(Although this proposal did not participate in the fix-it loop, for full comments on "restore and protect" type projects, please see heading "General comments concerning Nez Perce Tribe proposals to protect and restore various watersheds" at the beginning of the ISRP comments on project # 199607702, Protect & Restore Lolo Creek Watershed. The comments below are from the ISRP's June 2006 preliminary review of this proposal.)

Overview Comments on the following proposals, which should be considered as a set:
200710500 - Protecting & Restoring the Wallowa River Watershed;
200711600 - Lostine River Watershed Restoration;
200724500 - Protect and Restore the Joseph Creek Watershed; &
200725700 - Protect and Restore the Imnaha Subbasin

Each of these project proposals is essentially identical. The following general comments apply to all four and should be addressed in a response. Specific comments for each proposal/watershed are provided after the general comments.

Each project has a large budget, is overly general, vaguely justified, and is presented with an overly ambitious "do everything" approach. We are concerned that these qualities will only intensify the potential for failing to deliver on the project's goals and biological objectives.

As each proposes to do an enormous amount of work, they primarily fail in presenting the details of what and how much will be done, where, in what order, and how effectiveness will be monitored. Essentially, this group of proposals needs a priori prioritization, in terms of which watersheds and the activities therein will offer the greatest effectiveness or potential within a broader context of the Subbasin and especially with the Grande Ronde Model Watershed Project and the role it plays in the basin. Ultimately, this begs a basic question as to "why this project not ‘approved' by GRMWP" - apparently GRMWP has authority to approve and there is no indication of this?

Each project proposal has the same basic set of "prescriptions" regardless of watershed conditions. Each needs to be integrated within a watershed assessment context (which should be part of the Subbasin Plan). We are concerned the uniform prescription approach does not reflect true diagnosis of limiting factors, in a quantitative (versus qualitative) sense within each watershed specifically regardless of their commonalities.

Ultimately, we recommend potentially a phased-in schedule or approach. First, we conclude that it is appropriate to provide rather leaner funding to demonstrate that the sponsors can accomplish this kind of work. Second, sponsors need to develop a sufficiently robust M&E methodology and treatment to be integrated across project - perhaps as a group - with non-treated reference streams. We do not imply that every variable must be monitored, but rather that some effort must be included to define basic hypotheses and response variables. Third, from this M&E, the sponsors should be able to demonstrate (or not) that the approach has a measurable response (i.e., the approach works). Finally, that expansion of these projects to other places (and more of them within the watersheds) will have a cumulative benefit (population-level response).

Other general issues:
• Aside from habitat treatments, the projects propose to complete "roads" assessments. Were not these done as part of the Subbasin Plan?
• The linkages to other projects are not well described. An obvious example is the Grande Ronde Model Watershed Project. There are likely others.
• There is a need for some basic analyses (are there data in the watersheds that define the limiting factors in a quantitative v. qualitative way) to better justify the projects, indicating whether they are affecting habitat in significant fish production areas (or will the restoration action have a measurable impact on habitat and fish), and the extent of impact on these areas (how much damage has been done to habitat and fish that would warrant a restoration/protection action).

Technical and Scientific Sections: All four of these projects were submitted by the Nez Perce Tribe, by the same PI, using a common narrative template. All propose similar (though not identical) landscape treatments - culvert removal, fish migration barrier mitigation, riparian habitat improvement, and in-stream flow measures.

The technical and scientific background is not effective at communicating how the projects implemented by the proposals will address the problems in these respective watersheds. There is much background text that is not essential to the proposal, for example, the background on Nez Perce ceded lands. This provides some context but makes it harder to find out exactly what the sponsors want to do and why. Similarly, the discussion about how culverts and other barriers effect fish populations is not necessary. Simply presenting the results from the various assessments that establish this as a limiting factor in the watersheds is sufficient.

Rationale and significance to subbasin plans and regional programs: While the proposals qualitatively and loosely address limiting factors in the Grande Ronde Subbasin Plan, the 2000 Biological Opinion, and the tribal recovery plan (CRITFC), the proposals do not adequately connect the actions proposed in the methods and work elements with locations identified in the subbasin plan or federal recovery documents as high priorities for action.

As an example, on page 15 of the Lostine River proposal is a table (1) listing strategy recommendations from the Grande Ronde subbasin plan. These strategies need to be connected to watershed segments identified in the subbasin plan and then these proposals need to identify that the projects they are choosing are high priorities.

Relationships to other projects: The proposed work involves state, federal, and private entities in a cooperative venture. It is related to several BPA funded provincial and subbasin projects, but the sponsors do not sufficiently explain these relationships within the context of the proposed project.

We specifically identify a known entity with authority for coordinating projects - i.e., the GRMWP has several projects that have been executed in these watersheds. How have the sponsors ensure they are not duplicating work from other projects or not undoing the benefits from others?

Objectives: These projects have far too many objectives (and work elements) to be effective without prioritization as to which will have the greatest benefit to salmon or more specific details about what actions will be taken where.

As such, each of these proposals has a "do everything" kind of feel to it without any sense of whether everything (or anything) is doable and will be effective.

Also, sponsor must approach objectives as measurable (expected biological response in terms of fish and wildlife). Treatments then serve as the basis of hypotheses and through basic population monitoring can help determine response and effectiveness. This needs to go beyond simply providing tables that refer to prioritized strategies in the subbasin plan. Proposals are stand-alone documents and the objectives should be stated explicitly, not simply referred to by number in another document.

Tasks (work elements) and methods: Methods are only generally described with some methodological details presented in the appendix. In all four proposals there are a series of tables (for example table 2 in the Lostine Proposal) that provide objectives, links to strategies in the subbasin plan, and work element numbers for the proposal. Under each of the work elements there needs to be a short paragraph explaining the approach used to finish the task, not just state that the task exists.

The sponsors assert that restoration will occur on the reach/segment scale, but they do not explicitly describe how this scale of work will be accomplished, in what order or priority, or if it is even possible.

For example, the sponsors need to provide better justification and prioritization for the proposed culvert replacements. Here, they need to explain how culvert replacements locations were prioritized, whether the blocked areas were once (or should be) productive for fish based on habitat assessment, and the conditions and extent of the habitat that will be opened by culvert replacement.

Moreover, the work elements related to sedimentation and channel reconstruction are simply too general and represents little more than a vague promise at this point to do something good. Possible locations, methods of prioritization, and explanations of how sediment sources will be identified and their contribution to the total sediment load are not provided. The methods largely consist of a list of actions that might reduce sediment loads. In all four proposals (under sedimentation and channel-reconstruction in the Lostine proposal) 1/8 mile of stream per year is to be treated. How can this short reconstruction effectively improve the habitat-forming processes in the watersheds?

The sponsor needs to justify the 160 acres for weed control. Where will the effort be located in the basin? How were the sites selected? What was the process of prioritization? What is the specific impact of noxious weeds on terrestrial and aquatic habitat at the project sites? What is the expected benefit and impact to salmon or wildlife populations?

Monitoring and evaluation: The M&E approach is not well defined. The sponsors say they will rely on the NEOH project for monitoring. But, as described, the M&E is too vague to be judged appropriate in a scientific light. Descriptions appear to be materials "cut" from other documents and did not link to these proposals. Rather, monitoring for these proposals should use the same methods and format as used by the CTUIR, GRMWP, and ODFW projects for consistency within the Grande Ronde and Imnaha subbasins.

Facilities, equipment, and personnel: Until a more succinct proposal with clear tasks is provided, it is difficult to determine if the personnel and equipment are sufficient.

Comments specific to this proposal:

Technical and scientific background: The problem is clearly identified. The need to address the problem is clear: the Wallowa River was once a productive stream but has been severely degraded by land use activities that have occurred over long periods of time. The sponsors propose to address the problem through habitat restoration actions.

A rather lengthy list of active and passive restoration techniques will be applied to improve fish and wildlife habitat. The background is overly general and the proposed actions somewhat grandiose without some set of identified priority places throughout watershed. These need to be specified and tied to the objectives a bit more.

This technical and scientific background could be much shorter and succinct. Sponsors might wish to look at the CTUIR proposal 199608300 or the Grande Ronde Model Watershed 199202601 for examples of using the loss of fish and the EDT analysis from the subbasin plan to provide an effective background, as well as for potential linkages.