The ISRP requests the proponents to provide information on the following two conditions in the next annual report and future workplans.

1. Objectives and priorities. The proponents should report their strategy and progress for collaborating with the CBWTP to establish objectives and priorities for their geographic area in their annual reports during this funding period and in future proposals.

2. Scope of work. The proponents should explain the scope of work for the subset of CBWTP projects that it implements, its evaluation and adjustment process, and the location of publicly available data for their projects in the next annual report.

The response indicates that the staff in this project seek and implement on-the-ground water purchases associated with the lands of the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) that are prioritized and funded by the Columbia Basin Water Transactions Program (CBWTP). They essentially suggest that this project is Not Applicable for scientific review due to administrative decisions, and that the scientific review of the CBWTP under project 200201301 meets the requirements for scientific review. The Council staff determined that this project, funded through BPA, would be submitted for this review process. The ISRP recommends that the project continue to receive scientific review because it contains science elements and to ensure that coordination between these two BPA-funded projects meets scientific requirements. We recommend that the proponents describe the coordination of this project and the CBWTP and their collaborative development of SMART objectives. Such objectives should be summarized for the fish and wildlife species within the geographic area addressed by this project. The proposal indicates that the CBWTP and CTUIR are jointly developing quantitative objectives. Past ISRP review of this project and the CBWTP have called for development of SMART objectives. The proponents should report their strategy and progress for developing these objectives for their geographic area in their annual reports during this funding period and in future proposals.

Although the 2019 ISRP review found that the CBWTP (200201301) Met Scientific Review Criteria, the ISRP still expects the proponents of this project to explain the scope of work for the subset of CBWTP project that it implements, its evaluation and adjustment process, and the location of publicly available data for their projects. Important questions to address include: Do the proponents participate in the Project Evaluation and Adjustment activities described by the CBWTP (e.g., biannual coordination conferences)? How has progress on the development of resiliency criteria been implemented into the program?

The ISRP found it difficult to understand how the activities of this project are connected to the CBWTP and what tasks and scope are attributable to this project over the next contract period. The proposal and the response do not provide the requested information. The proponents should provide this information in the next annual report. The proposal from Idaho MOA/Fish Accord Water Transactions (200860800) may serve as a useful example of the type of information the ISRP is expecting regarding the Conditions listed above.

The ISRP agrees that the previous review of the instream flow methodology of the CBWTP (200201301) is sufficient for this review.

Preliminary ISRP report comments: response requested (Provided for context. The proponents responded to the ISRP’s questions; see response link and final review above.)

Response request comment:

The proposal describes a program for restoring flows to priority subbasins, supporting the broader CBWTP in addressing over-allocation of flows, a limiting factor for ESA-listed species. While the project has successfully secured water for rivers, several weaknesses in the proposal need to be addressed.

The ISRP requests the proponents to address the following in a point-by-point response to assist our review of the proposal:

1. SMART objectives. Please provide SMART objectives (see proposal instructions) based on intended project outcomes. Even if flow target analyses for specific reaches have not been finalized, the proponents can provide examples and explain thoroughly how the objectives for flow are determined and how they are related to intended ecological outcomes. In addition, project-based objectives may be appropriate that do not involve specific flow targets for individual reaches.

2. Scope of work. Clarity on the scope of work for the full proposed project period is needed.

3. Project evaluation and adjustment. Describe the process for how the vision and strategy for the project are developed and how the projects are evaluated and adjusted. Describe the internal process for evaluation and adaptive adjustment, including information on known decision points, explicit schedules for evaluation and decision-making, and documentation of decisions and project changes.

4. Instream flow analysis methods. Provide additional detail on the proposed methods for evaluating instream flow needs for the basin. When the proponents contract this assessment to others, how do they verify the scientific credibility of the analysis? How do these assessments include development of the natural, unimpaired flow as a context for developing the objectives and future management?

5. Publicly available database. Provide a description of the plan to create a publicly available database and the associated education and outreach capacity to accompany the database.

6. M&E matrix - support. As habitat projects and monitoring projects are not presented as part of an integrated proposal or plan, the need for a crosswalk to identify the linkages between implementation and monitoring is extremely important for basins or geographic areas. The ISRP is requesting a response from the Grande Ronde Model Watershed Project (199202601) to summarize the linkages between implementation and monitoring projects in the Grande Ronde and Imnaha geographic area. We ask this project to assist them in creating the summary and provide information to them about what is being monitored for this implementation project and where and when the monitoring occurs. A map or maps of locations of monitoring actions would be helpful in this regard.

Q1: Clearly defined objectives and outcomes

The proposal does not provide SMART objectives that are quantifiable and have explicit time frames. In the text that follows the objectives, the proponents should explain the basis or justification of each objective. The current objectives are not measurable, though some of the narrative beneath them gets close to SMART objectives. For example, the first objective is to “Improve the instantaneous rate of flow through a defined stream reach,” which is not a SMART objective. However, the text that follows the objective clarifies that the proponents aim to acquire “roughly 10 cfs in flow restoration improvements” annually, based on what they were able to achieve in the prior project period. Similarly, while Objective 3 is not a SMART biological or physical objective, it is an implementation objective of completing one flow target analysis per year.

Objective 2—“Improve the total volume of water restored to a defined stream reach over a period of time”—is more problematic, for reasons the proponents acknowledge (e.g., variation in irrigation season, difficulty in estimating total volume based on measurements, and so forth). The ISRP questions the value of this objective if it cannot be defined quantitatively or measured.

The ISRP recommends eliminating Objectives 4-6. Objectives 4 and 5 are not SMART, and Objective 6 is not a complete sentence. It is not clear what Objective 6 aims to achieve. Objective 4 does not use an accurate measure of the egg to smolt survival ratio. Egg deposition depends on the size of the adult; therefore, the number of redds will not provide an accurate estimation of eggs. In addition, data are collected by other RM&E monitoring projects. Who conducts the necessary analyses for evaluating this objective, and what trends are evident after many years of acquiring water rights? Objective 5 does not seem realistic. Increasing off channel habitat requires large quantities of water, particularly during the irrigation season. Given that Objective 1 aims to increase instream flows by only 10 cfs across the entire basin, how feasible is Objective 5?

The prior ISRP review also identified the need for defining SMART objectives. In their response this comment (page 18), the proponents point to the need to complete the flow targets analysis to define quantitative objectives. However, while flow targets for individual reaches are potentially useful for guiding the project and prioritizing efforts, these flow targets are not necessary for defining quantifiable objectives for the project itself. For example, Objective 3 reflects a project objective that is an outcome or deliverable of this project’s efforts. Are there other outcomes that this project achieves as part of the process of restoring specific flow rates in specific reaches?

As the proponents point out, no data are collected to support any objectives beyond the first two. It is hard to understand how the proponents will know if they are meeting their objectives, and thus whether their approaches should be modified.

In summary, ISRP expects quantitative objectives, such as the 10 cfs per year identified under Objective 1, that directly link to and justify project activities. Objectives 4-6 are either unnecessary, unmeasurable, or infeasible.

Q2: Methods

The methods are described in the proposal as including “the identification and acquisition of priority water rights.” The project summary on CBfish further clarifies that: “CTUIR will work with CBWTP to help provide local planning and coordination to identify instream flow project opportunities in the Umatilla and Walla Walla Basins. CTUIR will assist CBWTP QLEs and the National F&W Foundation (current BPA contractor) in researching and establishing water right purchase opportunities.” While the specific CTUIR activities associated with identifying and acquiring water rights are not described in the proposal, it is unlikely that such activities are relevant for scientific review. However, the proposal was unclear on what activities would be conducted (and by whom) under the next project period. For example, the development of the GIS-based project evaluation tool sounds useful and some details about the tool were provided in the section on prior ISRP reviews, but it is not clear if this work is still ongoing and what tasks remain to be continued into the next project period for the tool to be launched. Thus, the ISRP requests proponents provide a description of the plan to create a publicly-available database and education and outreach capacity to accompany the database.

The project prioritization, compliance monitoring, and review process that is supported by the technical advisory committee are relevant to our scientific review. These aspects are strengths of the program. Though not described in detail within this proposal, they are described in the proposal from CBWTP and were examined by the ISRP in the 2013 Geographic Review.

A new scope is introduced in this proposal regarding the use of IFIM/PHABSIM to establish targets for instream flows for the priority subbasins. The description of this work does not provide sufficient information for scientific review. While IFIM/PHABSIM is still widely used, it has many limitations (National Research Council 2008) and many improvements (e.g., Naman et al. 2020, Rosenfeld and Naman 2021) have been introduced since the original implementation. These limitations and application of advancements can significantly affect the usefulness and relevance of the results. Description on this effort is needed. Are all contractors using the same techniques and where are those methods described? In addition, are these IFIM/PHABSIM analyses based simply on existing flow or do they develop a hydrologic context based on natural, unimpaired flows?

Q3: Provisions for M&E

The proposal provides links to documents describing the compliance monitoring conducted by the QLEs but does not describe how decisions are made about adjusting the project’s direction more broadly. The proposal contains many examples of the proponents making strategic decisions. For example, how was the decision to use project funds for analysis of flow targets made? Or the decision to use Accord funds to integrate more real estate expertise into the project? Alternately, since flow data are so critical to compliance, how will project leaders make decisions about adjusting compliance protocols or project resources to address this need? Finally, it appears that the project is moving in the direction of land acquisition to secure water rights. How will those lands and water resources be managed strategically after acquisition? In asking these questions, the ISRP seeks clarity on how the project is evaluating and adapting to meet project objectives that ultimately benefit fish.

The response to the ISRP’s second prior qualification (page 18, Results and Adaptive Management) is not adequate. As noted above regarding the GIS-based tool, the ISRP re-emphasizes that better access to project accomplishments and data is needed.

Q4: Results – benefits to fish and wildlife

The proposal summarizes the water rights secured since the 2008 Accords (page 7), though it is hard to place the total volume in a fish-related context. Is ~70 cfs (+5000 AF) protected between 2015-2022 a meaningful level of flow across these subbasins, either individually or collectively? What does this represent in terms of available fish habitat or proportion of the region’s seasonal or annual discharge? This issue was raised in the 2013 Geographic Review. The proposed IFIM/PHABSIM analyses to prioritize where restoration of instream flows may be most beneficial in meeting flow needs potentially will provide an indirect indication of benefit to fish. The ISRP emphasizes that these analyses need to be conducted and interpreted and the project will need to highlight the overall outcomes and potential benefits to fish and wildlife.

References

Naman, S.M., J.S. Rosenfeld, E. Jordison, M. Kuzyk, M and B.C. Eaton. 2020. Exploitation of velocity gradients by sympatric stream salmonids: Basic insights and implications for instream flow management. North American Journal of Fish Management 40: 320-329. https://doi-org.ezproxy.proxy.library.oregonstate.edu/10.1002/nafm.10411

National Research Council. 2008. Hydrology, Ecology, and Fishes of the Klamath River Basin. Washington, DC: The National Academies Press. https://doi.org/10.17226/12072

Rosenfeld, J.S., and S.M. Naman. 2021. Identifying and mitigating systematic biases in fish habitat simulation modeling: Implications for estimating minimum instream flows. River Research and Applications 37: 869– 879. https://doi-org.ezproxy.proxy.library.oregonstate.edu/10.1002/rra.3803

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

Inadequate stream flow is a major factor limiting salmon survival and growth, and impeding migration in interior Columba River basin streams. This proposal is to support the Columbia Basin Water Transactions Program (CBWTP), a partnership between BPA and the National Fish and Wildlife Foundation (NFWF). The CBWTP works through Qualified Local Entities (QLEs) to acquire or lease water rights to enhance instream flow, especially during critical low flow periods in late summer, for the benefit of threatened and endangered anadromous and resident fishes. The focus of the project is the Walla Walla, Umatilla, and Grande Ronde subbasins. If done properly, this effort can yield important benefits for ESA listed salmon and resident fish.

The proposal describes the Columbia Basin Water Transactions Program's project goals, objectives, means of acquiring water rights, and accomplishments. The priority of the Program is acquiring or leasing senior water rights. The CBWTP program seems to be well organized and managed. The project is clearly significant to regional programs and is strongly guided by the subbasin plans and ESA recovery plans for the Walla Walla, Umatilla, and Grande Ronde subbasins, and other federal, state, and tribal recovery plans. It appears to be well-coordinated with other regional programs and, therefore, is an important component of the regional restoration strategy.

The Problem Statement provides a good description of the issues being faced. The fourth paragraph implies that low water flow currently delays steelhead migration upstream into the Touchet River. Is there evidence that they previously were able to migrate upstream earlier, or that earlier migration would be beneficial?

While all the Objectives are relevant, only the first three are adequately addressed. Objective 4 (Improve egg to smolt survival ratio), Objective 5 (Improve species diversity and abundance), and Objective 6 (Address Limiting Factors), while vitally important, basically are not addressed by the work elements and deliverables in the proposal. They should be important parts of the proposal and, as such, need to be fully developed with quantifiable deliverables.

The challenges to achieving Objectives 4 and 5 are significant and are not well explained. Multiple factors can influence egg-smolt survival and species diversity and abundance. An important consideration is whether immigration and emigration can be estimated or ruled out as factors confounding estimates of egg-to-smolt survival. Also, why would the challenge of controlling for environmental variability and biophysical changes, for example requiring control streams, be greater for Objective 5 than for Objective 4? Objectives 3 and 6 appear to be much the same except that temperature is mentioned in Objective 6 but not in Objective 3. If there is a difference between these objectives, more explanation is required; if not, they should be combined.

As the sponsors clearly recognize, M&E is crucial for accomplishing Objectives 4, 5, and 6 via Deliverable 3. However, the current status of the RM&E program is unclear. On the one hand, the sponsors imply that a monitoring program to evaluate the effectiveness of water transactions in improving habitat and fish survival and growth was developed in 2011 (for example, see the Executive Summary) and therefore currently is in place. If an M&E program is in place, the sponsors should provide details of that program. While the sponsors cite methods and metrics for monitoring in MonitoringMethods.org, for example CHaMP, they do not provide critical elements essential for a successful monitoring program such as its objectives, a sampling design, how sample sites will be selected, and the scale of the monitoring program, that is, will monitoring occur at the site, reach, or watershed scale. Will there be uniformity of monitoring design and methods among all transactions or will it be adapted to local conditions?

On the other hand, the sponsors also imply that a comprehensive habitat and biological monitoring program currently is not in place but will be developed or at least implemented as part of the current project. The proposal states that the CBWTP will be working with QLEs to establish the baseline information needed to increase monitoring of biological response to enhanced instream flow. If an M&E program is not in place, the approaches and strategies for developing one need to be described in reasonable detail. Developing and implementing a comprehensive M&E program for habitat and fish is a large and complex undertaking, and likely will require participation of partners such as ODFW. The sponsors should clearly define the roles of these partners and ensure that they will participate to the fullest extent in development of the M&E program.

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

This project has completed an impressive number of water transactions to enhance flows. Although it is reassuring to see continuing improvements through the years, the accomplishments seem to pre-date the initiation of this project.

The sponsors appear to have a well-defined process for selecting and implementing water transaction projects. The projects are selected using criteria approved by the ISRP. A link is provided that discusses the criteria in detail. Once projects have been implemented, an Accounting Framework will be used to track the effectiveness of the flow enhancement projects. This framework will be implemented in 2013.

The program's responsiveness and ability to deliver large quantities of information in a timely manner are key strengths. It is reassuring to note that increasingly more of the annual budget is going towards transactions as the program develops (19% in 2010, 24% in 2011, and 28% in 2012), and that correspondingly greater amounts of water volume and flow have been secured. It is difficult to understand the ecological importance of acre-feet of water and cubic feet per second of flow by themselves. What percentage of the flow expected to occur naturally or historically is being conserved? A comparison to historical flow estimates during the low flow months would be more meaningful. The figures on pages 8, 11, and 12 would provide greater perspective if the amount of water secured by transactions was also expressed as a proportion of the total water volume, and if targets were indicated. Also, more explanation is needed of the forecasted amounts of water reserved for instream flow (2013-2030 and perpetuity) in the figures on page 8; presumably the decline in forecasted amounts is due to past transactions expiring over time. Have forecasts of reduced flow due to climate change been incorporated, or could they be an additional scenario? Some effort in this direction is needed to reassure reviewers that the program is gaining or at least maintaining flow.

While it is encouraging to see improvement in flows, are there quantifications of what the ideal flow for fish would be? Considering the costs and efforts involved in flow restoration, having an ideal target flow that can be ecologically defended, is essential. Further, these streams probably are ecologically important for mussels, fishes other than salmonids, and for other organisms. What are the E-flow requirements for these species? After all, the ultimate goal is to establish vibrant ecological systems.

The figures on page 10 and 11 that show an increase in adult steelhead abundance in the Touchet River after water transactions began in 2010 are out of date. What has happened since 2010? What mechanism is proposed to account for the increased abundance and the relatively greater increase in wild than hatchery adults?

The sponsors should avoid statements that cannot be statistically supported. For example, the proposal states that “In 2010, when transactions were implemented on the Touchet River, the number of adult fish went up dramatically. Thus providing a correlation between the importance of instream flows and fish population numbers.” This increase is only for one year. It is not clear if these were hatchery or wild fish, or resulted from natural year-to-year variations in stock strength.

Adaptive management appears to be a strong aspect of this program as evident in the diversity of approaches being tried, including the novel experiment to store spring runoff in underground aquifers so that it could be pumped into Catherine Creek as needed later in the season. Sustainability is enhanced by these deliberate efforts to experiment because they generate new ideas and options, thereby increasing cultural adaptability. Following an ISRP recommendation, the CBWTP has instituted an improved process for selecting and implementing project and coordinating with state, federal, and tribal entities. Nevertheless, adaptive management could be practiced more effectively. Perhaps, because of the nature of the activities conducted by the CBWTP, adaptive management may not be fully appropriate. In that case, it might be better to employ Structured Decision Making, which the sponsors seem to be doing already.

Evaluation of Results

This project facilitates a partnership between the CTUIR and the National Fish and Wildlife Foundation (NFWF) enabling funds from the Accords agreement to be used by the NFWF’s Columbia Basin Water Transactions Program (CBWTP; BPA project 2002-02-301) to acquire or lease water rights to improve instream flow. The CTUIR will work with the CBWTP and the National Fish and Wildlife Foundation to identify flow restoration opportunities, purchase water rights, and implement flow enhancement projects. The core of the CBWTP is the Qualified Local Entities (QLE), which include state water agencies and nonprofits. In coordination with the NFWF and CTUIR, the QLEs work in local communities to identify, develop, and negotiate water transactions.

This project has completed an impressive number of water transactions since its inception and appears to have a well-defined process for selecting and implementing water transaction projects. It has enacted over 340 water transactions that returned over 1000 cubic feet per second of flow to subbasin tributaries, has secured over 4.9 million acre-feet of water, and enhanced flow for over 1500 miles of stream. Since CTUIR partnered with the CBWTP in 2010, 20 transactions have been funded through the Accords agreement.

The sponsors recognize that RM&E is critical for evaluating the effectiveness of water transactions in enhancing instream flow and improving fish survival and growth. Objectives 4, 5, and 6 in the proposal pertain to biological responses to water transactions, but they are not addressed adequately by the work elements and deliverables. It is clear that a robust and well-designed M&E program is crucial for accomplishing these Objectives.

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

The project appears to be well coordinated with the QLEs and other partnering entities. It is clear that the success of a program like this one depends on the capacity of the sponsors to find willing partners by undertaking extensive outreach, planning, and coordination with the community at large and other QLEs. The record of success to date suggests that project relationships have been a strong aspect of the program.

This work, understandably, appears to be done in isolation of other limiting factors such as temperature, toxic agricultural chemicals, sediment delivery, beaver, and riparian conditions. What is the longer term view on how these factors will be integrated with E-flows?

The implications of climate change are discussed in some detail. Nevertheless, climate change effects could be addressed more effectively. More quantitative projections of the effect on water flow and timing under a variety of scenarios would be useful to demonstrate that this approach has a reasonable probability of achieving its ultimate objectives (4 and 5 in the proposal). There are approaches in use to gain insights into future flows. These include scenario analyses to inform and improve existing instream flow restoration projects (see Donley et al. 2012, Global Change Biology (2012), DOI: 10.1111/j.1365-2486.2012.02773.x). It is important to assess the sensitivity of late summer (July, August, and September) flows to the following scenario simulations singly or in combination: climate change, changes in the quantity of water used for irrigation and possible changes to existing water resource policy. As the sponsors are aware, flows can be modeled using the Water Evaluation and Planning system (WEAP; as well as other modeling platforms) under historical and projected conditions, for example 2020 and 2040, for each scenario. It is surprising that models to perform these analyses were not mentioned in the proposal.

4. Deliverables, Work Elements, Metrics, and Methods

Deliverables one and two are crucial to the success of the water transaction program. Adequate Deliverables are required for Objectives 4, 5, and 6. These Objectives are essential for determining whether water acquisitions are effectively improving instream conditions and fish growth and survival. The Deliverables are far too general, make simple assumptions about the relationships between water transactions and biological responses, and lack detail concerning the proposed M&E program. The Deliverables will not, by themselves, be sufficient to achieve, or even to monitor progress to achieving the success of Objectives 4 and 5. No Deliverables are given for Objective 6 (Address limiting factors).

Work elements should include scenario modeling for the target streams to assess vulnerability to climate change, agricultural water withdrawals, and policy change. If WEAP is not being used or is inappropriate, then a statement is needed as to why it is not employed.

One or two professional publications in a refereed journal should be listed as a Deliverable. It is important for large scale projects, like this one, to provide leadership in the broader restoration community.

Specific comments on protocols and methods described in MonitoringMethods.org

No comments.

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

The Columbia Basin Water Transactions Program can point to numerous successes in acquiring or leasing water rights to improve stream flow. The sponsors have developed what appears to be a sound approach for selecting and monitoring projects. A particular strength of this project is the outreach and education provided by the QLEs that both inform and encourage landowners to participate in the water transaction program.

The following qualifications should be addressed during contracting and in future proposals and reports:

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

Inadequate stream flow is a major factor limiting salmon survival and growth, and impeding migration in interior Columba River basin streams. This proposal is to support the Columbia Basin Water Transactions Program (CBWTP), a partnership between BPA and the National Fish and Wildlife Foundation (NFWF). The CBWTP works through Qualified Local Entities (QLEs) to acquire or lease water rights to enhance instream flow, especially during critical low flow periods in late summer, for the benefit of threatened and endangered anadromous and resident fishes. The focus of the project is the Walla Walla, Umatilla, and Grande Ronde subbasins. If done properly, this effort can yield important benefits for ESA listed salmon and resident fish.

The proposal describes the Columbia Basin Water Transactions Program's project goals, objectives, means of acquiring water rights, and accomplishments. The priority of the Program is acquiring or leasing senior water rights. The CBWTP program seems to be well organized and managed. The project is clearly significant to regional programs and is strongly guided by the subbasin plans and ESA recovery plans for the Walla Walla, Umatilla, and Grande Ronde subbasins, and other federal, state, and tribal recovery plans. It appears to be well-coordinated with other regional programs and, therefore, is an important component of the regional restoration strategy.

The Problem Statement provides a good description of the issues being faced. The fourth paragraph implies that low water flow currently delays steelhead migration upstream into the Touchet River. Is there evidence that they previously were able to migrate upstream earlier, or that earlier migration would be beneficial?

While all the Objectives are relevant, only the first three are adequately addressed. Objective 4 (Improve egg to smolt survival ratio), Objective 5 (Improve species diversity and abundance), and Objective 6 (Address Limiting Factors), while vitally important, basically are not addressed by the work elements and deliverables in the proposal. They should be important parts of the proposal and, as such, need to be fully developed with quantifiable deliverables.

The challenges to achieving Objectives 4 and 5 are significant and are not well explained. Multiple factors can influence egg-smolt survival and species diversity and abundance. An important consideration is whether immigration and emigration can be estimated or ruled out as factors confounding estimates of egg-to-smolt survival. Also, why would the challenge of controlling for environmental variability and biophysical changes, for example requiring control streams, be greater for Objective 5 than for Objective 4? Objectives 3 and 6 appear to be much the same except that temperature is mentioned in Objective 6 but not in Objective 3. If there is a difference between these objectives, more explanation is required; if not, they should be combined.

As the sponsors clearly recognize, M&E is crucial for accomplishing Objectives 4, 5, and 6 via Deliverable 3. However, the current status of the RM&E program is unclear. On the one hand, the sponsors imply that a monitoring program to evaluate the effectiveness of water transactions in improving habitat and fish survival and growth was developed in 2011 (for example, see the Executive Summary) and therefore currently is in place. If an M&E program is in place, the sponsors should provide details of that program. While the sponsors cite methods and metrics for monitoring in MonitoringMethods.org, for example CHaMP, they do not provide critical elements essential for a successful monitoring program such as its objectives, a sampling design, how sample sites will be selected, and the scale of the monitoring program, that is, will monitoring occur at the site, reach, or watershed scale. Will there be uniformity of monitoring design and methods among all transactions or will it be adapted to local conditions?

On the other hand, the sponsors also imply that a comprehensive habitat and biological monitoring program currently is not in place but will be developed or at least implemented as part of the current project. The proposal states that the CBWTP will be working with QLEs to establish the baseline information needed to increase monitoring of biological response to enhanced instream flow. If an M&E program is not in place, the approaches and strategies for developing one need to be described in reasonable detail. Developing and implementing a comprehensive M&E program for habitat and fish is a large and complex undertaking, and likely will require participation of partners such as ODFW. The sponsors should clearly define the roles of these partners and ensure that they will participate to the fullest extent in development of the M&E program.

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

This project has completed an impressive number of water transactions to enhance flows. Although it is reassuring to see continuing improvements through the years, the accomplishments seem to pre-date the initiation of this project.

The sponsors appear to have a well-defined process for selecting and implementing water transaction projects. The projects are selected using criteria approved by the ISRP. A link is provided that discusses the criteria in detail. Once projects have been implemented, an Accounting Framework will be used to track the effectiveness of the flow enhancement projects. This framework will be implemented in 2013.

The program's responsiveness and ability to deliver large quantities of information in a timely manner are key strengths. It is reassuring to note that increasingly more of the annual budget is going towards transactions as the program develops (19% in 2010, 24% in 2011, and 28% in 2012), and that correspondingly greater amounts of water volume and flow have been secured. It is difficult to understand the ecological importance of acre-feet of water and cubic feet per second of flow by themselves. What percentage of the flow expected to occur naturally or historically is being conserved? A comparison to historical flow estimates during the low flow months would be more meaningful. The figures on pages 8, 11, and 12 would provide greater perspective if the amount of water secured by transactions was also expressed as a proportion of the total water volume, and if targets were indicated. Also, more explanation is needed of the forecasted amounts of water reserved for instream flow (2013-2030 and perpetuity) in the figures on page 8; presumably the decline in forecasted amounts is due to past transactions expiring over time. Have forecasts of reduced flow due to climate change been incorporated, or could they be an additional scenario? Some effort in this direction is needed to reassure reviewers that the program is gaining or at least maintaining flow.

While it is encouraging to see improvement in flows, are there quantifications of what the ideal flow for fish would be? Considering the costs and efforts involved in flow restoration, having an ideal target flow that can be ecologically defended, is essential. Further, these streams probably are ecologically important for mussels, fishes other than salmonids, and for other organisms. What are the E-flow requirements for these species? After all, the ultimate goal is to establish vibrant ecological systems.

The figures on page 10 and 11 that show an increase in adult steelhead abundance in the Touchet River after water transactions began in 2010 are out of date. What has happened since 2010? What mechanism is proposed to account for the increased abundance and the relatively greater increase in wild than hatchery adults?

The sponsors should avoid statements that cannot be statistically supported. For example, the proposal states that “In 2010, when transactions were implemented on the Touchet River, the number of adult fish went up dramatically. Thus providing a correlation between the importance of instream flows and fish population numbers.” This increase is only for one year. It is not clear if these were hatchery or wild fish, or resulted from natural year-to-year variations in stock strength.

Adaptive management appears to be a strong aspect of this program as evident in the diversity of approaches being tried, including the novel experiment to store spring runoff in underground aquifers so that it could be pumped into Catherine Creek as needed later in the season. Sustainability is enhanced by these deliberate efforts to experiment because they generate new ideas and options, thereby increasing cultural adaptability. Following an ISRP recommendation, the CBWTP has instituted an improved process for selecting and implementing project and coordinating with state, federal, and tribal entities. Nevertheless, adaptive management could be practiced more effectively. Perhaps, because of the nature of the activities conducted by the CBWTP, adaptive management may not be fully appropriate. In that case, it might be better to employ Structured Decision Making, which the sponsors seem to be doing already.

Evaluation of Results

This project facilitates a partnership between the CTUIR and the National Fish and Wildlife Foundation (NFWF) enabling funds from the Accords agreement to be used by the NFWF’s Columbia Basin Water Transactions Program (CBWTP; BPA project 2002-02-301) to acquire or lease water rights to improve instream flow. The CTUIR will work with the CBWTP and the National Fish and Wildlife Foundation to identify flow restoration opportunities, purchase water rights, and implement flow enhancement projects. The core of the CBWTP is the Qualified Local Entities (QLE), which include state water agencies and nonprofits. In coordination with the NFWF and CTUIR, the QLEs work in local communities to identify, develop, and negotiate water transactions.

This project has completed an impressive number of water transactions since its inception and appears to have a well-defined process for selecting and implementing water transaction projects. It has enacted over 340 water transactions that returned over 1000 cubic feet per second of flow to subbasin tributaries, has secured over 4.9 million acre-feet of water, and enhanced flow for over 1500 miles of stream. Since CTUIR partnered with the CBWTP in 2010, 20 transactions have been funded through the Accords agreement.

The sponsors recognize that RM&E is critical for evaluating the effectiveness of water transactions in enhancing instream flow and improving fish survival and growth. Objectives 4, 5, and 6 in the proposal pertain to biological responses to water transactions, but they are not addressed adequately by the work elements and deliverables. It is clear that a robust and well-designed M&E program is crucial for accomplishing these Objectives.

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

The project appears to be well coordinated with the QLEs and other partnering entities. It is clear that the success of a program like this one depends on the capacity of the sponsors to find willing partners by undertaking extensive outreach, planning, and coordination with the community at large and other QLEs. The record of success to date suggests that project relationships have been a strong aspect of the program.

This work, understandably, appears to be done in isolation of other limiting factors such as temperature, toxic agricultural chemicals, sediment delivery, beaver, and riparian conditions. What is the longer term view on how these factors will be integrated with E-flows?

The implications of climate change are discussed in some detail. Nevertheless, climate change effects could be addressed more effectively. More quantitative projections of the effect on water flow and timing under a variety of scenarios would be useful to demonstrate that this approach has a reasonable probability of achieving its ultimate objectives (4 and 5 in the proposal). There are approaches in use to gain insights into future flows. These include scenario analyses to inform and improve existing instream flow restoration projects (see Donley et al. 2012, Global Change Biology (2012), DOI: 10.1111/j.1365-2486.2012.02773.x). It is important to assess the sensitivity of late summer (July, August, and September) flows to the following scenario simulations singly or in combination: climate change, changes in the quantity of water used for irrigation and possible changes to existing water resource policy. As the sponsors are aware, flows can be modeled using the Water Evaluation and Planning system (WEAP; as well as other modeling platforms) under historical and projected conditions, for example 2020 and 2040, for each scenario. It is surprising that models to perform these analyses were not mentioned in the proposal.

4. Deliverables, Work Elements, Metrics, and Methods

Deliverables one and two are crucial to the success of the water transaction program. Adequate Deliverables are required for Objectives 4, 5, and 6. These Objectives are essential for determining whether water acquisitions are effectively improving instream conditions and fish growth and survival. The Deliverables are far too general, make simple assumptions about the relationships between water transactions and biological responses, and lack detail concerning the proposed M&E program. The Deliverables will not, by themselves, be sufficient to achieve, or even to monitor progress to achieving the success of Objectives 4 and 5. No Deliverables are given for Objective 6 (Address limiting factors).

Work elements should include scenario modeling for the target streams to assess vulnerability to climate change, agricultural water withdrawals, and policy change. If WEAP is not being used or is inappropriate, then a statement is needed as to why it is not employed.

One or two professional publications in a refereed journal should be listed as a Deliverable. It is important for large scale projects, like this one, to provide leadership in the broader restoration community.

Specific comments on protocols and methods described in MonitoringMethods.org

No comments.

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

The Columbia Basin Water Transactions Program can point to numerous successes in acquiring or leasing water rights to improve stream flow. The sponsors have developed what appears to be a sound approach for selecting and monitoring projects. A particular strength of this project is the outreach and education provided by the QLEs that both inform and encourage landowners to participate in the water transaction program.

The following qualifications should be addressed during contracting and in future proposals and reports:

1) Ensure that the sponsors provide appropriate Deliverables for Objectives 4, 5, and 6; or delete them from the proposal as stated objectives.

2) Ensure that the sponsors provide defensible biological targets for late summer flows in the targeted streams.

3) Ensure that the sponsors provide a long-term strategy for integrating the suite of “emerging” factors with the E-flow program.

4) Ensure that the sponsors provide an integrated scenario analyses for targeted streams into the work plan.

5) Ensure that an appropriate M&E program is in place or will be developed to evaluate the effectiveness of the water transactions. Include more explanation of how monitoring will conducted to evaluate progress towards objectives 4 (“Improve egg to smolt survival”) and 5 (“Improve species diversity and abundance”).