This proposal needs further work to satisfy most of the ISRP criteria. Spending over $1 million for accessing 13.8 miles of stream, with no geomorphological assessment and only 60% spent on (design and?) construction, should be supported by a more complete proposal. This culvert project should be part of watershed rehabilitation and guided by the subbasin plan and watershed assessments. It is not linked to subbasin plans, and not identified as an activity having high priority.

The technical aspects are not well articulated and there are no data on fish presence. The main objective is to prioritize culvert replacement according to:
"The Boise and Sawtooth National Forests also asked the following questions to verify that these crossings were located in areas considered to be priorities for restoration.
• Is the project in a high priority subwatershed as determined by the Watershed Aquatic Recovery Strategy and/or Aquatic Conservation Strategy?
• How many listed fish or other aquatic species would benefit from upgrading the barrier?
• Does critical habitat exist above the culvert?
• How many miles would be made accessible if passage was restored?
• Will correction of this barrier make the stream more accessible to introduced species?"

However, directly after quoting the above, the attached fish barrier report claims to have used the following criteria for Table 4: "The order within Table 4 is not necessarily firm, but is listed in order according to the amount of suitable habitat upstream. Also, note that the miles of perennial stream above each culvert varies greatly. Some perennial stream miles may not necessarily provide suitable fisheries habitat, but may provide habitat for other aquatic-dependent species."

Attached to Table 4 is the following: "Criteria for ranking culverts are weighted mainly on the miles of habitat that will be accessible after replacement. However, our criteria included the inventory priority for species, the aquatic conservation strategy, the watershed and aquatic recovery strategy, the benefit to listed species, and the accessibility to introduced species."

No process for using these criteria is explained; what is one supposed to conclude from this jumble of supposed criteria? This is indicative of poor science, particularly when it is the basis for spending $1 million.

The cookie-cutter diagrams showing how a hanging culvert is replaced are dangerous in situations where the morphological dynamics of the stream are unknown, as in this case apparently -- again, not good science.

The method statement is brief and vague. No mention of culvert replacement design (clear-span bridge or bottomless culvert) is given based on geomorphic analysis, including possible incision or aggradation processes and sediment sources, and the need for the capacity to pass a chosen-probability flood (and sediment without concentrating flow and increasing the velocity/unit width ratio that will likely cause erosion immediately downstream).

Monitoring and evaluation are mentioned twice in the entire proposal but are not adequately described. Facilities, equipment and personnel are not very specific and without mention of the necessary fluvial geomorphology expertise needed for this proposal. No information transfer is mentioned.

There is insufficient explanation of benefits to focal species and other activities in the watershed. The proposal indicates non-focal species as "All Wildlife, Brown Trout, Bull Trout, Cutthroat Trout, Freshwater Mussels, Rainbow Trout, Westslope Cutthroat, river otter & mink", but makes no further mention of the benefits to these species.