The Confederated Tribes of the Grand Ronde Community of Oregon (Tribe) propose the acquisition of 880 acres of wildlife habitat in the Willamette River Subbasin to protect, restore, and manage focal habitats that have been identified in the Subbasin Plan. Planning is in the very early stages, and links to existing planning documents are only vaguely described. The Tribe might be better off to pre-select a subset of parcels, perhaps in collaboration with others, then develop a more specific proposal. Provision for future management, other than just continuing Program funding, would be more compelling. Discussion of anticipated restoration (if needed), maintenance, focal species to be managed for, and a monitoring and evaluation program should all be included for specific parcels when identified. Collaboration with complementary programs in the sub-basin is likely to improve overall conservation value due to the degree of fragmentation present.

Monitoring, in terms of regular measurement of established indicators and comparison to desired conditions, followed by adaptive management, is not included in this proposal. The project's ability to "improve species trend..." is doubtful if there are no specific goals or monitoring of success relative to target species. Proposing to acquire a minimum number of Habitat Units from unspecified lands, at estimated prices, as is done here, could create an untenable commitment by the tribe and offers no obvious advantage over a more focused approach. Timelines are optimistic. The estimated cost per HU of $12,166 is considerably higher than similar proposals.