monitoring and Evaluation... 5 2.0 COLUMBIA BASIN CONSERVATION AQUACULTURE... 6 3.0 ORIGINAL WSBBP PLAN DEVELOPMENT... 7 4.0 DOUGLAS BROODSTOCK AND LARVAE COLLECTION... 8 5.0 WSMP PHASE I SUPPLEMENTATION GOALS... 11 5.1 Progress to Date... 11 5.2 Population Model Scenarios... 11 5.2.1 Baseline Population... 11 5.2.2 Modeling Exercises in 2016... 14 5.2.3 2017 Model Results... 15 6.0 CONCLUSIONS... 17 7.0 LITERATURE CITED... 19

1.0 INTRODUCTION As of the end of 2017, the Public Utility District No. 1 of Douglas County (Douglas PUD or Douglas), the owner and operator of the Wells Hydroelectric Project (FERC Project No. 2149), has achieved all of the goals and objectives found in the Federal Energy Regulatory Commission (FERC) approved White Sturgeon Management Plan (WSMP), the White Sturgeon Broodstock Collection and Breeding Plan (WSBBP). Following achievement of the goals of this plan, the District met with the members of the Aquatic Settlement Work Group (SWG) to establish the goals and objectives for the remainder of Phase I (2018-2022) of the White Sturgeon Management Plan. Following several meetings, the Aquatic SWG unanimously approved several significant changes to the Phase I plan. First, it is expected there will be no future need to collect adult sturgeon broodstock and no need to implement a complex mating plan for those broodstock. Instead the goals of the WSMP during the remainder of Phase I will be achieved utilizing only juvenile white sturgeon originating from wild-caught larvae. These adaptations to the plan are being made based upon the best available science and technical information including studies conducted under the monitoring and evaluation aspects of the WSMP. These changes are sufficiently significant that they also necessitate changing the reference document used to manage these stocks. Douglas PUD and the Aquatic SWG will no longer be operating under the guidance of the White Sturgeon Broodstock Collection and Breeding Plan but will instead be conducting all future White Sturgeon enhancement efforts under the guidance of the White Sturgeon Supplementation Plan (WSSP). The District is seeking FERC approval of this new plan pursuant to the requirements of article 401[a] of the FERC license for the Wells Project. 1.1 Wells Project Relicensing During the relicensing of the Wells Hydroelectric Project (Wells Project), Douglas developed a White Sturgeon Management Plan (WSMP; Douglas PUD 2008). The WSMP is one of six Aquatic Resource Management Plans contained within the Aquatic Settlement Agreement (Agreement). The WSMP was developed in close coordination with state and federal agency and tribal natural resource managers (Aquatic SWG). During the development of this plan, the Aquatic SWG focused on developing management priorities for resources potentially impacted by Project operations. The WSMP was based on similar plans that have been developed in other areas of the middle and upper Columbia River Basin, specifically the Kootenai White Sturgeon Recovery Plan, the Upper Columbia White Sturgeon Recovery Initiative Recovery Plan (UCWSRI 2002), the Priest Rapids White Sturgeon Management Plan (Grant PUD 2009), and the Rocky Reach White Sturgeon Management Plan (Chelan PUD 2005). The Kootenai and Upper Columbia recovery programs were implemented in 1996 and 2001, respectively. The Priest Rapids WSMP was initiated in 2009 and the Rocky Reach WSMP was initiated in 2010. As part of the requirements found within the Douglas WSMP (4.1.1) and license requirements (article 401[a]) Douglas developed a White Sturgeon Broodstock Collection and Breeding Plan (WSBBP) in 2011. The WSBBP was developed in concert with, and received the approval of, the Aquatic Settlement Work Group. Following the November 2012 issuance of a new FERC license for the Wells Hydroelectric Project, Douglas submitted the WSBBP to the FERC on February 13, 2013. FERC reviewed and approved this plan by Order date May 28, 2013 (Appendix A). License requirements

require periodic review and revision to the WSBBP at the request of the Aquatic SWG or as necessary with updates to program and knowledge. As such, the WSBBP is being updated to reflect significant changes in the program s goals and objectives and is being renamed to avoid future confusion with the supplementation emphasis of the new plan (herein referred to as the White Sturgeon Supplementation Plan or WSSP ). 1.2 WSMP and WSBBP Progress The goal of the WSMP is to increase the white sturgeon (Acipenser transmontanus) population in the Wells Reservoir to a level that can be supported by the available habitat and characterized by a diverse age structure consisting of multiple cohorts (juvenile and adult). In addition, the WSMP is intended to support spawning, rearing and migration as identified by the aquatic life designated use under WAC 173-201A in the Washington State water quality standards. Based upon the information available as of December 2006, the Aquatic SWG determined that an assessment of Project effects on white sturgeon was not practical given sturgeon life history characteristics and the limited number of fish estimated to exist in the Project. Therefore, the Aquatic SWG concluded that resource measures related to white sturgeon should focus on population protection and enhancement by means of supplementation as an initial step in order to increase the number of fish within the Wells Reservoir. The version of the WSBBP that was approved by the FERC in 2013 was written with this fundamental goal in mind. As part of the WSMP and WSBBP implementation, in June 2012 Douglas and members of the Aquatic SWG approved two efforts to provide Douglas with juvenile white sturgeon over the first four years of implementation in order to meet supplementation requirements. Beginning in 2013 and ending in 2016 Douglas funded the collection and spawning of wild broodstock collected in the lower Columbia River reservoirs and the collection of white sturgeon larvae collected in the upper Columbia River (Appendix B). In 2014 Douglas PUD released the first group of yearling white sturgeon into the Wells Reservoir. In 2014 approximately 60% of the fish released were those that were sired by a 3 female x 3 male factorial cross (May 29, 2013) and a 1 female x 3 male cross (6/19/2013). The balance of fish (40%) released in 2014 were those captured predominately from fish collected in Lake Roosevelt as wild produced larvae. In 2015, all members of the Aquatic SWG reviewed and approved/abstained (Yakama Nations abstained) a White Sturgeon Source and Stocking Consideration document that prioritized the use of larvae origin fish towards meeting supplementation goals in the years 2015-2017 if available and use sturgeon from conventional adult broodstock crosses if larvae were not available (Appendix C). Based on this document and white sturgeon availability, in years 2015-2017 only wild caught larvae from Lake Roosevelt were used to meet the 5,000 fish release target. A summary of the white sturgeon juvenile releases completed to date is provided in Table 1.

Table 1. Wells Project White Sturgeon Supplementation Totals by Year, Source, and Stocking Location. WCL stands for Wild Caught Larvae, and CBS stands for Conventional Brood Stock. Washburn Island Near Bridgeport, WA TOTAL Date WCL CBS WCL CBS WCL CBS GRAND TOTAL 2014 15-Jan 16 1 0 0 16 1 17 10-Apr 0 2,881 0 30 0 2,911 2,911 12-Jun 2,116 0 0 0 2,116 0 2,116 2014 TOTAL 2,132 2,882 0 30 2,132 2,912 5,044 2015 1-2 Jun 4,985 0 24 0 5,009 0 5,009 2015 TOTAL 4,985 0 24 0 5,009 0 5,009 2016 1-Jun 5,248 0 41 0 5,289 0 5,289 2016 TOTAL 5,248 0 41 0 5,289 0 5,289 2017 1-2 Jun 0 0 5,132 0 5,132 0 5,132 2017 TOTAL 0 0 5,132 0 5,132 0 5,132 GRAND TOTAL 12,365 2,882 5,197 30 17,562 2,912 20,474 Since Douglas s requirement to stock 5,000 fish/year in the first four years (up to 20,000 fish) has been met, Douglas and the Aquatic SWG must work together to develop subsequent stocking numbers for the remainder of the first ten years of license implementations. The new WSSP was designed to adapt to new information and to more effectively supplement the white sturgeon population in the Wells Reservoir 1.3 2003 Wells Project White Sturgeon Population Status Research to determine the abundance, distribution, population dynamics, biophysical attributes of preferred habitat, seasonal movement patterns, and spawning characteristics of white sturgeon were conducted in Wells Reservoir from 2001 to 2003 (Jerald 2007). This information has been summarized below and where applicable, was used to tailor both the 2013 and 2018 version of the WSBBP and WSSP.

A relatively small population of white sturgeon (estimated at 34 fish; 95% CI of 13-217 fish), primarily consisting of adults, was estimated to be present in the Wells Reservoir following research conducted in 2003 and 2004. Based on setline capture and radio telemetry movement information, white sturgeon were found primarily near the confluence of the Okanogan and Columbia rivers and in the lower Okanogan River. White sturgeon were not documented during telemetry surveys or setline surveys conducted outside this area during the spawning period. The location of spawning areas and the occurrence of spawning in the reservoir were not documented during this effort. Sex ratios for white sturgeon captured in the Wells Reservoir were not determined. Captured sturgeon ranged in age from 6 to 30 years old demonstrating that all of these fish recruited to the Wells Reservoir after Wells Dam was completed in 1967 with strong year-class recruitment between the years 1972 and 1978 and again between 1988 and 1996. The presence of fish within these age classes suggests that successful recruitment within or to the Wells Reservoir is occurring either through (1) spawning within the Wells Reservoir and/or (2) immigration into the Wells Reservoir from populations upstream. Catches were dominated by white sturgeon from 60 to 135 cm fork length (FL), which represented fish between the 1988 to 1997 year-class and from 180 to 210 cm FL (1972 to 1978 year-class). These two groups accounted for all captures. A frequency distribution showed a relatively low proportion of younger juvenile white sturgeon, with 15% of the total catch composed of juvenile fish less than 90 cm. However, the use of set lines with large circle hooks (11/0, 13/0 and 15/0) likely reduced the capture of smaller, younger fish. Two white sturgeon were captured and subsequently recovered to provide growth rate information. One juvenile grew from 65 cm FL at capture on July 11, 2001 to 87 cm FL on September 26, 2002, a growth rate of 22 cm in 14 months. One adult fish caught on August 9, 2001 measured 197 cm FL and when recaptured on September 6, 2002 measured 199 cm FL, a 2 cm growth over approximately 13 months. This fish was subsequently found deceased in October of 2006 and was 228.5 cm FL, which represented an increase of 29.5 cm FL over an approximate four year period (average of 7.4 cm per year). In total, six white sturgeon were radio-tagged and monitored throughout the study period using mobile and fixed telemetry. Telemetry data along with setline capture data verified that white sturgeon congregated in the Columbia River near the Okanogan River confluence during the summer, fall, and winter months with none of the six fish being detected downstream from Brewster (RM 530) or upstream of Park Island (RM 538). Very little movement of tagged sturgeon was observed during winter months. In the spring of 2002, one adult made an upstream migration into the Okanogan River; in 2003, two different adults undertook movements into the Okanogan River. In general, the results of the white sturgeon study in the Wells Reservoir were similar to the results of a study conducted in the neighboring Rocky Reach Reservoir in 2001-2002 (Chelan PUD 2005). Both studies captured similar numbers of sturgeon using similar amounts of effort and similar capture techniques. Radio-telemetry data from both studies suggest that very little activity occurs during the winter. 1.4 Post License 2015-2016 Monitoring and Evaluation In 2015, Douglas PUD began implementing the components of the WSMP requiring monitoring and evaluation (M&E) of both the wild and hatchery produced white sturgeon within the Project. The M&E requirements within Phase I of the WSMP include an acoustic telemetry program, an index monitoring program, and research toward determining natural reproduction potential.

During the first four years of the supplementation program >20,000 age 1 hatchery-produced juvenile sturgeon were released into the Wells Reservoir. All of the age 1 sturgeon were affixed with a passive integrated tag (PIT) tag and marked by the removal of specific lateral scutes. In addition, 49 of the brood year (BY) 2014 fish and 50 of the BY2015 fish were each outfitted with an acoustic tag prior to release. Additionally, acoustic tags were deployed in the field during 2015-2017. For example, acoustic tags were applied to 50 BY2013 fish when they were recaptured. Acoustic-tracking was completed using an array of 29 receivers distributed throughout the Wells Project from the Chief Joseph Dam tailrace to the Wells Dam tailrace. PIT-tag detection arrays were deployed in the Methow and Okanogan rivers, and at Wells Dam fish ladders. For index monitoring, stratifiedrandom setline sampling was conducted in the summer (July/August) and fall (September/October) in each of the years spanning 2015-2017. For each set, the total number of sturgeon was recorded. All captured sturgeon were scanned for PIT tags, measured (fork length, weight), and any fish without a PIT tag or scute mark had one applied. Based on their PIT tag IDs, all recaptured hatchery fish were of known age (brood year). Collectively, there were 441 capture events in 2015 and 723 in 2016. The acoustic-tagged fish appeared to have initially spread out from the release site, but subsequent movements of sturgeon were not dramatic. Sturgeon were detected (using telemetry) and captured (during indexing) in all of the reservoir sampling zones, although some areas had more sturgeon than others. The distribution of sturgeon did not vary markedly between the summer and fall sampling sessions of 2015, but showed a downstream shift between 2015 and 2016, followed by an upstream shift between the summer and fall sessions of 2016. Acoustic telemetry data collected in 2017 has yet to be analyzed; however, the presence of tagged sturgeon in all areas of the Wells Project was dissimilar than results in 2003-2004 radio tracking data, but is likely an artifact of the radio telemetry application rather than the acoustic work done in more recent years. The fact that acoustic tagged sturgeon were predominately observed in the same locations that they were exclusively observed in the 2003-2004 work suggest that sturgeon have preferred habitat within the Wells Project. Apparent survival rates were estimated using the PIT-tag mark and recapture data. Survival from release to recapture was estimated at 23.1% (SE = 1.2%) for BY2013, and 30.3% for BY2014. Due to observed gear selectivity issues for juvenile sturgeon, estimates of early stage survival is probably biased low. Survival of larval-origin fish (those raised from wild-caught larvae) was ~5% higher than that for fish raised from direct gametes or conventional broodstock program, but the difference was not statistically significant. The apparent survival rates did not account for tag loss or emigration. Modelling emigration of 5.4% and tag loss at 1.9% resulted in <2% increase in survival. Growth rates of age 1 hatchery reared sturgeon during the first few months in the reservoir appeared to be higher than those observed in other similar studies, but slowed to a more typical growth rate after the fish spent more time (1+ years) in the reservoir. 1.4.1 Wild Fish Encounters During Monitoring and Evaluation In 2015, seven wild-origin fish were caught during juvenile indexing. These measured between 69 and 91 cm FL, and weighed between 2.4 and 5.3 kg (but the largest fish, which was not weighed, was estimated at 6 kg). In 2016, during the summer and fall juvenile indexing efforts, another 11 wild-origin fish were encountered, which measured between 59 and 130 cm FL, and weighed between 1.3 and 17.5 kg. During a fishing session that targeted adults (large hook sizes) in 2016, another 16 wild-origin fish were caught, which ranged from 60 to 260 cm FL (measured weights ranged from 1.4 and 125 kg, but

not all fish were weighed and the largest estimated at 200 kg). Statistically, the weights of the wildcaught sturgeon fit tightly (r2 = 0.986) to a third-power function of FL. In 2016 over fourteen days, 86 white sturgeon were captured on 112 setlines (0.77 fish/line or 6.1 fish/day). Of the 86 captures, 16 were suspected wild-origin fish (having neither a PIT tag nor scute scar). Of these, 10 were <108 cm FL and classified as juveniles, and six were between 178 and 260 cm FL (no wild-origin fish were between 109 and 177 cm). Of the 16 wild-origin fish, 14 had not previously been captured and were affixed with PIT tags. Two were recaptures, having been previously captured during 2015 or 2016 juvenile indexing, the latter having been implanted with an acoustic tag. Aging (pectoral-fin ray) of wild juveniles captured in 2015 and 2016 suggested that fish were born in 2011 or 2012. The presence of large adult fish and juveniles that assigned to the years 2011 and 2012 suggest that recruitment occurred within the Wells Project after the monitoring that took place in 2003 and 2004 but does not occur on an annual basis and therefore may be somewhat limited. 2.0 COLUMBIA BASIN CONSERVATION AQUACULTURE Within the native range of white sturgeon in North America, early attention has been placed on the advancement of a specific type of sturgeon hatchery involved in what is termed conservation aquaculture. Essentially these facilities are used as tools for the recovery of endangered or depressed sturgeon species/stocks. Given the issues associated with legislation regarding endangered species in North America (the Endangered Species Act in the U.S. and the Species at Risk Act in Canada), it is deemed unacceptable to stock large numbers of generic-stock white sturgeon as a method to recover endangered populations. Instead, a conservation aquaculture program was developed that factors in issues/concerns such as genetic make-up, genetic swamping, interaction with adjacent populations, breeding plans, family numbers, propensity for spontaneous autopolyploidy, etc., as compared to a typical hatchery where production numbers and fish health are the dominant concerns. Further the use of wild caught larvae as the source of supplementation and a period of hatchery rearing, often termed repatriation, has been increasingly relied upon as a tool to reboot struggling white sturgeon populations and minimize genetic risks associated with conventional aquaculture programs. At present, the four white sturgeon conservation aquaculture programs, excluding the Wells Program, presently operating in the Pacific Northwest are: 1. The Kootenai Tribe of Idaho currently operates two conservation aquaculture hatcheries to restore Kootenai River White Sturgeon and Burbot. The first hatchery, the Kootenai Tribal Sturgeon Hatchery, was constructed in 1991, on the Kootenai River near Bonners Ferry, Idaho. The second facility, the Twin Rivers White Sturgeon and Burbot Hatchery, was completed in 2014, and is located about 6 miles upstream of Bonners Ferry at the confluence of the Kootenai and Moyie Rivers. Both facilities are used for the Kootenai White Sturgeon recovery program. The newest hatchery has allowed for an increase in genetic contribution from the wild adult population to annual hatchery year classes by providing more broodstock holding, and more unique family rearing space. Also, the new facility has the capability to accelerate growth of hatchery-reared juveniles, which results in higher post-release survival. Most recently, the facility relies upon a factorial mating scheme involving 10 females and 30 males per year; and tests wild broodstock and hatchery-reared juveniles for autopolyploidy prior to spawning and releasing hatchery fish (Shawn Young; Kootenai Tribe of Idaho Pers Comm 2017). 2. Kootenay Trout and Sturgeon Hatchery (KTSH) at the upper end of Lake Koocanusa near Wardner, B.C and run by the British Columbia Ministry of Environment (BCMOE). This facility

was originally a trout hatchery and was expanded in 1998 as a failsafe facility to raise sturgeon for the Kootenai white sturgeon recovery program and in 2002 commenced production for the Upper Columbia White Sturgeon Recovery program. In 2014 this program switched from a factorial mating scheme, to a wild caught egg and larvae program that uses repatriation to meet recovery goals. 3. The Washington Department of Fish and Wildlife (WDFW), Spokane Tribe of Indians, and Colville Confederated Tribes established an aquaculture program in Washington in 2003 at WDFW s Columbia Basin Hatchery (CBH) in Moses Lake to assist with the Upper Columbia White Sturgeon Recovery program. All fish produced in the Washington program were released into the Washington section of the Transboundary Reach of the Columbia River. Initially the Washington program utilized Upper Columbia white sturgeon juveniles, and then eggs and larvae provided from the KTSH. The Washington program became self-sufficient in 2006 when they began collecting and spawning their own adult broodstock. Spawning activities were conducted at the WDFW Sherman Creek Hatchery located near Kettle Falls, WA. The progeny from these fish were raised at the CBH before being released into the Washington section of the Transboundary Reach of the Columbia River. Beginning in 2010, the Washington program experimented with the capture of wild larvae as an alternative to brood capture. After positive results, the program discontinued adult broodstock capture and shifted their entire production to wild caught larvae in 2011. Steady progress has been made in this program with much efficiency realized. For example, from 2014-2017 this program has captured over 30,000 larvae on an annual basis. Larvae captured during this program have been furnished to Douglas PUD to be reared at the Wells Fish Hatchery with as many as 17,000 wild caught larvae transported to this facility annually from 2013-2017. 4. In 2009, the Yakima Nation initiated construction of a white sturgeon culture facility at Marion Drain near Toppenish, WA. This facility received its first broodstock (from McNary Reservoir) in late spring 2010 and is presently rearing sturgeon to be out planted in 2018 as part of the Priest Rapids WSMP and Rocky Reach WSMP. Fish from Marion Drain have been reared at Wells, Chelan Falls, and Columbia Basin Hatcheries in some or all of the years spanning 2011-2017. The facility relies on a factorial mating scheme but has piloted capture of wild caught larvae from the lower Columbia River reservoirs in the year 2016-2017. The ultimate goal of each conservation aquaculture program is to ensure the continued existence of the population while attempting to maximize genetic diversity and keep hatchery-produced fish as wild as possible. This approach is fundamentally different from a traditional fish production facility. 3.0 ORIGINAL WSBBP PLAN DEVELOPMENT The goal of the WSMP was to promote growth of the white sturgeon population in the Wells Project area to a level that was commensurate with the available habitat and characterized by a diverse age structure consisting of multiple cohorts (juvenile and adult). The WSBBP was a key component of the WSMP and its implementation has been the initial step toward increasing the white sturgeon population in the Wells Reservoir. Based upon the available information on the white sturgeon population segment (as summarized in Section 2.0), the Aquatic SWG agreed that efforts should focus, initially, on supplementation efforts to increase the population within the Wells Reservoir in order to address Project effects. Once the population numbers have been increased to a level that can be studied, as determined by the Aquatic SWG, Douglas shall implement a monitoring and evaluation program (see Section 1.4) to

accurately assess natural recruitment, juvenile habitat use, emigration rates, carrying capacity, and the potential for natural reproduction so as to inform the scope of a future, long-term supplementation strategy. The White Sturgeon Broodstock Collection and Breeding Plan supported the following objectives as outlined in the WSMP: Objective 1: Supplement the white sturgeon population in order to address Project effects, including impediments to migration and associated bottlenecks in spawning and recruitment; Objective 2: Determine the effectiveness of the supplementation activities through a monitoring and evaluation program; Objective 3: Determine the potential for natural reproduction in the Wells Reservoir in order to appropriately inform the scope of future supplementation activities; Objective 4: Adaptively manage the supplementation program as warranted by the monitoring results and in consultation with the Aquatic SWG. In order to meet these objectives, Douglas, in consultation with the ASWG, developed and began implementing a WSBBP in Year 1 of the ten year Phase 1 of the implementation of the WSMP. The desired end point was augmentation and maintenance of the sturgeon population through supplementation in order to provide a stable future population. The following assumptions were considered in the preparation of the original WSBBP: natural reproduction was present but appears to be insufficient in the foreseeable future to maintain a stable or increasing population of sturgeon in the Project area; the carrying capacity of the Project area was substantially greater than existing white sturgeon population levels; recruitment to the existing white sturgeon population, at levels necessary to sustain or increase the populations, will require supplementation of the existing population; 4.0 DOUGLAS BROODSTOCK AND LARVAE COLLECTION The WSMP, the WSBBP, and various Aquatic SWG Agreements between 2012 and 2015 summerize white sturgeon program requirements and summarize the programs successful history to date. These various documents and successes are summarized below. The Wells WSMP states, The initial source of brood stock shall be determined within the first year of issuance of the new license. Collection of brood stock shall occur consistent with the brood stock collection plan in years 1-4 of the new license. Any additional years during the Phase I program (first ten years of the new license) in which brood stock collection shall occur in order to facilitate additional juvenile stocking into the Wells Reservoir (Section 4.1.2) will be determined by the Aquatic SWG. The intent of brood stock collection is to use their progeny, if feasible, for future white

sturgeon stocking activities in the Wells Reservoir. The brood stock collection plan shall be updated annually, or as otherwise recommended by Douglas in consultation with the ASWG, to incorporate new and appropriate information. Given the requirement to use a broodstock collection plan to meet WSMP supplementation goals, the WSBBP was developed in concert with the Aquatic SWG and approved by the FERC on May 28, 2013. In addition to requiring the WSBBP development, the WSMP called for the release of up to 5,000 juveniles/year for four years into Wells Reservoir, and was therefore reflected in the 2012 WSBBP, In consultation with the Aquatic SWG, yearling fish for release shall be acquired from appropriate wild Columbia River sources. Sturgeon for supplementation may be obtained through the collection of gametes from adult broodstock and/or collection of wild larval, subyearling and/or yearling fish. Gametes and/or fish younger than yearlings will be grown out to yearlings in an artificial production environment. Specifically, the 2012 WSBBP favored a 6 x 6 factorial mating scheme but allowed for a 3x3 breeding matrix if broodstock were limited, but also allowed wild caught larval drift techniques to support the supplementation targets. Following the review and FERC approval of the WSBBP, Douglas received two proposals to provide gametes and larvae in order to meet the supplementation goals described in the WSMP. Following lengthy discussions the Aquatic SWG approved an SOA that supported both use of wild caught larvae and offspring secured from conventional broodstock techniques that lead to preferred factorial crosses as follows: The Aquatic Settlement workgroup (Aquatic SWG) agrees that Douglas PUD should implement a dual strategy for the collection of white sturgeon offspring starting in the spring/summer of 2013. This approach will include the implementation of wild larval collection and adult brood collection programs. This two program approach will be utilized for four years toward identifying the best strategy for the long-term supplementation of white sturgeon in the Wells Project. The Aquatic SWG will evaluate program implementation and progress towards achieving the objectives of the White Sturgeon Management Plan on an annual basis and make any adjustments, if necessary. Douglas PUD developed contracts with both the Yakama Nation and Colville Confederated Tribes, which led the conventional brood program and wild origin larvae program, respectfully. To support the collection effort, an SOA approved on March 20, 2013 provided locations where the two programs would target their efforts. During the spring of 2013 a successful 3x3 and 1x3 mating schemes were achieved at the Marion Drain Sturgeon Hatchery using the conventional broodstock approach. In addition, approximately 8,000 BY2013 wild caught larvae, predominately captured from the transboundary reach of Lake Roosevelt, were delivered to the Wells Fish Hatchery. Offspring from both programs were reared at Wells Fish Hatchery in 2013 and early 2014. Together, approximately 2,400 wild caught larvae and 2,600 broodstock origin fish were planted within the Wells Project to meet the 5,000 fish target in 2014 and at the consensus of the Aquatic SWG (See Table 1).

Following a successful first year of supplementation in 2014 the Aquatic SWG thought it prudent to develop some guidance for supplementation in subsequent years remaining under the dual program approach. As such, in February 2015 the Aquatic SWG developed an agreement titled, White Sturgeon Source and Stocking Considerations, which provided the following guidelines for the remaining three years (2015-2017) of stocking: 1. Consistent with the Broodstock and Breeding Plan and recent genetic findings (Drauch Schreier et al. 2013), it is allowable that white sturgeon brood stock and/or larvae can be collected from the US-Canada trans-boundary reach of the Columbia River downstream to the face of Bonneville Dam. Entities involved in collection efforts are responsible for addressing non-technical concerns, such as closed fishing areas due to conservation and jurisdictional issues. Fishing will be conducted in areas where success is most likely based on previous efforts and estimated numbers of adult spawners, in order to improve the chances of successfully capturing target numbers, maximizing genetic diversity, and ultimately achieving the (up to) 5,000 fish release annual target. 2. All available healthy wild larvae origin fish will be used first toward achieving the (up to) 5,000 fish release target. a. If wild larvae collected from more than one Columbia River reservoir are available for release into Wells Pool, the ASWG will discuss and approve a composite stocking strategy that utilizes all available sources. 3. Direct gamete origin fish will be used to make up the program balance. 4. If no larvae are available and less than 18 half-sibling crosses are produced then a reduced (i.e., <5,000 yearlings) and pro-rated number of direct gamete origin white sturgeon yearlings will be released into the Wells Reservoir. In this situation, the ASWG will discuss and reach unanimous consensus on the reduced and pro-rated number of white sturgeon juveniles to be released into the Well Reservoir. 5. Fish of different sources may be stocked at a smaller or larger size, as was applied in BY 2013, at the unanimous consent of the Aquatic SWG. This tool may be used to further prioritize genetic diversity and assumes improved survival for larger stocked fish. If unanimous consent cannot be obtained the default will be stocking all program types at the same size, and on a similar timeline. 6. In years where 5,000 fish cannot be achieved, the subsequent year s release goal may be adjusted upward in an attempt to make-up for the reduced stocking number in the previous year. The prioritization described in steps 1 4 will apply to these make-up fish. Unanimous consent from the ASWG would also be required. 7. All fish health related decisions will be consistent with the WDFW White Sturgeon Fish Health Plan (May, 2014). The guidelines developed above were employed during the remaining three years (2015-2017) of stocking. In all three years healthy wild caught larvae were available in excess of program needs after a year of rearing these white sturgeon at Wells Fish Hatchery and therefore release groups in the years 2015-2017 were made up exclusively of wild caught larvae (Table 1).

5.0 WSMP PHASE I SUPPLEMENTATION GOALS The annual supplementation target for the WSMP is up to 5,000 yearling white sturgeon annually for four consecutive years (up to 20,000 fish total). The numbers of juvenile sturgeon to be stocked during the remainder of Phase I would be determined by the Aquatic SWG and would not exceed 15,000 juvenile sturgeon (total of up to 35,000 juvenile sturgeon during Phase I). 5.1 Progress to Date Following releases in June 2017 Douglas PUD and the Aquatic SWG met this goal during the first four years of the program (see Table 1). In anticipation of meeting the 20,000 fish target the Aquatic SWG began discussions in the summer and fall of 2016 towards developing stocking targets in the years 2018-2022. Many considerations were used to determine stocking rates, which included, but were not limited to, recent monitoring and evaluation data, adult density data from the Bonneville Reservoir, the Wells Reservoir surface area, expected survival at given release sizes and years at large, exploitation (harvest) rates, slot limits, estimated size of existing population, recruitment limitations, and size and age at maturity. 5.2 Population Model Scenarios The modeling approach that was used in 2016 to determine stocking rates in the years 2018-2022 followed similar methods that were employed during the development of the WSMP. During the relicensing process, population trajectories were modeled for the white sturgeon populations in Wells Reservoir with a simple age-structure demographic model using: i) hypothetical hatchery and wild sturgeon recruitment rates; ii) existing data on abundance, growth, maturation, and juvenile and adult survival; and iii) the assumptions inherent in the most recent version of the model developed for use in the Upper Columbia River. The scenario represented expected population responses to supplementation measures (i.e., releasing 5,000 hatchery-raised juveniles annually for 4 years into Wells Reservoir and 2,500 juveniles per year for the remaining 6 years of the 10-year Phase 1 program). Because of the approximate 25 to 30 year age until full maturation (assumed to be age-25 for the baseline model), the existing adult population was projected to decline to very low numbers over the next 30 year period even with the immediate release of hatchery-reared juveniles. Subsequently, it was expected that adult numbers would build as hatchery sturgeon mature and recruit to the adult population. Unknown during modeling was the number of wild origin recruits that would be produced by the hatchery origin fish as they recruited into the adult spawning population and as such assumptions were made in early modeling. 5.2.1 Baseline Population During relicensing of the Wells Project a baseline scenario was modeled based on the following assumptions: an initial wild population of 34 fish; a stocking rate of 5,000 juveniles per year for the first 4 years (commencing in 2014) with 2,500 juveniles per year for the following 6 years; zero natural recruits per year for the first 25 years and then 200 natural recruits per year after 25 years; females maturing at age-25; and

population metric data (e.g., growth, survival, size-at-maturity, etc.) from adjacent white sturgeon populations in the upper and middle Columbia River. This scenario produced an initial rapid population increase to approximately 1,800 adults by 2045, with a subsequent decline in population to the target level of approximately 1,000 adults by 2060 when the progeny of the hatchery adults would start to mature and begin to contribute to the wild population (Figure 1). Assuming a 1:1 sex ratio of fish surviving to adulthood, approximately half of the adults would be mature females of which about 115 would spawn in any given year (assuming a 5-year spawning interval for females) by 2045 and decline to 80 females by 2060 (Figure 2). Restoration of a relatively stable sturgeon age distribution for this scenario was expected in approximately 50 years based on a natural recruitment rate after 25 years of 200 age-1 fish annually (Figure 3).

Figure 1 Projected future wild and hatchery adult white sturgeon population size following implementation of a baseline supplementation scenario in Wells Reservoir. Figure 2 Projected future reproductive potential of white sturgeon following implementation of a baseline supplementation scenario in Wells Reservoir.

Figure 3 Projected changes in sturgeon age composition following implementation of a baseline supplementation scenario in Wells Reservoir. Parties that participated in the modeling exercise also realized that maintenance of an adult population size of more than 1,000 adults may not be achievable or desirable in Wells Reservoir. Monitoring of the population status and growth would be required to identify and mitigate negative density-dependent effects on growth and survival. To help manage adult numbers through time, a controlled harvest for sub-adults can be used as a means to adjust future population levels of adult white sturgeon. Using the model above and applying a 5% annual harvest commencing 10 years after the initial stocking and targeting the 100 150 cm FL size-class (pre-spawners), would reduce the maximum population size to 1,400 adults. If this harvest were increased to 10% for this size-class, total maximum population would be approximately 1,200 adults. Both these estimates assume constant levels of natural recruitment after 25 years. 5.2.2 Modeling Exercises in 2016 Following a successful first four years of sturgeon supplementation within the Wells Reservoir, technical leads within the Aquatic SWG met to review white sturgeon population model and model inputs in October 2016. The model and draft inputs were generally agreed to by all participants. The following key assumptions were made during the exercise: The population of white sturgeon in the Bonneville Reservoir (lower Columbia River) was used as an example of a healthy population of white sturgeon where density dependence observations were likely occurring. The Aquatic SWG used the Bonneville pool surface area as a tool to estimate the expected healthy population of adult white sturgeon within the Wells Reservoir and within a reduced Project surface area. Using this method a target of 1,000-1,100 adults within the Project resulted. (Bonneville s surface area is 1.94 times bigger than the Wells Project area at 7,632 ha compared to Wells at 3,941 and Bonneville was estimated to have ~2200 adult sized fish at the time).

Since no new natural population estimate had been conducted the Aquatic SWG agreed that the original population estimate of 34 was suitable for the purposes of this exercise. Although the majority of wild fish captured during recent monitoring and evaluation efforts within the Wells Reservoir appeared to be less than 10 years old, less than 20 of these fish were encountered. Therefore, the Aquatic SWG agreed that not enough information was available to estimate natural recruitment. Further, if natural recruitment is occurring it is probably not occurring in most years with very few fish produced in years that it occurs. As such they agreed to leave the recruitment estimate at 0 for the new modeling exercise. The Aquatic SWG agreed to model for 50 years of supplementation (slightly longer than the license term, however the Aquatic SWG recognized that management actions and M&E data will revise the stocking schedule in advance of the 50 year period making the term somewhat arbitrary for this model exercise). Perhaps the biggest change to the original modeling that was conducted during the relicensing process was an agreement to target survival rate of 86% for white sturgeon released at 200 grams and during their first year at large. Therefore the Aquatic SWG agreed to target releasing fish 200 gram/fish (estimate of survival is based on Upper Columbia White Sturgeon Recovery Initiative M&E data specific to weight at release based survival). Further, they agreed that survival after 1 year at large is probably 98% for all subsequent years. The Aquatic SWG agreed that a harvestable size (slot) similar to that of Bonneville Reservoir slot (widest slot on Columbia River; 38-54 inches [97-137 cm]) could be used to address expected high survival of fish planted in the first four years and additional surplus that would be available from additional stocking efforts, whereby fish would be released at a greater size and have higher survival. Additionally, the group agreed that an exploitation rate of the former slot could be 25% beginning 10 years from the beginning of supplementation. The first few years of a fishery using this slot limit would have many more fish in the slot compared to years following 2028 (upfront stocking in years 1-4 are much greater than recommended stocking rates 2018 and beyond). No changes were made to the Age and Growth and Reproduction assumption that were made during the relicensing modeling exercise. 5.2.3 2017 Model Results Based on modeling, the Aquatic SWG agreed that hatchery releases beginning in year 2018 (collected in 2017) should approximate 325 age 1 fish at 200 grams/fish. This would provide 1,124 adults at year 50 (Figure 4) and approximately 200 fish a year for total harvest (recreational and tribal) within the 38-54 inch FL slot (Figure 5). The Aquatic SWG acknowledged that the target of 1,000-1,100 adults would be exceeded after 50 years even with the slot limit and exploitation rates (Figure 6). All members acknowledged that this model would feed into a 5 year Statement of Agreement (Appendix D). Additional M&E data and improved estimates of survival would feed into improved iterations in subsequent years.

Figure 4. Expected relationship of juveniles, subadults and adult white sturgeon in the Wells Project through time using stocking targets of 325 fish per year at 200g. Figure 5. Fish available for harvest in the Wells Project through time using stocking targets of 325 fish per year at 200g and considering the 20,000 fish planted before July 2017.

Figure 6. Proportional relationship of juveniles, subadults and adult white sturgeon in the Wells Project through time using stocking targets of 325 fish per year at 200g and supplementing at this rate for 50 years. In January 2017, all technical leads within the Aquatic SWG voted to approve the Statement of Agreement (Appendix D), with the exception of the Yakama Nation, which abstained from the vote: Douglas PUD will release 325 (±5%) white sturgeon 200 grams/fish into the Wells Reservoir annually between 2018 and 2022 to complete the supplementation requirement in Phase I of the White Sturgeon Management Plan (WSMP). These releases will be comprised of juveniles originating as wild caught larvae sourced from the Columbia River between Bonneville Dam and the US/Canada border. The Aquatic SWG will determine the proportional composition of each release in years when fish are captured at more than one location (reservoir) and successfully raised at the hatchery. If the stocking target is not achieved in a given year, the Aquatic SWG will discuss increasing the stocking target in the subsequent year. 6.0 CONCLUSIONS The WSMP, WSBBP, various SOAs, and the successful stocking occurring during the years of 2014-2017 has led to the development and Aquatic SWG approval of the WSSP in 2018. Members of the Aquatic SWG, including the Yakama Nation, Colville Confederated Tribes, Washington Department of Fish and Wildlife, and United States Fish and Wildlife have actively engaged in not only the development of Douglas WSSP but also to date, have participated in its successful implementation. Throughout the initial phase of implementing the WSMP, the Aquatic SWG has used the best available science and technical information to guide supplementation efforts occurring within the Wells Project (2014-2017) and have used a similar approach to the development of the WSSP that will occur within the Project (2018-2022). At the request of the Aquatic SWG, or as necessary and based on the best available data, the Aquatic SWG membership will adaptively manage this program implementation as written in the Aquatic Settlement Agreement. As necessary, and at the advice of the Aquatic SWG, the WSSP may need to be updated again in 2022 as the WSMP transitions from Phase I supplementation to Phase II restoration

efforts. The WSSP is being submitted to the FERC as an ongoing requirement to meet FERC license requirements associated with the WSMP. In summary, Douglas will collect larval white sturgeon, rear them at the Wells Fish Hatchery and then release 325 (±5%) white sturgeon at 200 grams/fish into the Wells Reservoir. These stocking efforts will take place annually between 2018 and 2022 to complete the supplementation requirement in Phase I of the WSMP. Should stocking take place at any level in the years beyond 2022, the number and approach to supplementation will follow the Phase II supplementation goals as written in the WSMP and required by Douglas Water Quality 401 Certification and FERC license requirements as associated with implementing the Aquatic Settlement Agreement. In addition, stocking efforts conducted in Phase II will follow the adaptive management protocol as described in the WSMP.

7.0 LITERATURE CITED Chelan PUD (Public Utility District No. 1 of Chelan County). 2005. Rocky Reach White Sturgeon Management Plan. Public Utility District No. 1 of Chelan County, Wenatchee, WA. Douglas PUD (Public Utility District No. 1 of Douglas County) 2008. White Sturgeon Management Plan Wells Hydroelectric Project FERC Project No. 2149. Grant PUD (Public Utility District No. 1 of Grant County) 2009. Priest Rapids Project FERC P-2114 White Sturgeon Management Plan. License Article 401(a)(11). Ephrata, WA. Drauch, A.; Börk, K.; May, B.; Rodzen, J. 2013: Development of new microsatellite markers for white sturgeon and continued genetic monitoring of the KTOI broodstock. Unpubl. technical report to Kootenai Tribe of Idaho, Award #01633, Bonners Ferry, ID, pp. 22. Jerald, T. 2007: White sturgeon (Acipenser transmontanus) population assessment in Wells Reservoir. Master s Thesis. Central Washington Univ., Ellensburg, WA. pp. 59. UCRWSRI. 2002. Upper Columbia River White Sturgeon Recovery Initiative. Draft Recovery Plan. April 15, 2002. 86p.

Appendix A Order approving 2012 White Sturgeon Broodstock and Breeding Plan

143 FERC 62,149 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Public Utility District No. 1 of Project No. 2149-155 Douglas County, Washington ORDER APPROVING WHITE STURGEON BROODSTOCK COLLECTION AND BREEDING PLAN (May 28, 2013) 1. On February 13, 2013, Public Utility District No. 1 of Douglas County, Washington (licensee) filed its White Sturgeon Broodstock Collection and Breeding Plan pursuant to article 401(a) of the license for the Wells Hydroelectric Project. 1 The Wells Project is located on the Columbia River in Douglas, Okanogan, and Chelan Counties, Washington. The project occupies lands administered by the U.S. Department of the Interior (Interior) and the U.S. Army Corps of Engineers. BACKGROUND AND LICENSE REQUIREMENTS 2. Various conditions of the license for the Wells Project require the licensee to prepare plans in consultation with specified entities for approval by the Washington Department of 1 Order Issuing New License, issued November 9, 2012 (141 FERC 62,104).

Ecology (Washington DOE), Interior, and the National Marine Fisheries Service (NMFS) without Commission approval. Article 401(a) of the license identifies a series of these plans, and requires that the plans be filed with the Commission for approval, including the White Sturgeon Broodstock Collection and Breeding Plan (sturgeon plan) required by condition No. 6.5 of Washington DOE s February 27, 2012 Section 401 Water Quality Certification, which is attached to the license as Appendix A. The requirements for the sturgeon plan are contained in section 4.1.1 of the White Sturgeon Management Plan, which is one of a series of larger plans contained in a settlement agreement that the licensee filed with its May 27, 2010 license application. 3. The larger White Sturgeon Management Plan includes, as section 4.1.2, stocking of juvenile sturgeon to increase population in Wells Reservoir. The licensee s filed sturgeon plan is a key component of the larger plan for supplying suitable juvenile sturgeon. Under the settlement agreement and the White Sturgeon Management Plan, the licensee is to prepare and implement the sturgeon plan in consultation with resource agencies and tribes that are members of the Aquatic Settlement Working Group (Aquatic SWG) established in the settlement agreement. The source of sturgeon broodstock is to be determined within the first year of issuance of the new license. Collection of broodstock is to then occur in years 1 to 4 of the new license, with additional collections during the next 6 years, as determined to be necessary by the Aquatic SWG. 4. Article 401(a) requires the licensee to include with its filed sturgeon plan documentation that the plan was developed in consultation with NMFS, the U.S. Fish and Wildlife Service, the U.S. Bureau of Land Management, the Washington Department of Fish and Wildlife, the Confederated Tribes of the Colville Reservation, and the Confederated Tribes and the Bands of the Yakama Nation, and has been approved by Washington DOE. LICENSEE S PLAN 5. Under the licensee s filed sturgeon plan, juvenile sturgeon for stocking under section 4.1.2 of the larger White Sturgeon Management Plan would be obtained through the collection of gametes from adult broodstock fish, and/or collection of wild larval, subyearling and/or yearling fish. Gametes and/or fish younger than yearlings would be grown

out to yearlings in an artificial production environment prior to release. The licensee indicates that the broodstock contribution of six male and six female spawning sturgeon, equaling six maternal families, would be the target if broodstock collection is utilized to provide all juveniles for annual stocking at levels required under the White Sturgeon Management Plan. The licensee generally describes protocols that would be used to mate white sturgeon if wild broodstock fish in breeding condition are available, and protocols that would be used if such fish are not available, to maximize genetic diversity. AGENCY CONSULTATION 6. The licensee included copies of finalized conference call minutes and copies of emails indicating that the sturgeon plan was developed in consultation with the agencies and tribes in the Aquatic SWG, which includes the agencies identified in Article 401(a). The licensee also included a copy of a February 11, 2013 email from Washington DOE indicating the agency s approval of the plan. DISCUSSION AND CONCLUSIONS 7. The licensee s sturgeon plan, filed February 13, 2013, would ensure juvenile sturgeon are available for use in restoring white sturgeon populations at the Wells Project, and is consistent with the larger White Sturgeon Management Plan between the licensee and the Aquatic AWG resource agencies and tribes. The sturgeon plan meets the requirements of Article 401(a) of the license for the Wells Project, and should be approved. The Director orders: (A) Public Utility District No. 1 of Douglas County, Washington s White Sturgeon Broodstock Collection and Breeding Plan, filed February 13, 2013, pursuant to Article 401(a) of the license for the Wells Hydroelectric Project, is approved.

(B) This order constitutes final agency action. Requests for rehearing by the Commission may be filed within 30 days of the date of issuance, as provided in section 313(a) of the Federal Power Act, 16 U.S.C. 8251 (2006), and the Commission s regulations at C.F.R. 385.713 (2012). The filing of a request for rehearing does not operate as a stay of the effective date of this order, or of any other date specified in this order. The licensee s failure to file a request for rehearing shall constitute acceptance of this order. Steve Hocking Chief, Environmental Review Branch Division of Hydropower Administration and Compliance OEP/DHAC Yarrington, B. Peter: bpy 05/23/2013 041

Appendix B Wells White Sturgeon Offspring Collection Plan Statement of Agreement (SOA) May 2012 for Implementation in 2013-2016

Wells White Sturgeon Offspring Collection Plan Statement of Agreement (SOA) May 2012 for Implementation in 2013-2016 Statement The Aquatic Settlement workgroup (Aquatic SWG) agrees that Douglas PUD should implement a dual strategy for the collection of white sturgeon offspring starting in the spring/summer of 2013. This approach will include the implementation of wild larval collection and adult brood collection programs. This two program approach will be utilized for four years toward identifying the best strategy for the long-term supplementation of white sturgeon in the Wells Project. The Aquatic SWG will evaluate program implementation and progress towards achieving the objectives of the White Sturgeon Management Plan on an annual basis and make any adjustments, if necessary. If necessary and appropriate, the Aquatic SWG will use adaptive management as defined in the Aquatic Settlement Agreement (ASA) to make such adjustments. By the end of year four of these efforts (July 2016), the Aquatic SWG will have developed evaluation criteria, evaluate the results of the first four years of the two programs, and identify the best long-term regional offspring collection strategy for the Wells sturgeon supplementation program.

Background The Aquatic Settlement Agreement, White Sturgeon Management Plan (WSMP) requires that Douglas PUD fund the collection of white sturgeon offspring starting in 2013 toward the release of up to 5,000 juvenile sturgeon per year starting in the summer of 2014 and up to 20,000 by 2017. The intent of this program is to increase the abundance and genetic diversity of white sturgeon found within the Wells Project. In an effort to develop the most effective and beneficial long-term sturgeon supplementation strategy, Douglas PUD is proposing to implement dual offspring collection evaluation. This combined approach will utilize two primary offspring collection methods including both wild larval collection and wild adult broodstock collection strategies. The goal of this study is to identify the best long-term supplementation strategy that will maximize the successful out planting of the required numbers of juvenile sturgeon and the genetic diversity of the offspring released into the Wells Project. Both programs will be funded by Douglas PUD for four years (2013-2016). Both the larval collection and the broodstock collection programs will be funded equally during the first two years. Larval fish or fertilized eggs will be delivered to Wells Hatchery within one day following capture or fertilization. Fish/gametes will be isolated from one another according to Washington Department of Fish and Wildlife (WDFW) fish health requirements, and permitting to transfer fish will be obtained to follow other WDFW guidelines. Over this four-year period the Wells Hatchery will be designed to accommodate up to 6 maternal family units produced from wild broodstock (derived from a partial or full factorial mating strategy that includes up to 6 male and 6 female parents) and up to an additional 6 larval collection groups. It is highly probable that over this four-year program differential success will occur among and within programs. To address differential success within and between programs the Aquatic SWG will be consulted annually to determine the numbers of fish to be stocked from each maternal family and collection group. Douglas PUD will participate in the Regional White Sturgeon Technical Working Group. Technical information shared in this group may be brought to the ASWG by any regional white sturgeon technical workgroup member in order to assist in making informed decisions through adaptive management. The Aquatic SWG will evaluate program implementation and progress towards achieving the objectives of the White Sturgeon Management Plan. Aquatic Settlement Agreement signatories will make unanimous adjustments as required to remain consistent with the Aquatic Settlement Agreement.

Appendix C White Sturgeon Source and Stocking Considerations Aquatic SWG White Sturgeon Collection and Stocking: Brood Years 2014-2016. Public Utility District No. 1 of Douglas County

White Sturgeon Source and Stocking Considerations Aquatic SWG White Sturgeon Collection and Stocking: Brood Years 2014-2016. Public Utility District No. 1 of Douglas County May 2014 Introduction The goal of the White Sturgeon Management Plan (WSMP), included in the Wells Project License, is to increase the sturgeon population in the Wells Reservoir to a level that can be supported by the available habitat and is characterized by diversity in age structure and genetics. Adaptive management is part of the procedure to attain that goal. The FERC license for the Wells Project, issued in 2012, requires Douglas to release up to 5,000 white sturgeon yearlings into the Wells Reservoir annually for four consecutive years (20,000 fish total). To accomplish this goal a dual faceted approach of collecting white sturgeon larvae and using a conventional brood stock program was approved by the parties to the Aquatic Settlement Work Group (Aquatic SWG) and funded by Douglas PUD. In 2013, the Confederate Tribes of the Colville Reservation (Colville Tribes) successfully collected approximately 5,000 white sturgeon using drift net collection, mainly from Lake Roosevelt (FDR). After 11 months of rearing, over 2,100 of the FDR larval fish survived in the Wells Hatchery and are scheduled for release into the Wells Reservoir in June of 2014. The Colville Tribes also spent considerable time attempting to collect larval sturgeon in the Wanapum Reservoir. Specifically, the majority of their efforts were expended at the Wanapum Reservoir sites representing 82.5% of the total larval collection effort in 2013. Unfortunately, only 53 sturgeon larvae were collected from the Wanapum Reservoir over 1,892 frame hours, representing 0.28 fish per hour of collection effort 2. In February 2014, 18 of the surviving Wanapum sturgeon were released into the Wells Project. The Wanapum fish were released early in order to more efficiently utilize the rearing tanks at the hatchery toward reducing the rearing densities for the more abundant FDR larval fish In addition to larvae, approximately 70,000 fertilized eggs from 12 half-sibling family groups were made available for rearing at the Wells Fish Hatchery in 2013. These offspring were the result of efforts coordinated by the Yakama Nation, Mid-Columbia PUDs, and Aquatic SWG stakeholders. These fish exhibited very high survival at the Wells Hatchery. The high rate of survival resulted in the need to cull large numbers of fish from the program in order to maintain suitable rearing densities. Large numbers of these fish were also shipped out of the Wells Hatchery to other regional hatcheries to help augment programs that had been compromised by poor rearing conditions. In total, 2,900 of the direct gamete origin fish were released into the Wells Reservoir in the spring of 2014 counting toward a total program release target of 5,000 fish when combined with the larvae program. Direct gamete origin fish from brood year (BY) 2013 are primarily offspring from adults captured from below McNary Dam in May of 2013. One female used as broodstock came from the Wanapum Reservoir in 2013. 2 Final Minutes of the August 14, 2013 Aquatic SWG Conference Call

Many technical and non-technical issues were discussed and addressed in arriving at the agreed upon collection methods and the subsequent release strategy for 2014 (BY 2013). They included: 1. Fish Source 2. Collection Ease 3. Cultural Boundaries 4. Fish Health 5. Genetics 6. Stocking Goals Taking into consideration the above list of issues, the Aquatic SWG will follow the protocol below in order to prioritize collection and meet program goals for sturgeon stocking in years 2015-2017. Stocking and Collection Prioritization Rules 2014-2017 1. Consistent with the Broodstock and Breeding Plan and recent literature (Drauch Schreier et al. 2013), it is allowable that white sturgeon brood stock and/or larvae can be collected from the US-Canada trans-boundary reach of the Columbia River downstream to the face of Bonneville Dam. Entities involved in collection efforts are responsible for addressing non-technical concerns, such as closed fishing areas due to conservation and jurisdictional issues. Fishing will be conducted in areas where success is most likely based on previous efforts and estimated numbers of adult spawners, in order to improve chances of successfully capturing target numbers, maximizing genetic diversity, and ultimately achieving the (up to) 5,000 fish release annual target. 2. All available healthy (see item 7 for health determination) wild larvae origin fish will be used first toward achieving the (up to) 5,000 fish release target. a. If wild larvae collected from more than one Columbia River reservoir are available for release into Wells Pool, the ASWG will discuss and approve a composite stocking strategy that utilizes all available sources. 3. Direct gamete origin fish will be used to make up the program balance. 4. If no larvae are available and less than 18 half-sibling crosses are produced then a reduced (i.e., <5,000 yearlings) and pro-rated number of direct gamete origin white sturgeon yearlings will be released into the Wells Reservoir. In this situation, the ASWG will discuss and reach unanimous consensus on the reduced and pro-rated number of white sturgeon juveniles to be released into the Well Reservoir. 5. Fish of different sources may be stocked at a smaller or larger size, as was applied in BY 2013, at the unanimous consent of the Aquatic SWG. This tool may be used to further prioritize genetic diversity and assumes improved survival for larger stocked fish. If unanimous consent cannot be obtained the default will be stocking all program types at the same size, at the same locations, and on a similar timeline. 6. In years where 5,000 fish cannot be achieved, the subsequent year s release goal may be adjusted upward in an attempt to make-up for the reduced stocking number in the previous year. The prioritization described in steps 1 4 will apply to these make-up fish. Unanimous consent from the ASWG would also be required. 7. All fish health related decisions will be consistent with the WDFW White Sturgeon Fish Health Plan (May, 2014).

Literature Cited Drauch Schreier, A., B. Mahardja, and B. May. 2013. Patterns of population structure vary across the range of the White Sturgeon. Transactions of the American Fisheries Society 142:1273 1286.

Appendix D Statement of Agreement Wells Reservoir White Sturgeon Supplementation Plan (2018-2022)

Statement of Agreement Wells Reservoir White Sturgeon Supplementation Plan 2018-2022 Date: January 11, 2017 Douglas PUD will release 325 (±5%) white sturgeon 200 grams/fish into the Wells Reservoir annually between 2018 and 2022 to complete the supplementation requirement in Phase I of the White Sturgeon Management Plan (WSMP). These releases will be comprised of juveniles originating as wild caught larvae sourced from the Columbia River between Bonneville Dam and the US/Canada border. The Aquatic SWG will determine the proportional composition of each release in years when fish are captured at more than one location (reservoir) and successfully raised at the hatchery. If the stocking target is not achieved in a given year, the Aquatic SWG will discuss increasing the stocking target in the subsequent year.

Background From 2014-2016 Douglas PUD released >15,000 yearling white sturgeon into the Wells Project. In 2017, an additional 5,000 yearling white sturgeon are expected to be released into the Wells Project. Following the initial four years of stocking (up to 20,000 white sturgeon) the White Sturgeon Management Plan (WSMP) limits additional stocking in license years 5-10 to no more than a total of 15,000 additional fish. During the summer and fall of 2016 the Aquatic Settlement Work Group (Aquatic SWG) considered several factors when determining how many white sturgeon to stock during the reminder of the WSMP s Phase I to meet the up to 15,000 fish guideline. These factors included, but were not limited to, recent monitoring and evaluation data, adult density data from the Bonneville Reservoir, the Wells Reservoir surface area, expected survival at given release sizes and years at large, exploitation (harvest) rates, slot limits, estimated size of existing population, recruitment limitations, and size and age at maturity. After reviewing these factors and information, the Aquatic SWG agreed to the following principles: Estimated carrying capacity of the Wells Reservoir for adult white sturgeon is approximately 1,100 fish (>165 cm fork length) based on applying the density of adults (fish/ha) in the Bonneville Reservoir to the Wells Reservoir surface area. Estimated that the first year post-release survival for 200 g fish would be 86% based on monitoring data developed as part of the Upper Columbia White Sturgeon Recovery Initiative. Annual survival rates for 2+ year-old fish are estimated to be 98%. Exploitation rate was assumed to be 25% within a 40 cm harvest slot; thus the projected combined (tribal and recreational fisheries) harvest rate would equalize at approximately 210 fish each year following higher rates in the first 4 years due to the larger numbers of fish initially released. A preference for using wild caught white sturgeon larvae to meet stocking goals. Considering the assumptions listed above, as well as all other input variables (i.e., growth functions), the modeling exercise indicated that releasing approximately 325 white sturgeon at 200 grams each on an annual basis would meet the Wells Reservoir adult population goals during and after the term of the license. The Aquatic SWG agreed to start with these production rates initially in WSMP stocking years 5-10 and reconsider stocking rates as monitoring and evaluation data becomes available. Recent research suggests that white sturgeon populations are not differentiated genetically from the Bonneville Pool to the transboundary reach of the Columbia River (Hugh Keenleyside

Dam, British Columbia), that fish are more related based on reservoir proximity, and that gene flow has historically occurred in a downstream direction. Based on this information, the Aquatic SWG concluded that larval white sturgeon captured from any of the Columbia River reservoirs between the Bonneville Dam and the US/Canada border are acceptable for supplementing the Wells Reservoir.

Exhibit B Pre-filing consultation record for the White Sturgeon Supplementation Plan

Notice to the Aquatic Settlement Workgroup to Review the White Sturgeon Supplementation Plan

From: Kristi Geris <kgeris@anchorqea.com> Sent: Wednesday, February 21, 2018 3:57 PM To: Andrew Gingerich; Bob Rose; Chas Kyger; Donella Miller (mild@yakamafish-nsn.gov); Jason McLellan; John Ferguson; Kristi Geris; Mark Peterschmidt (mape461@ecy.wa.gov); Patrick Verhey (Patrick.Verhey@dfw.wa.gov); Ralph Lampman (lamr@yakamafishnsn.gov); Sean Goudy (gous@yakamafish-nsn.gov); 'Steve Lewis'; Zimmerman, Breean (ECY) Subject: FW: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 Attachments: 2018_02_21 Douglas - Draft White Sturgeon Supplementation Plan Feb 2018.doc Follow Up Flag: Flag Status: Follow up Completed Hi ASWG Technical Leads: please see the email below from Andrew and the attached Draft White Sturgeon Supplementation Plan, which is available for review with edits and comments due to Andrew by COB Wednesday, March 28, 2018. The attached draft plan is also available for download from the Aquatic SWG Extranet Site, under: Documents > All by Mtg Date > 3/14/2018 (instructions below). Thanks! kristi Instructions: To gain access to the Aquatic SWG Extranet Homepage, please use the following procedure: * Visit: https://extranet.dcpud.net/sites/nr/aswg/ * Login using Forms Authentication (for non-douglas PUD employees) You should now be at the Aquatic SWG homepage. If you encounter problems, or need a login username and password to access the site: Please feel free to contact me, Andrew Gingerich, or Julene McGregor [jmcgregor@dcpud.org; (509) 881-2236] and we will gladly assist you with questions or issues. Kristi Geris ANCHOR QEA, LLC kgeris@anchorqea.com C 360.220.3988 Original Message From: Andrew Gingerich [mailto:andrewg@dcpud.org] Sent: Wednesday, February 21, 2018 3:40 PM To: Kristi Geris <kgeris@anchorqea.com> Subject: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 Hi Kristi, please distribute to technical leads within the Aquatic SWG. Please find attached a draft White Sturgeon Supplementation Plan. The document is a revised, updated, and retitled form the "Broodstock Collection and Breeding Plan." The original document was developed in 2012, approved by the Aquatic SWG, submitted to the FERC, and approved by FERC in 2013. The document was originally required to be submitted to the FERC within one year of license issuance as found in Article 401(a) of the license. Since the approval, 1

Douglas PUD and the Aquatic SWG have met a 4 year up front stocking goal, agreed to various SOAs and documents, and expanded our technical knowledge/approach. In addition, this year we are on target to release larger but far fewer fish into the Project. According the White Sturgeon Management Plan, "The brood stock collection plan shall be updated annually, or as otherwise recommended by Douglas in consultation with the ASWG, to incorporate new and appropriate information." It seems appropriate to summarize the last four year's success and update this document based on the information we have shared/discussed over that period. As such, the draft document for consideration is attached. Douglas PUD suggests a 30+ day review with comments due by EOB March 28, 2018. We'll discuss this document during the March 14, 2018 conference call and ask for approval during the April 11, 2018 conference call. Please let me know if you have questions. Respectfully, Andrew Andrew Gingerich Senior Aquatic Resource Biologist Public Utility No. 1 of Douglas County 1151 Valley Mall Parkway East Wenatchee, WA 98802 Office: (509) 881 2323 Your message is ready to be sent with the following file or link attachments: Douglas White Sturgeon Supplementation Plan Feb 2018 Note: To protect against computer viruses, e mail programs may prevent sending or receiving certain types of file attachments. Check your e mail security settings to determine how attachments are handled. 2

Email from the Colville Confederated Tribes Suggesting Edits to the White Sturgeon Supplementation Plan

From: Jason McLellan (FNW) <Jason.McLellan@colvilletribes.com> Sent: Tuesday, March 27, 2018 11:56 AM To: Andrew Gingerich Cc: Kristi Geris (kgeris@anchorqea.com) Subject: RE: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 Attachments: 2018_02_21 Douglas - Draft White Sturgeon Supplementation Plan Feb 2018 CCT.doc Follow Up Flag: Flag Status: Follow up Completed Thanks for the reminder. Suggested edits are attached. From: Andrew Gingerich [mailto:andrewg@dcpud.org] Sent: Tuesday, March 27, 2018 7:54 AM To: 'Kristi Geris' <kgeris@anchorqea.com>; Bob Rose <rosb@yakamafish nsn.gov>; Chas Kyger <chask@dcpud.org>; Donella Miller (mild@yakamafish nsn.gov) <mild@yakamafish nsn.gov>; Jason McLellan (FNW) <Jason.McLellan@colvilletribes.com>; John Ferguson <jferguson@anchorqea.com>; Mark Peterschmidt (mape461@ecy.wa.gov) <mape461@ecy.wa.gov>; Patrick Verhey (Patrick.Verhey@dfw.wa.gov) <Patrick.Verhey@dfw.wa.gov>; Ralph Lampman (lamr@yakamafish nsn.gov) <lamr@yakamafish nsn.gov>; Sean Goudy (gous@yakamafish nsn.gov) <gous@yakamafish nsn.gov>; 'Steve Lewis' <stephen_lewis@fws.gov>; Zimmerman, Breean (ECY) <bzim461@ecy.wa.gov> Cc: 'Chad Jackson' (chad.jackson@dfw.wa.gov) <chad.jackson@dfw.wa.gov> Subject: RE: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 Hi all. Just a friendly reminder that we are seeking comments on this document. The comment period expires tomorrow. Appreciate your review. Respectfully, Andrew 509 881 2323 Andrew Gingerich Senior Aquatic Resource Biologist Public Utility No. 1 of Douglas County 1151 Valley Mall Parkway East Wenatchee, WA 98802 Office: (509) 881 2323 From: Kristi Geris [mailto:kgeris@anchorqea.com] Sent: Wednesday, February 21, 2018 3:57 PM To: Andrew Gingerich; Bob Rose; Chas Kyger; Donella Miller (mild@yakamafish-nsn.gov); Jason McLellan; John Ferguson; Kristi Geris; Mark Peterschmidt (mape461@ecy.wa.gov); Patrick Verhey (Patrick.Verhey@dfw.wa.gov); Ralph Lampman (lamr@yakamafish-nsn.gov); Sean Goudy (gous@yakamafish-nsn.gov); 'Steve Lewis'; Zimmerman, Breean (ECY) Subject: FW: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 1

Hi ASWG Technical Leads: please see the email below from Andrew and the attached Draft White Sturgeon Supplementation Plan, which is available for review with edits and comments due to Andrew by COB Wednesday, March 28, 2018. The attached draft plan is also available for download from the Aquatic SWG Extranet Site, under: Documents > All by Mtg Date > 3/14/2018 (instructions below). Thanks! kristi Instructions: To gain access to the Aquatic SWG Extranet Homepage, please use the following procedure: * Visit: https://extranet.dcpud.net/sites/nr/aswg/ * Login using Forms Authentication (for non-douglas PUD employees) You should now be at the Aquatic SWG homepage. If you encounter problems, or need a login username and password to access the site: Please feel free to contact me, Andrew Gingerich, or Julene McGregor [jmcgregor@dcpud.org; (509) 881-2236] and we will gladly assist you with questions or issues. Kristi Geris ANCHOR QEA, LLC kgeris@anchorqea.com C 360.220.3988 Original Message From: Andrew Gingerich [mailto:andrewg@dcpud.org] Sent: Wednesday, February 21, 2018 3:40 PM To: Kristi Geris <kgeris@anchorqea.com> Subject: Emailing: Douglas White Sturgeon Supplementation Plan Feb 2018 Hi Kristi, please distribute to technical leads within the Aquatic SWG. Please find attached a draft White Sturgeon Supplementation Plan. The document is a revised, updated, and retitled form the "Broodstock Collection and Breeding Plan." The original document was developed in 2012, approved by the Aquatic SWG, submitted to the FERC, and approved by FERC in 2013. The document was originally required to be submitted to the FERC within one year of license issuance as found in Article 401(a) of the license. Since the approval, Douglas PUD and the Aquatic SWG have met a 4 year up front stocking goal, agreed to various SOAs and documents, and expanded our technical knowledge/approach. In addition, this year we are on target to release larger but far fewer fish into the Project. According the White Sturgeon Management Plan, "The brood stock collection plan shall be updated annually, or as otherwise recommended by Douglas in consultation with the ASWG, to incorporate new and appropriate information." It seems appropriate to summarize the last four year's success and update this document based on the information we have shared/discussed over that period. As such, the draft document for consideration is attached. Douglas PUD suggests a 30+ day review with comments due by EOB March 28, 2018. We'll discuss this document during the March 14, 2018 conference call and ask for approval during the April 11, 2018 conference call. Please let me know if you have questions. Respectfully, Andrew 2

Andrew Gingerich Senior Aquatic Resource Biologist Public Utility No. 1 of Douglas County 1151 Valley Mall Parkway East Wenatchee, WA 98802 Office: (509) 881 2323 Your message is ready to be sent with the following file or link attachments: Douglas White Sturgeon Supplementation Plan Feb 2018 Note: To protect against computer viruses, e mail programs may prevent sending or receiving certain types of file attachments. Check your e mail security settings to determine how attachments are handled. 3

Email from the Washington Department of Fish and Wildlife Suggesting Edits to the White Sturgeon Supplementation Plan

From: Sent: To: Subject: Attachments: Follow Up Flag: Flag Status: Verhey, Patrick M (DFW) <Patrick.Verhey@dfw.wa.gov> Thursday, March 29, 2018 4:07 PM Andrew Gingerich 2018_02_21 Douglas - Draft White Sturgeon Supplementation Plan Feb 2018.doc 2018_02_21 Douglas - Draft White Sturgeon Supplementation Plan Feb 2018.doc Follow up Completed Andrew, Chad provided some comments on the Draft White Sturgeon Supplementation Plan. Patrick Verhey WDFW Habitat Program Energy and Major Projects Division Biologist 1550 Alder St N.W. Ephrata, WA 98823 Office (509) 754 4624 ex. 213 Cell (509) 431 8296 Patrick.Verhey@dfw.wa.gov Work schedule is M Th 1

Aquatic Settlement Work Group Conference Call Meeting Minutes from April 11, 2018 Explaining Revisions to the White Sturgeon Supplementation Plan and Obtaining Approval of the Revised Plan

FINAL Conference Call Minutes Aquatic Settlement Work Group To: Aquatic SWG Parties Date: May 9, 2018 From: John Ferguson, Chair (Anchor QEA, LLC) Re: Final Minutes of the April 11, 2018 Aquatic SWG Conference Call The Aquatic Settlement Work Group (SWG) met by conference call on Wednesday, April 11, 2018, from 10:00 a.m. to 12:45 p.m. Attendees are listed in Attachment A of these conference call minutes. I. Summary of Action Items 1. 2. 3. Ralph Lampman, Steve Lewis, and Patrick Verhey will discuss within the Priest Rapids Fish Forum, Rocky Reach Fish Forum, and Aquatic SWG coordination of regional Pacific Lamprey translocation efforts by Grant, Chelan, and Douglas PUDs (notably trapping timing, number of fish tagged, and release locations in 2018; Item VI-1). Aquatic SWG members will discuss within their respective agencies what to include in the draft Douglas PUD Pacific Lamprey Translocation Statement of Agreement (SOA) and their position on the SOA regarding evaluations and implementation of in-ladder modifications at Wells Dam to be discussed during the Aquatic SWG meeting on May 9, 2018 (Item VI-3). The Aquatic SWG meeting on May 9, 2018, will be held by conference call (Item VII-2). II. Summary of Decisions 1. Aquatic SWG members present approved the White Sturgeon Supplementation Plan, as revised, with the Yakama Nation (YN) abstaining (Item VI-2). III. Agreements 1. There were no agreements discussed during today s conference call. IV. Review Items 1. The draft report, Evaluations of White Sturgeon Supplementation and Management Plan Implementation in the Wells Reservoir, 2014-2017, was distributed to the Aquatic SWG by Kristi Geris on March 20, 2018. This document is available for a 42-day review with edits and comments due to Andrew Gingerich by May 1, 2018 (Item VI-4).