Document Type


Publication Title

Environmental Law

Journal Abbreviation

Env't L.


This article, written as a kind of brief to the Northwest Power Planning Council as it was considering recommendations for the Columbia Basin Fish and Wildlife Program, argued that Congress expected the Council to defer to the recommendations of the region's fish and wildlife agencies and Indian tribes, which had submitted joint comprehensive program recommendations. The article examines several statutory provisions that produced this conclusion, a position which was largely affirmed by the Ninth Circuit in its decision in Northwest Resource Information Center v. Northwest Power Planning Council in 1994 (35 F.3d 1371).

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