FY 2000 proposal 198335000

Section 1. Administrative

Project location

Reasonable and Prudent Alternatives (RPAs)

Section 2. Past accomplishments

Section 3. Relationships to other projects

Section 4. Budget for Planning and Design phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Planning and Design phase

Section 5. Budget for Construction and Implementation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Construction and Implementation phase

Section 6. Budget for Operations and Maintenance phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Operations and Maintenance phase

Section 7. Budget for Monitoring and Evaluation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Monitoring and Evaluation phase

Section 8. Estimated budget summary

Itemized budget

Total estimated budget

Cost sharing

Other budget explanation

Schedule Constraints: 1) Broodstock availibility may limit supplementation and recovery effort, 2) Weather may delay construction process, 3) Cultural resources mitigation may interfere with construction schedule.

Reviews and recommendations

This information was not provided on the original proposals, but was generated during the review process.

Comment:

Comments: This proposal claims to have the blessing of the ISRP (which is not true) and others, but many of the "innovative" approaches described have not been proven to yield greater survival of released fish. Furthermore, the technical-scientific background section and the rest of the proposal depend on references that are almost exclusively from gray literature rather than from the peer-reviewed open literature.

Project advocates believe they will achieve greater efficiency and effectiveness than typical hatchery operations; however, typical hatchery programs have had many generations of experience to alter their programs for efficiency and are arguably highly efficient. Only a rigorous monitoring and evaluation program will determine whether the proposers' hopes can be realized.

The proposal makes various unsubstantiated claims, such as on p. 19, lines 8-10,: "Although returns [of potential brood fish] are predicted to be extremely low for these years [1999 and 2000], the improved juvenile survival and beneficial progeny: parent return ratio offered by hatcheries justify efforts to survive [sic] the broodyear [sic] through artificial propagation." If this were so, wouldn't there be large numbers of salmon from the many, many existing hatcheries? At this point, the proposers ignore the problem of inferior post-release fitness of the hatchery-reared fish, though they acknowledge it elsewhere. Another unsubstantiated statement (beginning on next-to-last line of p. 23): "NPTH will rear fish at a density that is a third as much [as the 9.6 kg/m3 recommended by NMFS] and should impart economic efficiency to the hatchery. . .", yet the proposers do not define how the benefit will occur.

The proposers also claim that by keeping within natural "carrying capacities" they will not impact populations of wild fish. Carrying capacity is difficult to measure and altering density at any natural population level through the addition of propagated fish will no doubt influence the population in nature. They also claim they will mimic natural conditions of temperature etc., yet stream temperatures are not the same from year to year, and from site to site.

Other specific comments include: P. 22, line 5—"Phase III (11-20 years) will create opportunities for harvest. . ." Is this a departure from the hatchery's "supplementation" objective? If so, is it justified? Bottom of p. 25—A 100% FTE administrative assistant/secretary for a fish hatchery seems out of line. Top of p. 27 and budget table, p. 8—Travel cost of $36,407 seems excessive for building and beginning to operate a fish hatchery. Planning costs of $8.87M to date certainly seem excessive.

Comment:

Comment:

Comment:

Comment:

This project focuses on a largely untested concept on too large a scale. Over the last decade, the Basin has entered into 3 substantial programs that were intended to serve as experimental tests of supplementation (NEOH, Idaho, and Yakima projects); but have not yet had time to yield reliable findings. The scientific foundation for the NPT large-scale project has therefore, not been provided. The proposed activities should more directly address or at least circumvent limiting factors to salmon production.

According to instructions from Congress, the ISRP is required to assess projects in this review for their scientific validity. This is a well-written document, but it has little to do with science. Many of the assertedly "innovative" approaches have not been proven to yield greater survival of released fish than standard practice. Project advocates also claim that they will not impact populations in nature by keeping within natural "carrying capacities." Carrying capacity has proven difficult to measure and altering density at any population level with propagated fish will no doubt influence the population in nature. On the positive side, it appears the sponsors have undertaken surveys to determine carrying capacity and appear to be undertaking habitat improvement projects to absorb the hatchery-produced fish.

ISRP Specific Comments On the NPT response to ISRP comment that the proposal does not establish that the proposed activities are likely to result in benefits to fish and wildlife: NPT asserts that the proposal "establishes" that certain numbers of naturally spawning chinook salmon will result from the project, however, the figures presented in the proposal (p 20) are clearly stated as "predictions." Predictions can establish estimates and objectives, but cannot establish results. For estimates, the uncertainty involved should be indicated. The proposal gave no indication of the uncertainty of the predictions, and no statistical basis was presented for judging how accurate and precise the predictions might be. Some modeling was summarized, but whatever variabilities of data and hence output were considered were not incorporated in the summary.

On the NPT response to ISRP comment that the proposed activities are likely to cause problems for wild fish and other biota: NPT invokes the FEIS noting the previous review process from BPA and other interested parties. However, any potential adverse effects considered in the EIS were not mentioned in the proposal. Decision on starting new supplementation programs for chinook and coho should await, among other things, conclusive measurement of this potential source of damage to wild populations.

On the NPT response to ISRP comment that overcoming egg mortality in streams has not been shown to increase fish populations: The response reiterates the over-150-year-old rationale for artificial propagation in which results usually failed to meet expectations or prove cost-effective. Producing "more viable" juveniles is cited as an objective, but their lower fitness relative to naturally produced juveniles is not mentioned in the response.

In the original proposal, production of juveniles that are more fit than in conventional hatcheries and at hoped-for cost reduction is stated as an experimental objective—but such experiments are already being done on massive scales elsewhere in the basin. A "higher return per spawner" is cited in the response, but the expected high cost per returned adult is not mentioned. Hoped-for improved results from supplementation (as opposed to conventional hatchery programs) is stated, but this should be considered in the light of the three large supplementation experiments already underway in the basin (Yakima Hatchery System, NE Oregon Hatchery System, and Idaho Supplementation Program) which are intended to test supplementation's utility, but have not yet had time to yield reliable findings. Investments in further supplementation hatcheries should not be made until positive biological and economic results of the existing major programs become conclusively evident.

On the NPT response to ISRP comment that fish passage remains as an unaddressed problem to the work: The proposal admits that its results will depend (in large measure) on improved fish passage through the river system's dams and reservoirs. Clearly, programs that depend on fish passage improvements should not be undertaken until after the necessary improvements have been made, or are at least scheduled to correspond with the needs of juveniles and adults.

In this connection, the Council should consider that basic requirements for validity of any biological-resource-improvement project are (1) that the conditions primarily responsible for limiting the resource (the salmon population in this case) be identified, and (2) that it be demonstrated that the proposed project will remove those limiting conditions or circumvent them. The proposed project has not established that it will do either.

On the NPT response to ISRP comment that the proposal does not adequately describe findings from referenced studies: The response begins to mention some of the topics in the references but is in general unresponsive. The complaint that "summarizing the findings would require considerable effort" stands out. Considerable effort is warranted in view of the proposed project's enormous scale and $20-million budget request.

On the NPT response to ISRP comment that a clear monitoring and evaluation plan is not yet developed: NPT emphasis of the M&E plan by Steward (1966) is noted. We were not provided with copies of that plan, and the proposal did not summarize its main features. Much as we respect Dr. Steward, blanket references do not provide a sound basis for assessing a proposal.

On NPT response 4 questioning the need for inclusion of published literature in the review and background of the proposal: If the project is based on reasonable breadth and depth of science, then there must be more than grey literature that pertains to it. The point is, the parties involved should understand a reasonable amount of the existing, basic science that supports or contradicts the plan. A larger, particularly ecological overview is needed, not just the planning and planning studies of the sponsor and hired parties. As essential as that planning is and as massive as it may have been, it and the proposed operations must relate to underlying science in order to stay on track, and must show that in order to be credible. Often, the proposal and responses try to claim such validity by listing hoops the sponsor has jumped through but don't describe (summarize) the content involved in the hoops and don't show what the scientific basis is.

Comment:

Comment:

Discussion/Background: Project 8335000 seeks to implement construction of the Nez Perce Tribal Hatchery supplementation program to assist in the recovery and restoration of non-listed spring chinook and ESA-listed Snake River fall chinook in the Clearwater subbasin Project 8335003 proposes to continue implementation of a comprehensive ecosystem approach to monitoring and evaluation (of up to 83 performance variables) of the proposed Nez Perce Tribal Hatchery to determine success of restoring salmon populations and avoiding adverse ecological impacts in the Clearwater subbasin.

ISRP Reviews: 1) Facility construction (8335000) Do not fund in the initial and response reviews. 2) M&E (8335003) Fund in part. Those aspects of the project to collect baseline data needed to evaluate the long-term goals of enhancement in the Clearwater Basin appear valuable; however, those aspects that are dependent on the hatchery should be removed.

Policy Issues Identified by Sponsor: The NPT specified that the following policy criteria applied to their project. Criteria "a" due to what they view as an ISRP misunderstanding of the previous reviews and proposals and the ISRP's questions regarding the use of hatcheries (i.e. supplementation) for any recovery efforts in the basin. Criteria "b" due to the numerous approved and adopted program measures relating to the NPTH. Criteria "c" due to the two decades of commitment to NPTH as it directly relates to obligations imposed by the Act regarding mitigation and enhancement of fisheries resources. Criteria "e" due to the possible failure to secure the lands needed for the project. (See Part 1(b)(5) for explanation of the criteria).

Discussion and Council Recommendations: The monitoring and evaluation project and the facility project are linked. The ISRP recommendation to eliminate the hatchery-related elements of the monitoring and evaluation project was clearly made because the ISRP recommended that the hatchery itself not be built. Therefore, the Council's approach will be to treat these projects as a pair, and seek to insure consistency in its final funding recommendations.

Council members and Council staff met numerous times throughout the summer and fall to review the NPTH hatchery proposal in light of the program language, prior Council action in previous steps of the project, and the Fiscal Year 2000 ISRP recommendations. On November 10th, Council staff, NPT staff, and BPA staff met regarding the NPTH proposal. At the conclusion of this meeting, Council staff requested that the sponsor submit by November 24th a proposal including:

1. a statement indicating that it had successfully developed a "low cost/small scale" facility (not to exceed $16 million dollars) and include in that statement a list of the facilities proposed to be built and also proposed production numbers for each facility;
2. a presentation of the trade-offs associated with a reduction in the scale of the project and elimination of specific elements of the experimental design along with the associated risks;
3. a presentation on establishing "biological triggers" for consideration of subsequent phases of the facility; and
4. a brief presentation of a proposed monitoring and evaluation plan, including a plan for collaboration with the ISRP on that plan.

On November 24, 1999, the NPT responded to the Council's request for a revised project for the Nez Perce Tribal Hatchery. Documents submitted addressed all of the items requested by the Council at the November 10th meeting. The staff found, and reported to the Fish and Wildlife Committee, that the submittal captured the intent of the numerous meetings and correspondence that had occurred over the past year regarding this proposal. The NPT addressed in an adequate way the "low cost," small-scale" language of the program measure while maintaining production needs to achieve their goals and objectives. This has partially been accomplished by developing temporary and portable facilities. In addition the production numbers are complimentary to the requirements of their extensive monitoring and evaluation plan.

Fish and Wildlife Committee Review: The Committee reviewed the November 24 submission, and found it to be responsive to the elements the Council sought to have addressed. There was concern within the Committee that a statement in the narrative of the November 24 submission sought to bind the Council to future expansion of the facilities. The Committee did not believe future Councils can or should be so bound, but indicated that the Council's final approval (to proceed with construction after Step 3) should include a statement that meeting the "triggers" or "milestones" are an indication of sufficient success that the recommendation is that expansion should proceed, as this is what this Council contemplated.

The Committee had considerable concern that the biological triggers, particularly the fall chinook trigger, proposed by the NPT did not "set the bar high enough" if these milestones were supposed to be indicators of not only success of the first phase of the project, but such robust success that the project should be expanded significantly. Discussions at the Committee meeting (that included representatives of the NPT) indicated that the Council and sponsor could further discuss appropriate triggers or milestones as the project moved to final design. The Committee stated that selecting the appropriate biological triggers or milestones for future expansion is primarily a policy issue for the Council to establish, but recognized that the ISRP may help with ensuring that the technical aspects of them are appropriate. The Committee recommendation was next considered by the full Council.

Council Recommendation: The Council found the proposal detailed in the November 24 submission to be significantly reduced in scale and intensity from the original proposal. This reduction directly addressed what appeared to the Council to be the ISRP's primary criticism of the original proposal ("untested concept at too large a scale"). The Council also found significant the sponsor's willingness to work with the ISRP on the design of the monitoring and evaluation program for the facility. The Council's expectation is that this collaboration and ISRP review and approval will address many of the concerns noted by the ISRP on M&E design and implementation. Finally, the Council believes that the requirement of establishing biological triggers for possible future expansion speaks to the ISRP's criticism that expansion of supplementation experiments in the basin should await a demonstration of the success of the technique.

The Council approves expenditures to proceed with the completion of final designs and other associated tasks that are specific to the Step 3 submittal that is anticipated in March 2000. This submittal package will include the requested information as outlined in the Step 2 decision document (as outlined and supplemented in a letter addressed to Silas Whitman dated November 13, 1998). This submittal also needs to include a schedule for the estimated cost expenditures for future needs (ten years) for this project. Additionally, it is critical that this submittal follows the intent of the November 24, 1999 letter received by the Council from the Nez Perce Tribe.

Additional items that need to occur prior to a final decision on construction includes the review and approval of the M&E plan by the ISRP (submittal date - January 2000). As part of the ISRP review the Council will also request their review and advice on the "biological triggers" proposed by the Nez Perce tribe in its November 24 submittal. There are two general issues for the ISRP regarding the triggers. First, are the proposed "biological triggers" appropriate indices in light of the M&E plan? Is the M&E plan designed to function in a manner that permits the tracking of the indices? Second, the ISRP will be asked to give its advice, if possible, on the question of whether or not the standard or "bar" set for each of the indices is generally recognized as being set at a level that would indicate robust success for the artificial propagation program. To assist the Council and the ISRP in their consideration of the proposed biological triggers, the Council requests that Nez Perce staff provide Council staff with an explanation of how the proposed triggers were selected. The Council will consider the ISRP's advice on these two general issues in its effort to reach agreement with the Nez Perce Tribe on the appropriate biological triggers.

Comment:

Sponsor comments: See comment at Council's website