Although no one doubts that freshwater mussels are highly imperiled, the rationale and significance of this proposed project is too weakly developed to warrant funding at this time. There are insufficient references to specific subbasin plans. The reference to the Fish and Wildlife Plan is very general and does not provide a sufficiently strong tie to justify this proposal. The technical background needs to be fleshed out more. The goal of the project is to develop freshwater mussel survey methods; however, the study plan basically describes a 1-year mussel survey of the Similkameen River. Moreover, the proposal does not consider the potential pitfalls of limiting the investigation to a single year.

There are few references to other mussel survey techniques (surely this work has been done in the south), and alternative methods are not described. There is no mention of other BPA-supported mussel research projects that has been going on in the Umatilla and John Day Rivers since 2003.

The "3 or 4" mussel species in the Similkameen River are not identified, nor are their life cycles or intermediate hosts given. The basic question, "Why do we need mussel distribution, abundance, and life history survey methods?" for the Columbia Basin, as opposed to other areas where such methods have been worked out, is not addressed. Additionally, the reason for choosing the Similkameen River over others is not adequately justified. The proposal does not give enough detail to understand exactly how they are going to proceed with the project. This proposal is a plan to develop a plan and is inadequate.

The tasks are delineated, but much of the preliminary design work should have been completed before the proposal was submitted. References are given for the tasks but no methods are described in detail. There is no discussion of evaluating alternative sampling techniques. Have survey protocols already been determined? If so, should the proposal have a different title?

At a minimum, this proposal should have addressed the following questions: (1) what are the sampling challenges for determining mussel distribution, abundance, and life history, (2) what alternative sampling methods are being evaluated, and (3) what are the cost/effectiveness tradeoffs of different survey techniques? These questions are inadequately addressed in the proposal.

The objective of Task 1 is to develop a statistically valid survey method, but the lead investigator has apparently already done so "in a subdrainage of the Columbia River in 2005" (p. 2). Task 2 proposes to focus on the Similkameen River because it contains a diverse mussel assemblage, but it is not clear that results would be applicable elsewhere in the Columbia River Basin. The Similkameen River is a transboundary tributary that has been heavily impacted by mining and agricultural practices and survey methods for this system may not be the most appropriate for cold montane rivers.

Task 3 was too generally written to be helpful for understanding database management. Were data to be stored in Excel or Access, or in some proprietary WDFW database management system? The objective of Task 4 is to determine distribution, abundance and life histories of the mussels, but there is no mention of sampling any intermediate hosts. Do the mussels require only native fish species as intermediates, or can the glochidia infest non-native fishes?

The second reference (Stevens and Olsen (2004) is not in the literature cited. The design to look above and below a dam is a good concept. But not enough detail was provided to understand exactly how the project would proceed.