FY 2000 proposal 199705700

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: Disagreement on availability of broodstock; Mainstem passage conditions

Reviews and recommendations

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

Comment:

Comments: This proposal requires greater detail and clearly stated objectives with provisions for monitoring and evaluation of results. The CBFWA evaluations included the comment that the "Proposal is vague and does not provide a complete project description." Except in describing other projects (Sec. 8c), it addresses fishery resource problems only in the vaguest of terms. Its content is directed toward developing a rather unspecified method of artificial propagation and description is lacking of any results of previous funding in 1996-98. There is no clear discussion of method other than a listing of several possible "low-tech" culture techniques. Monitoring methods are equally vague and there is little evidence of planning here. The authors neglect to justify the proposed costly expenditures on facilities, equipment, travel, etc. Hatchbox technologies could be tested on a much smaller scale. There is no provision for cost sharing.

The technical intent has some admirable qualities (e.g., "low tech"), but the applicants' explanations are naïve and do not show convincingly how it would solve a resource problem. Stream-side incubators a) have received favorable media attention and suggest increasing local awareness of the issue and b) have involved many young people in the process, but their biological efficacy should be assessed and compared with other options before the program is expanded. As it stands, the project is almost purely activity-oriented rather than fishery-results-oriented, and thus appears to be busy work. Additionally, with a budget request of $913K, the proposal would be "low tech" at a very high price.

The Abstract notes that "based upon scientific principles and theory for recovery of naturally reproducing native fish species, proposed methods involve reforming and redirecting existing hatchery programs and practices in conjunction with the addition of small, relatively inexpensive (streamside and satellite) facilities to incubate eggs and provide volitional releases of naturally acclimated juvenile fish." Nowhere in the proposal are any scientific principles or theory stated. Some of the proposal's review of general problems provides only equivocal argument for embracing the applicants' proposals. For example, the table on p. 10 shows "expected life history survival for different production strategies," but the source of the data is not identified.

Comment:

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Apparently confusion has been created because the work toward a broad-scale "Salmon River Salmon and Steelhead Master Plan" (SRSSMP) is mixed in with one of its components, the narrower "Salmon River Production Program" (SRPP). Conducting the two as separate projects would seem to be a better approach. The sponsor says its is now at only the "first step of a detailed three-step process" that is required by the NPPC to continue funding. The first step is to develop a Master Plan for the Salmon River Basin. Such a plan does not presently exist, and will incorporate not only production actions, but also harvest and habitat requirements. There is no other project in the NPPC Fish and Wildlife Program to develop this master plan." The Master Plan should be completed before considering the SRPP. To launch into an SRPP without a complete plan would be unwise.

June 15 ISRP Comment: This proposal requires greater detail and clearly stated objectives with provisions for monitoring and evaluation of results.

Sponsor Response: "Detail is lacking because, as stated above (and as a recurring response to the ISRP comments), the project is at the first phase – development of a master plan for production (and related) actions in the Salmon River Subbasin. The scrutiny from many entities that is part of master planning will force a high level of detail to be developed during the FY 1999 funding, in preparation for initiation of implementation in FY 2000." ISRP: Here again, the plan detail ought to be settled before starting the "production."

Sponsor Response: "Objectives are clearly stated in sections 7 and 8e of the proposal: redirecting artificial production efforts to recover declining wild fish populations; constructing low-cost streamside incubation and rearing, acclimation, volitional release and broodstock holding facilities; reforming existing hatchery programs and facilities in the Salmon River; and providing fish culture education and training for SBT Tribal Members as part of the federal government's trust responsibility to treaty tribes." ISRP: Objectives should be stated in terms of desired resource outcomes, not activities to be performed.

"Specific monitoring and evaluation parameters aimed at measuring whether biological objectives are met are detailed in section 8f, including the number of eggs hatched, number of fish released, survival at life stage, adult returns, and natural reproduction success of returning adults." ISRP: The first two of these are within-hatchery results, not resource outcomes. The last three correctly state intent to measure resource outcomes.

June 15 ISRP Comment/Question: Its content is directed toward developing a rather unspecified method of artificial propagation and description is lacking of any results of previous funding in 1996-98.

Sponsor Response: "BPA funding for this project started in May, 1998 (as stated in section 8d) and was only approximately six months old when the FY 2000 proposal was submitted. Results of previous production actions (since 1995, and limited to side-stream incubation) that were funded through other sources is currently in final report development." ISRP: This work probably should not have been done before there was a master plan.

June 15 ISRP Comment/Question: Except in describing other projects (Sec. 8c), it addresses fishery resource problems only in the vaguest of terms.

Sponsor Response: "Sections 8a, 8b and 8e describe these problems – primarily, that highly technical and quantity-oriented artificial production strategies and actions have not successfully mitigated for losses of naturally-producing populations (the past and present production programs in the upper Salmon River do not include the objectives of restoring naturally-producing populations)." ISRP: Sponsor not responsive to ISRP comment. Sponsor states problems with hatchery systems. A responsive answer should identify the resource-limiting factor(s) of the Columbia River system and what the proposed project can do to reduce or circumvent one or more of those factors.

June 15 ISRP Comment/Question: Hatchbox technologies could be tested on a much smaller scale.

Sponsor Response: "They have been. For example, the Oregon STEP program, the Washington Remote Site Incubator projects, the California SASEP and Truckee River, and projects in Wyoming (Green River and Snake River). The major passage migration barriers present for Salmon River anadromous fish populations and resultant smolt-to-adult survival rates cause the test of this technology in the Salmon River to be of a larger nature than elsewhere. The urgent nature of salmon recovery in the Salmon River basin precludes proceeding on a smaller scale. Knowing that salmon (including steelhead fry) can be produced using low tech on-site incubation, but needing to work at a level of production that will allow for evaluation beyond hatch rates and numbers of fry released. Under the present conditions of high mortalities due to the disruption of migratory corridors, adequate evaluation is not possible if the project is conducted on a small scale. The program should expand to a level that will produce adequate numbers of fish to provide for suitable evaluation." ISRP: Neither the proposal nor response establish the efficacy of the programs the sponsor cites as examples. In general, hatch-box programs have not been very effective. Perhaps only one genuine study was undertaken to test results. It was in the Oregon STEP program. Results from the first 2 years showed no evidence of beneficial effect from the hatch boxes. To be conclusive, that study should have continued for additional years, but it did not. While salmon recovery in the Salmon River Basin does have elements of urgency as the sponsor notes, the sponsor failed to establish how the proposed project would remedy cause(s) of the fish population problem that exists. "Disruption of migratory corridors" should be removed or significantly reduced before production projects like the proposed one are undertaken,

June 15 ISRP Comment/Question: Stream-side incubators a) have received favorable media attention and suggest increasing local awareness of the issue and b) have involved many young people in the process, but their biological efficacy should be assessed and compared with other options before the program is expanded.

Sponsor Response: "This issue, and the necessary comparisons of other alternatives, will be an essential part of not only the master planning process, but also the NEPA and ESA requirements under Step 2 of the NPPC process." ISRP: Then the master-planning process should be finished first.

June 15 ISRP Comment/Question: As it stands, the project is almost purely activity-oriented rather than fishery-results-oriented, and thus appears to be busy work.

Sponsor Response: "The on-the-ground production activities (e.g., side-stream incubation) that is occurring while the master plan, NEPA, ESA, and engineering design and feasibility work is performed are activities that are 100% fish-resource oriented. The SBT are strong proponents of learning while doing (just do it) rather than getting mired in studies (analysis paralysis) of potential actions. Such studies are important to resolve critical uncertainties if such uncertainties prevent initiation of actions, as is monitoring and evaluation in order to adaptively manage. However, it is at least equally important to the SBT initiate to actions to help prevent the imminent extinction of Snake River wild anadromous fish populations." ISRP: Again, without the guidance of a Master Plan, the Sponsor is recommending "just do it" activities that are not justified based on the results of the previous projects that sponsor has mentioned as examples above.

June 15 ISRP Comment/Question: Nowhere in the proposal are any scientific principles or theory stated.

Sponsor Response: "Principles and theories are stated in the document: Section 8b - "highly technical production strategies have not successfully mitigated losses of natural production;" Section 8d – "initiate low-cost, low-tech alternatives and improvements to existing hatchery programs;" Section 8e – "Determine if significant adult returns and successful natural reproduction to the natural environment occur by using this technology;" Section 8e – "test whether low-tech artificial production methods can increase egg-to-fry survival over natural in-gravel incubation while increasing production from fry-to-adult compared to current hatchery strategies;" and, "utilize hatcheries to return fish to the natural environment while maintaining harvest opportunities;" and, Section 8f – "juvenile fish would be more naturally acclimated to their rearing environment as a result of volitional releases...[and] providing a more natural rearing environment is believed to increase survivals of smolt-to-adults relative to fish incubated, hatched and reared in a traditional hatchery and transported to release sites.'" ISRP: The response is mainly technique-oriented and does not speak to underlying matters, such as limiting factors. The idea of producing juveniles more acclimated to the rearing environment and providing for more natural rearing is intuitive and indeed, is a goal of many artificial production programs in the basin, as well as the focus of the NATURES approach. However, such a goal is unlikely to be achieved without rigorous experimental designs and monitoring and evaluation protocols.

Review of this proposal and the ISRP's recommendations on it have strong parallels to our review of Project 9901900, Restore the Salmon River, in the Challis, ID area, to a healthy condition. Both projects suffer from attempting to implement broadly-stated recovery and restoration goals without benefit of having a technically-defensible master plan in place. The ISRP is directed by Congress to evaluate proposals based on several criteria, including varying levels of scientific accountability. The ISRP focuses primarily on the scientific and technical merits of proposed projects. It goes against the ISRP's Congressionally-mandated directives and good scientific common sense to recommend advancement of projects for funding that do not have a comprehensive plan (or its equivalent) in place that define critical elements of project planning, experimental design, and monitoring and evaluation.

Comment:

Comment:

Discussion/Background: The overall goal of the project is to use low cost, effective, closer-to-natural production measures to reintroduce and recover anadromous fish runs in vacant and under-seeded habitats of the Snake and Salmon rivers. Based upon the latest scientific principles and theory for rapid recovery of endangered native fish species, proposed methods involve reforming and redirecting existing hatchery practices in conjunction with the addition of small, relatively inexpensive facilities to hold broodstocks and enable volitional releases of naturally acclimated fish. Emphasis to date has focused on the use of streamside hatch boxes and various acclimated juvenile releases in conjunction with other captive broodstock initiatives in the Salmon River basin. Bonneville initiated funding for this project in fiscal year 1998. During the staff discussion on July 8, 1998 and in letter form to Shoshone-Bannock Tribe on August 12, 1998, it was determined that the "production" component of this project is in an experimental stage, therefore, it is currently at the master planning stage or step 1 in the three-step process. The sponsors intend to submit together the master plan and NEPA compliance documents in May 1999. Submission of these documents will initiate the Council review process. To date, no step documents have been received.

ISRP Review: Do not fund. The response did not adequately address the ISRP concerns. The master plan development and implementation are confusingly intertwined. Completion of the master plan should precede implementation. However, here it appears implementation precedes planning. There is not a sufficient monitoring and evaluation plan to test the efficacy of the project.

Sponsor Policy Response: The SBT specified that the following criteria applied to their project. Criteria "a" due to the question of whether a master plan should precede any implementation, and extent of adaptive management. The SBT feels that their development of an "operational" master plan, implementation of adaptive management, NEPA compliance, and equivalent master plans secure this program. (See Part 1(b)(5) for description of policy criteria).

Staff Recommendation: Until completion and approval of a master plan and NEPA compliance documents as part of the three step review all activities associated with this project should be funded at a level for these specific tasks. Other activities for this project will not occur until completion of the step and environmental documents. This funding level will be maintained until the Council receives and approves the step documents that answers the technical questions as outlined in the above referenced letter. In addition, the issues raised by the ISRP in the Fiscal Year 2000 Response Review and the policies described in the Artificial Production Review Report (document 99-15) need to be addressed and made part of the step 1 review. Adequate funds ($230,180) remain in the Fiscal Year 1999 contracts to complete the master plan. Fiscal Year 1999 contracts expire on June 30, 2000, and a no-cost time extension, if needed, will authorize the SBT to complete the project. Under this current contract (Fiscal Year 1999) the SBT have a deliverable of a master plan and more than adequate funding to complete this task.

Fiscal Year 2000 funds should not be expended on the master plan. Fiscal Year 2000 funds may be considered by the Council upon completion and approval of the master plan. The Council is concurring with the ISRP recommendation. The Council is approving the use of carry-forward funds, but only for the limited purpose of completing a master plan. The Council understands the ISRP's primary criticism with the proposal to be the lack of separation from planning and implementation, and with this recommendation calling for planning only, believes that its recommendation is consistent with and addresses the ISRP's recommendation.

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