This proposal does not clearly indicate that the reason for the lack of surface flow at the mouth of Toppenish Creek is due to leakage of shallow groundwater to deeper aquifer layers around poorly grouted well casings. Better evidence is needed that this is actually the cause of the problem. This proposal may be addressing an important issue, but there is not enough known about the nature and extent of the problem to launch into an expensive fix. Although plausible, leakage around well casings is conjectural, based primarily on experience in Arizona. An appropriate course for the authors would be to develop a proposal to better understand the problem (how much water is being lost, which wells are the most significant, which wells don't matter, etc.) and then, assuming the leakage is significant, submit a follow-up proposal to correct the wells causing the problem.

Technical and scientific background: The biological justification and benefits could have been more clearly explained. Specific details of how the project will benefit the focal species, Mid Columbia steelhead and spring chinook, should be presented.

Rationale and significance to subbasin plans and regional programs: The Yakima Subbasin Plan (SBP) is referred to generally as stating that Toppenish and Simcoe creeks are identified as currently used steelhead habitat and historically used habitat for spring Chinook, but there is not a clear link made to any specific objectives in the plan to improve groundwater flow conditions for steelhead or spring chinook habitat in these creeks. Other programs and plans were not mentioned.

Relationships to other projects: This proposal does a good job of describing its relationships to other projects. A detailed list of related BPA projects is given in the form plus a good description of how each relates to this project.

Objectives: Objectives and work elements are presented as a detailed list in outline form, which was not easy to read. The objectives are not stated in terms of benefits to target species of fish and wildlife except in a general way ("The proposed project is designed to increase groundwater discharge to Toppenish and Simcoe Creek. It is presumed that the increased groundwater discharge will improve habitat by moderating stream temperatures and providing nutrients."). No measurable benefits are predicted for the species of interest, and this objective cannot be tied to any specific strategy/action listed in the SBP for these creeks.

The flow objectives are not fully stated. How much additional flow can be expected? How much water is currently lost around the leaky wells? The lack of specific flow objectives is due to the fact that the importance of the problem this proposal is intended to correct is not well understood.

Methods: This proposal appears to be very weak in this area. Descriptions of methods were not provided. This section of the proposal had the appearance of a budget summary, not an explanation of how the work would be done. In part 10B.3 of the background section, some information on procedures for the well modifications are provided. But this information is not complete enough to judge the adequacy of the approach.

A greater problem is that there is no information presented that indicates that leakage around the well casings is actually the cause of the flow problem in the creek. Rather than attempting to regrout every well in the White Swan area, it would seem prudent to first identify how much shallow ground water is actually being lost around wells and which of the wells are the major culprits. It may be that the elimination of leakage at a few key wells may substantially correct the problem. Until some basic information on the extent and nature of this problem has been collected, applying the proposed corrective measures is not appropriate.

Monitoring and evaluation: There is some monitoring work proposed for flow in the channel, groundwater monitoring, some water quality evaluation and weather monitoring, pre and post project. Few details were provided about these monitoring efforts. The length of pre-project monitoring (a few months) may not be sufficient to assess response to the proposed treatment.

M&E work to better define the problem needs to be done before implementing a corrective treatment.

Facilities, equipment, and personnel: Contractors will do most of the sealing work. Project administration and technical support seems reasonable for the job.

Information transfer: Only progress reports are mentioned. There was no description of data management.

Benefits to focal and non-focal species: Given the issue with failure to fully define the nature and extent of the problem, it is difficult to determine what the impact on the focal species might be. If the problem hypothesized in the proposal is the cause of the lack of flow in the creek and if the proposed solution is effective and future wells are installed properly, the benefits to the focal species should be significant and long lasting. Nonetheless, without a better definition of the problem, the likelihood of success cannot be estimated. This proposal did not discuss non-focal species. Nonetheless, given the concerns expressed above, any claims regarding the response of non-target species would be very speculative.