This proposal is a key part of the Hood River Production Program (HRPP), which also includes a fish production and monitoring and evaluation project (198805303). The proposal was comprehensive and informative. It clearly described current and emerging issues affecting fish populations and aquatic habitat and a generally strategic effort to accomplish meaningful restoration at the whole watershed scale. Innovative use of Intrinsic Potential Assessment to identify priority areas for future restoration was described. Discussion and analyses of the potential impacts of climate change on stream flow and stream temperature and associated potential responses were very informative. Findings on the effectiveness of past work in achieving desired habitat conditions were also particularly useful. Finally, the table showing increased total steelhead smolt production from 1994 to present demonstrates benefits from the HRPP projects. A positive trend appears to begin around 2000. Unfortunately, there is no formal analysis of these data. Additional statistical analysis of these data and discussion regarding links to the restoration program should be included in the proposal.

In future annual reports and work plans, the proponents need to provide information to address the following Conditions:

1. Implementation and outcome objectives. Describe activities and outcomes for the time period 2023-2027. Particular focus should be to provide quantitative and time-bound outcome descriptions for Objective 2 (spawning and rearing habitat) and the four sub-objectives linked to it. Objectives for project maintenance, public outreach/ information sharing, and project-scale monitoring and evaluation should also be provided.
2. Strategic plan. Provide a concise description of the strategic plan that guides priority setting and implementation of this program. Include a list or analysis of prioritization of sites and projects proposed based on a quantitative model, EDT, or other technique to guide setting priorities.
3. Standard Operating Procedures. Provide a more detailed description of Standard Operating Procedures (SOPs) or a more detailed description of methods associated with the six specific objectives.
4. Coordination. Provide additional detail on coordination within the HRPP, particularly with the CTWS monitoring and evaluation project 198805303. More detailed information on findings to date regarding fish responses to restoration work at the watershed/subbasin scale and at project and/or reach scales is needed. Also, opportunities for improved coordination with the habitat restoration project should be addressed.
5. Trends in steelhead smolt production. Provide statistical analysis of the changes in steelhead smolt production from 1994 to present and discuss the implications of the trends for the restoration program.

Note: A qualification from the ISRP's 2007-2009 Project Review to “develop and implement monitoring and evaluation of the fish response to habitat related actions” has not yet been adequately addressed. The proponents are aware of this and state that they are waiting for direction from BPA regarding monitoring protocols to more fully assess the effectiveness of habitat restoration projects. Please provide a description of this once an agreement is reached with BPA.

Q1: Clearly defined objectives and outcomes

The proposal provides a detailed discussion of the major factors affecting aquatic habitat and the associated primary limiting factors to steelhead production. Four primary Limiting Factors and 14 Contributing Factors/Threats are listed in Figure 3. From these emerge the proposed activities to address them. The proponents provide a clear history of their work and report a modest level of results and EDT model outputs (found in the subbasin plan) to demonstrate issues, progress, and a logical framework for moving forward. Although steelhead are the target species, the Hood River has one of the most diverse assemblages of anadromous and resident fish in Oregon. The proposal provides very informative maps showing the distribution of species of particular interest.

There has been a recent review of limiting factors in the Hood River basin in state and federal recovery plans and the Subbasin Plan (ODFW 2010, NMFS 2013, USFWS 2015, Coccoli 2004) and their incorporation into the most recent strategic action plan for the watershed (Thieman 2021). This review is supplemented with findings from a number of past assessments and investigations in the basin including a Total Maximum Daily Load (TMDL) study of approaches for reducing stream temperatures, an assessment of riparian vegetation and potential for introduction of large wood on the 170 miles of stream in the watershed, opportunities to increase summer stream flows, and use of an Intrinsic Potential Assessment to identify specific stream reaches with high potential for benefits from future habitat restoration. Additional plans supporting the work of the Hood River Habitat Project include the Wy-Kan-Ush-Mi-Wa-Kish-Wit: Spirit of the Salmon and the Hood River Subbasin Summary. Unfortunately, it is not clear if there is a primary overarching strategic plan that synthesizes and unifies key elements of the plans to guide the project.

More detail is needed to better describe how the specific sites and activities are tied to a strategic list of projects to elevate the overall habitat improvement for the subbasin. The proposal contains three tables (Table 4 for water conservation actions, and Tables 5 & 6 for some project prioritization) that provide a qualitative linkage to physical objectives, but no quantitative, desired biological responses for proposed restoration treatments. Specifically, providing this information would really take the proposal to a higher level of usefulness.

A single primary biological objective (Objective 1) provides quantitative fish production targets for all species and identifies the long-term, desired outcome for the project. Objective 1 is accompanied by five other physical habitat objectives, most of which generally meet SMART criteria, although their listed time for completion (2042) is well beyond the timeline for this proposal. Objective 2, which addresses spawning and rearing habitat provides four sub-objectives describing type location and amounts of restoration work to be accomplished. Unfortunately, there are no quantitative objectives describing desired outcomes for these spawning and rearing habitat restoration activities. Also, despite stating that the proponents will continue to monitor physical habitat responses to individual restoration projects, using accepted protocols, no objectives for project monitoring and evaluation are provided. Finally, there are no objectives for project maintenance or public outreach and information sharing.

Q2: Methods

General methods for project prioritization are provided and describe a series of information resources and considerations used by the Technical Advisory Committee. These include aerial photography, Intrinsic Potential Assessment (Appendix B), fish use, and knowledge of site conditions and potential. Although there is no single, formal process described for priority setting, there is discussion of how general restoration opportunities have been prioritized using the Atlas model. It is not clear whether a single restoration plan/strategy is used to guide the process.

Q3: Provisions for M&E

A positive feature of the proposal is that Project monitoring has been adequate to demonstrate that desired physical outcomes have been achieved for most projects. There is an ongoing program for project implementation and effectiveness monitoring, but the proposal provides no detail regarding implementation monitoring. For effectiveness monitoring, the proposal states that the proponents will monitor physical habitat responses to restoration projects using accepted protocols to gauge the effectiveness of project activities. There is a list of the methods for various physical parameters and links to the protocols used. This includes the use of photo points and canopy measurements recorded for riparian vegetation for assessing the effectiveness of fencing and planting projects. For example, this monitoring has shown that the large wood placement projects, particularly those implemented in the last five years, have resulted in desired increases in spawning gravel, pool frequency, and pool area. These parameters could be used to describe or make predictions about desired future outcomes for restoration of spawning and rearing habitat (Objective 2).

There is little discussion of links to ongoing biological monitoring being done in the basin by other projects. For example, this challenging and long-standing issue is the first qualification from the ISRP’s 2007-2009 Project Review to “Develop and implement monitoring and evaluation of the fish response to habitat related actions.” The proponents say they are waiting for direction from BPA regarding monitoring protocols to assess the effectiveness of habitat restoration projects in meeting their FRCPS Biological Opinion obligations. It is noted that this project is one of three HRPP projects and that the focus of project 198805303 is to monitor the natural production of steelhead trout and Chinook salmon in the basin and to use this information in “determining fish distribution, providing context for habitat restoration efforts, and tracking population status and trends of fish in the watershed to potentially document the influence of habitat restoration activities on fish abundance.” There is no mention of formal data/ information sharing or coordination activities among the three projects. Additional detail on this coordination is needed, especially given that past reviews have identified it as a condition for the project.

The primary tool for making project adjustments is The Hood River Watershed Group (HRWG), which meets annually. These meetings include staff from the CTWS, USFS, and ODFW to review monitoring data related to habitat program effectiveness and lessons learned from implementing current or past-year projects. If projects have not yielded expected ecological outcomes, they are discussed in detail to develop suggestions for alternative implementation strategies. There is no mention of any other activities such as field visits, project design reviews or general coordination and information sharing meetings, which could broaden the scope of current adaptive management.

Q4: Results – benefits to fish and wildlife

Active protection and restoration of aquatic habitat in the Hood River basin has been ongoing since 1998. The proposal provides details for a range of past accomplishments. This includes accomplishments tied to a diversity of restoration treatment types including fish passage, riparian fencing, instream treatments, road decommissioning, water conservation and stream flow additions, and work with private landowners to reduce the introduction of toxic materials into streams. The removal of Powerdale Dam substantially expanded the range and number of lamprey in the system, and the HRPP has been documenting this recovery. However, more description would be useful of biological responses to other target fish species populations (especially native species) following dam removal.

Information addressing the effectiveness of past restoration work was particularly useful for this review. Project monitoring results have shown positive outcomes for most restoration actions. Examples include findings that large wood placement projects, particularly those implemented in the last five years, have shown desired increases in spawning gravel, pool frequency, and pool area (Eineichner 2020). Also, results from riparian buffer plantings and education on pesticide Best Management Practices (BMP’s) appear to be continuing to maintain lower pesticide levels in streams. The proposal states that, “a summary table of project effectiveness results was not possible for this proposal due to HRPP staff transitions.” Unfortunately, quantitative descriptions describing desired outcomes for some of the work, especially spawning and rearing habitat improvement, were not provided in the proposal.

An informative table in the section on Responses to Past Reviews illustrates the abundance of wild steelhead smolts (= 150 mm FL) by age category to the mainstem rotary screw trap (rm 4.5) from 1994 to the present (courtesy of Phil Simpson). Although no statistical analysis of the data is provided, the data potentially show a positive trend in total smolts from about year 2000 to the present. Additional detail and analysis of biological sampling would be very useful to summarize and include in future annual reports and proposals for this project.

The comments and questions in the sections below are intended to assist the sponsors in improving their project. The ISRP does not request a response.

1. Purpose: Significance to Regional Programs, Technical Background, and Objectives

The Hood River Fish Habitat Project responds to goals and objectives in the following regional plans/programs: Western Hood Subbasin Total Maximum Daily Load (DEQ, 2002), ESA Recovery Plan for Lower Columbia Steelhead (NMFS, in progress), ESA Recovery Plan for Hood River Bull Trout (USFWS, 2002), Hood River Subbasin Plan for Fish and Wildlife (NPPC 2004), plus others.

This project focuses primarily on restoring spawning and rearing habitat for Chinook and steelhead in the Hood River subbasin. Categories of actions include increasing instream flows during the irrigation season, monitoring water quality for agricultural chemicals (used primarily by fruit growers), restoring access to blocked habitat, and increasing channel complexity through large wood additions. The project is in its 15th year and seems reasonably well integrated into other restoration programs in the Columbia Gorge area.

The technical background and problem statements were explained in general terms, but it would have been helpful to provide more details about the extent and nature of habitat degradation. For example, why has there been an extensive effort to re-introduce large wood into the stream network (how far below wood loading targets is the system currently)? Overall, however, the project sponsors have placed their restoration emphasis on addressing obvious problems and their objectives seem clear and well grounded.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

Accomplishments to date are summarized primarily as miles of channel restored, for example treated in some way to achieve habitat targets such as wood loading, pools per mile, area of suitable spawning gravel, miles of stream made available through barrier removal, or additional stream-flow during the irrigation season. Summaries of habitat improvements in the proposal clearly explained what has been done in the past.

How the restoration sites were prioritized and ultimately selected in the Hood River subbasin was somewhat less clear. The proposal does not mention if the EDT analyses were used to prioritize habitat improvement activities, although later in the proposal it is stated that Intrinsic Potential (IP) modeling formed the basis for some of the wood addition projects.

We wish there were a summary of the status and trends of fish populations in the Hood River. The ISRP called for monitoring of fish response to habitat actions in our 2007 review of this project, but the linkage between restoration and population improvements appears to have remained unexamined. Perhaps fish monitoring is taking place as part of other projects, but if so it would have been very helpful to have shown the connection between the habitat work here and what others are learning about population trends.

Fish passage projects completed include installation of two fish screens on irrigation diversions, upstream migrant passage restoration on the Middle Fork Hood River, and preliminary design for a diversion replacement on the East Fork Hood River. Without a presentation of the extent of the problem and the extent to which past efforts have been successful, it is not easy for reviewers to assess these activities. No mention is made of fish abundance. Nevertheless, it seems reasonable progress is likely being made with regard to this objective.

The ISRP was also concerned about the potential effects of residualized hatchery Chinook on naturally produced fish, and the proposal suggests that hatchery residualism might not be as high as formerly thought. Even though the results are stated to be preliminary, it still would have been helpful to see the evidence.

Adjustments in the water quality sampling program in response to what was learned from prior chemical monitoring is an excellent example of adaptive management and shows that the project sponsors have been willing to change their water quality monitoring protocols to address key questions.

Evaluation of Results

Over a decade and a half this project has accomplished an extensive number of habitat protection and restoration actions. Results of these actions as far as the physical characteristics have been adequately reported in the current proposal in the format of summary tables and in annual reports to BPA.

In the ISRP FY07 review of this project the following recommendations were made:

"FY07 review: A history of watershed assessment and prescription within the Hood River indicates good planning, based on previous Provincial reviews, and has served as an example for other studies. Lacking to date, however, is an understanding of results in terms of benefits to fish. There is an ongoing fish M&E effort in the subbasin that this project might have drawn from, but benefits to fish and wildlife were not indicated in the proposal or response. The lack of fish data and results within the proposal or the response is viewed by the ISRP as a serious concern. In addition, the reporting of activities towards achieving project goals was lacking, and only a short list of activities exists for the time since commencement (1998).

The response leads to the ISRP recommendation of "Fundable (Qualified)" with the qualification that sponsors: (a) develop and implement monitoring and evaluation of the fish response to their habitat-related actions and (b) assess the extent to which the residualism of hatchery steelhead is resulting in the displacement of wild fish from Hood River habitat. It is expected that much of both tasks will be done in close conjunction with projects 198805303 and 198805304."

In response, the sponsors provided an adequate discussion of results from project 198805303 indicating the level of impact of hatchery steelhead on wild steelhead. But no information was included responding to the request for M&E data to measure/evaluate the habitat benefits to fish. The only statement was that the project was waiting for BPA to provide funding to meet their obligations for monitoring. The sponsors should at least coordinate with ODFW project 198805304 to summarize such information and see if changes in fish population status may be correlated with timing of habitat work. The last report from this ODFW project (2011) provided extensive fisheries data regarding the current status of steelhead and Chinook populations in the subbasin. The opportunity to discuss how the habitat restoration work completed may have affected the current status should be explored.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Restoring summer water flows, reducing herbicide and pesticide inputs, eliminating passage barriers, and increasing channel complexity are the main emphases of this project and in general the proposal does a good job of explaining how project staff has worked well with local landowners, irrigation districts, DEQ, and the Forest Service to accomplish objectives. Emerging limiting factors such as glacial recession leading to lower summer flows and the spread of invasive riparian and aquatic species are touched upon, but strategies for dealing with them are not identified.

Tailored questions are answered briefly.

4. Deliverables, Work Elements, Metrics, and Methods

Overall, the description of deliverables was reasonably complete. There were a few questions, however:

1) What is the anticipated benefit (in CFS to the Hood River) of the combined water conservation and irrigation efficiency actions?

2) The proposal suggests that thousands of logs will be introduced into the channel network over the next four years. Will this wood be anchored to prevent downstream movement, or if not, is there any concern that the mobilization of large quantities of wood during a severe storm could endanger capital structures downstream of the restoration?

3) A few more details about the engineered side channel in the lower Hood River would be helpful. Is it anticipated that the channel will need annual maintenance to continue to function as intended?

4) What species of plants will be planted in riparian buffers between orchards and the stream channels? What, if any, steps will be taken to reduce browse damage on these plants?

Specific comments on protocols and methods described in MonitoringMethods.org

Protocols and methods have been entered in MonitoringMethods.org and are completed with adequate details for all objectives.

===========QUALIFICATIONS FOLLOW================

The two issues below may be addressed in contracting and focused on in future project planning and proposal development.

The proposal lacks technical background and details regarding the nature of the habitat degradation and the purpose for the extensive efforts to re-introduce large wood into the stream network. How far below wood loading targets is the system currently?

The ISRP repeats its belief that this project deserves to be coupled to a biological monitoring effort (potentially ODFW Project #198805304) so that the benefits of the restoration can be demonstrated. Further information about how effectiveness monitoring could take place should be provided.

The comments and questions in the sections below are intended to assist the sponsors in improving their project. The ISRP does not request a response.

1. Purpose: Significance to Regional Programs, Technical Background, and Objectives

The Hood River Fish Habitat Project responds to goals and objectives in the following regional plans/programs: Western Hood Subbasin Total Maximum Daily Load (DEQ, 2002), ESA Recovery Plan for Lower Columbia Steelhead (NMFS, in progress), ESA Recovery Plan for Hood River Bull Trout (USFWS, 2002), Hood River Subbasin Plan for Fish and Wildlife (NPPC 2004), plus others.

This project focuses primarily on restoring spawning and rearing habitat for Chinook and steelhead in the Hood River subbasin. Categories of actions include increasing instream flows during the irrigation season, monitoring water quality for agricultural chemicals (used primarily by fruit growers), restoring access to blocked habitat, and increasing channel complexity through large wood additions. The project is in its 15th year and seems reasonably well integrated into other restoration programs in the Columbia Gorge area.

The technical background and problem statements were explained in general terms, but it would have been helpful to provide more details about the extent and nature of habitat degradation. For example, why has there been an extensive effort to re-introduce large wood into the stream network (how far below wood loading targets is the system currently)? Overall, however, the project sponsors have placed their restoration emphasis on addressing obvious problems and their objectives seem clear and well grounded.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

Accomplishments to date are summarized primarily as miles of channel restored, for example treated in some way to achieve habitat targets such as wood loading, pools per mile, area of suitable spawning gravel, miles of stream made available through barrier removal, or additional stream-flow during the irrigation season. Summaries of habitat improvements in the proposal clearly explained what has been done in the past.

How the restoration sites were prioritized and ultimately selected in the Hood River subbasin was somewhat less clear. The proposal does not mention if the EDT analyses were used to prioritize habitat improvement activities, although later in the proposal it is stated that Intrinsic Potential (IP) modeling formed the basis for some of the wood addition projects.

We wish there were a summary of the status and trends of fish populations in the Hood River. The ISRP called for monitoring of fish response to habitat actions in our 2007 review of this project, but the linkage between restoration and population improvements appears to have remained unexamined. Perhaps fish monitoring is taking place as part of other projects, but if so it would have been very helpful to have shown the connection between the habitat work here and what others are learning about population trends.

Fish passage projects completed include installation of two fish screens on irrigation diversions, upstream migrant passage restoration on the Middle Fork Hood River, and preliminary design for a diversion replacement on the East Fork Hood River. Without a presentation of the extent of the problem and the extent to which past efforts have been successful, it is not easy for reviewers to assess these activities. No mention is made of fish abundance. Nevertheless, it seems reasonable progress is likely being made with regard to this objective.

The ISRP was also concerned about the potential effects of residualized hatchery Chinook on naturally produced fish, and the proposal suggests that hatchery residualism might not be as high as formerly thought. Even though the results are stated to be preliminary, it still would have been helpful to see the evidence.

Adjustments in the water quality sampling program in response to what was learned from prior chemical monitoring is an excellent example of adaptive management and shows that the project sponsors have been willing to change their water quality monitoring protocols to address key questions.

Evaluation of Results

Over a decade and a half this project has accomplished an extensive number of habitat protection and restoration actions. Results of these actions as far as the physical characteristics have been adequately reported in the current proposal in the format of summary tables and in annual reports to BPA.

In the ISRP FY07 review of this project the following recommendations were made:

"FY07 review: A history of watershed assessment and prescription within the Hood River indicates good planning, based on previous Provincial reviews, and has served as an example for other studies. Lacking to date, however, is an understanding of results in terms of benefits to fish. There is an ongoing fish M&E effort in the subbasin that this project might have drawn from, but benefits to fish and wildlife were not indicated in the proposal or response. The lack of fish data and results within the proposal or the response is viewed by the ISRP as a serious concern. In addition, the reporting of activities towards achieving project goals was lacking, and only a short list of activities exists for the time since commencement (1998).

The response leads to the ISRP recommendation of "Fundable (Qualified)" with the qualification that sponsors: (a) develop and implement monitoring and evaluation of the fish response to their habitat-related actions and (b) assess the extent to which the residualism of hatchery steelhead is resulting in the displacement of wild fish from Hood River habitat. It is expected that much of both tasks will be done in close conjunction with projects 198805303 and 198805304."

In response, the sponsors provided an adequate discussion of results from project 198805303 indicating the level of impact of hatchery steelhead on wild steelhead. But no information was included responding to the request for M&E data to measure/evaluate the habitat benefits to fish. The only statement was that the project was waiting for BPA to provide funding to meet their obligations for monitoring. The sponsors should at least coordinate with ODFW project 198805304 to summarize such information and see if changes in fish population status may be correlated with timing of habitat work. The last report from this ODFW project (2011) provided extensive fisheries data regarding the current status of steelhead and Chinook populations in the subbasin. The opportunity to discuss how the habitat restoration work completed may have affected the current status should be explored.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Restoring summer water flows, reducing herbicide and pesticide inputs, eliminating passage barriers, and increasing channel complexity are the main emphases of this project and in general the proposal does a good job of explaining how project staff has worked well with local landowners, irrigation districts, DEQ, and the Forest Service to accomplish objectives. Emerging limiting factors such as glacial recession leading to lower summer flows and the spread of invasive riparian and aquatic species are touched upon, but strategies for dealing with them are not identified.

Tailored questions are answered briefly.

4. Deliverables, Work Elements, Metrics, and Methods

Overall, the description of deliverables was reasonably complete. There were a few questions, however:

1) What is the anticipated benefit (in CFS to the Hood River) of the combined water conservation and irrigation efficiency actions?

2) The proposal suggests that thousands of logs will be introduced into the channel network over the next four years. Will this wood be anchored to prevent downstream movement, or if not, is there any concern that the mobilization of large quantities of wood during a severe storm could endanger capital structures downstream of the restoration?

3) A few more details about the engineered side channel in the lower Hood River would be helpful. Is it anticipated that the channel will need annual maintenance to continue to function as intended?

4) What species of plants will be planted in riparian buffers between orchards and the stream channels? What, if any, steps will be taken to reduce browse damage on these plants?

Specific comments on protocols and methods described in MonitoringMethods.org

Protocols and methods have been entered in MonitoringMethods.org and are completed with adequate details for all objectives.

===========QUALIFICATIONS FOLLOW================

The two issues below may be addressed in contracting and focused on in future project planning and proposal development.

Modified by Dal Marsters on 6/11/2013 11:54:59 AM.

A history of watershed assessment and prescription within the Hood River indicates good planning, based on previous Provincial reviews, and has served as an example for other studies. Lacking to date, however, is an understanding of results in terms of benefits to fish. There is an ongoing fish M&E effort in the subbasin that this project might have drawn from, but benefits to fish and wildlife were not indicated in the proposal or response. The lack of fish data and results within the proposal or the response is viewed by the ISRP as a serious concern. In addition, the reporting of activities towards achieving project goals was lacking, and only a short list of activities exists for the time since commencement (1998).

The response leads to the ISRP recommendation of "Fundable (Qualified)" with the qualification that sponsors: (a) develop and implement monitoring and evaluation of the fish response to their habitat-related actions and (b) assess the extent to which the residualism of hatchery steelhead is resulting in the displacement of wild fish from Hood River habitat. It is expected that much of both tasks will be done in close conjunction with projects 198805303 and 198805304.

There is a need to evaluate the biological benefits of the work because some of the work might be confounded by residualized steelhead. It is important to ensure that the benefits to wild salmon and steelhead are fully realized. Effective investigation is required to document the assumed benefits, at least from some representative sites. Furthermore, a more comprehensive demonstration of the scale of work needed in the subbasin relative to the ability to reach their objectives is required, and some indication of where they are on achieving their goals. No solid evidence of an increase in fish production (smolt yield or wild parr densities) is presented.

More detail on the project sponsor's response is provided here below with questions from the ISRP original review followed by ISRP comment on how well the sponsors responded.
1) "There is no discussion of how fish populations have changed as a result of project activities." The response was brief and inadequate. A limited amount of data on steelhead (only) smolt trends was presented in three figures, which indicated that there has been no detectable response that could be attributed to habitat improvements. The typical response was "not determined at this time" or "project not completed."

2) "It is recommended that the proponents submit an addendum that states clearly what benefits have accrued from the expenditures to date, before further funding is agreed. What is the in-stream juvenile response?" In the response, benefits were briefly discussed, largely based on assumptions about the fish response to habitat work. No data on the instream juvenile response was indicated.

3) "What is the impact of residual males? What is the interaction with the habitat improvement work and its evaluation?" A description of the smolt release and monitoring process was briefly described. There was no indication that an adequate search and evaluation of residualized steelhead occurs - the assumption is that fish that fail to leave the acclimatization site (released elsewhere) represent the residuals, but there may be many residuals that leave the acclimatization site with smolts but then remain in the river, with the consequences previously described in our review. There remains a need to explore this and its interaction with habitat work.

The information provided in the response disagrees with information provided by Underwood et al. (2003), to which the response refers. Under "Hatchery Residuals," Underwood et al. (2003) report:

"An uncertain number of released hatchery steelhead residualized and did not contribute to the adult steelhead fishery or spawning population. Little data were available to estimate this proportion. However, Blouin (2003) found that up to 30% of parents of F1 generation steelhead returning to the Hood Basin had not in previous years passed Powerdale Dam. This indicated that a potentially substantial amount of steelhead returns to the Hood Basin were strays, or a large amount of steelhead production was being derived from resident rainbow trout or residual hatchery steelhead. Steelhead straying in the Hood Basin was thought to be low, and the degree of residualism versus anadromous production from resident rainbow was unknown, so we conservatively assumed that 5% of the released hatchery steelhead residualized." They go on to estimate that a hatchery residual had the potential to displace approximately 10 wild parr. An estimated 5% rate of residualization among releases of very large numbers of hatchery steelhead smolts equates to a potential for several thousand residual parr, thus a substantial impact to wild parr and to utilization of wild parr habitat and the improved habitat from this project. Many of these residual parr likely die or contribute little to wild production after displacing wild parr.