BPA Contract 55349. Environmental compliance for this project includes both Section 106 cultural consultation and federal Section 7 ESA consultation (USFWS and NOAA). MSRF has secured funding through Reclamation to complete the SEPA and JARPA permitting processes. Cultural and ESA consultation are not included in MSRF's budget with Reclamation and cannot be delayed until funding would be available through the BPA targeted solicitation process. Time constraints are further exacerbated by the weather in the Methow, which requires that field work for S. 106 generally be completed prior to the end of November. If the November window is missed, the field work could not be completed until snow melt, which could be as late as May, and would eliminate the opportunity to modify project designs to accommodate cultural concerns. To meet the planned start time of July1st, 2012 for instream construction on the first two scheduled M2 project areas (Whitefish Island and WDFW Floodplain), the BA needs to be submitted to USFWS no later than the end of January to receive a BiOp by June. As a BA is time consuming to prepare, it is necessary to start it well in advance of the January submission deadline.

The goal of this M2 pre-implementation contract would be to complete BPA's EC requirements ahead of the UCSRB targeted solicitation in order to ensure completion of these requirements within their respective timelines to allow construction to proceed in the summer 2012 work window.