Comment:

The ISRP has identified all tribal enforcement projects in this review as "not applicable" because scientific assessment of the enforcement activities to biological conservation objectives is not possible.

There is a need for proponents of this and other enforcement projects to coordinate with biologists from CRITFC and other agencies to obtain estimates of the biological metrics and relate these estimates to enforcement activities.

All the tribal enforcement projects have documented their activities. A separate effort is needed to track trends in enforcement activities among tribes, quantify their cumulative enforcement actions, assess changes over time, and relate these activities to biological conservation objectives.

We encourage the program to expand annual reports. Summary statistics as provided in the 2016 Annual Report should be provided each year so that the data can be used to document whether specific illegal activities are increasing or decreasing.

It is noted that the proposal states that more officers are needed to carry out all tasks including outreach and enforcement during night and day.

1. Objectives, Significance to Regional Programs, and Technical Background

The proposal describes five highly relevant objectives related to the overall goal of conservation enforcement on reservation and ceded lands. Concise background information is provided that includes the significance of enforcement to regional programs. The objectives are clear and reasonable but not quantitative. The overall goal and two objectives are explicitly linked to biological and physical outcomes. It is good that one of the objectives is to maximize accountability through monitoring and evaluation (M&E).

Quantitative outcomes are not provided despite the use of the terms "optimize" and "maximize" that imply a quantitative approach. Timelines are not provided. It is not possible to assess to what extent objectives have been met because of the lack of quantification of objectives and timelines.

The proposal seems incomplete in that only one deliverable is listed (i.e., assistance with Upper Columbia River steelhead recovery). No deliverables are associated with objectives 2, 4 or 5.

The ISRP 2010 (2010-44b) review comments are still relevant and should be addressed.

2. Results and Adaptive Management

Enforcement of resource protection regulations on Colville reservations and ceded lands is assumed to benefit salmon populations throughout the Upper Columbia Basin.

No results were provided in the proposal, but some results are provided in past annual reports. Enforcement actions are documented in most of the annual reports (excepting the most recent 2017 report), but outcomes have not been assessed as implied by the language in objectives 3 - 5. It would be useful to compile tables of resource protection actions by year over the history of the project to facilitate evaluation of temporal trends by type of action. Such a synthesis would facilitate assessment of success and may reveal challenges that face the project.

An adaptive management approach is not evident. For example, quantitative objectives with timelines, lessons learned, and project changes and reasons for them over time are not described.

Objectives and expected outcomes should be expressed quantitatively. Metrics and methods for evaluation of objectives should be documented in greater detail. These refinements would improve the adaptive management cycle by allowing for more effective review of methods, evaluation of performance outcomes, and sharing of lessons learned. Lessons learned about enforcement strategies or tactics have not been documented.

The proponents state that "new objectives/performance measures were established" and "a work plan has been developed." It would be helpful in a review of the proposal if the proponents described the objectives/performance measures and the work plan. The proponents state that they will do an evaluation and analysis of the project impacts, but no process for evaluation and analysis is described in the proposal.

3. Methods: Project Relationships, Work Types, and Deliverables

Neither the proposal nor most recent 2017 Annual Report describes methods to achieve the five objectives listed in the proposal in sufficient detail for review. The documents provide a general overview of police patrol procedures and actions, but they do not provide details about the survey design, standard procedures, dates, or extent of patrol coverage. The "work plan" mentioned in the proposal may contain details about methods. It would be useful if the proponents would provide details from the work plan. The need for a description of methods was identified as a qualification by the ISRP in 2010 (2010-44b), and this limitation persists.

Monitoring and evaluation (M&E) are not described. The proponents mention that they will evaluate the impact of the project. Information as to how this is to be done is not presented in the proposal and is needed to provide an effective review of the project. There is an opportunity to evaluate temporal and spatial trends in enforcement actions based on summaries in annual reports. A useful first step would be to compile data in the annual summaries to facilitate statistical evaluation of trends.

To facilitate adaptive management, quantifiable metrics with time lines are needed for each of the five objectives with a good description of deliverables for each.

The project of the Colville Confederated Tribes (CCT) is clearly relevant and related to regional programs. However, the proposal needs to make a better case as to specifically how it is related. It also needs to develop and describe deliverables associated with Objectives 2, 4 and 5, including performance indicators. The proposal would be more informative if it described the enforcement challenges, discussed any adaptive changes in approach as a result of operational learning, and assessed the educational needs and success of the project approach to meet these. Major compliance issues could be described. In common with other enforcement projects, useful lessons could be learned by taking a more analytical approach to evaluate the overall picture of compliance. The ISRP encourages the recording and mapping of information on illegal activities. A response should specifically: 1. Address ISRP comments on the need for data development and summary analysis by describing the existing enforcement data and plans for its analysis. 2. Address ISRP comments on the need for conservation education by addressing the type of public education that is conducted. 3. Provide information on significance of the project to regional programs. 4. Address ISRP comments about the need for deliverables and methods by developing and describing deliverables and methods and metrics for Objectives 2 (increase cost-effectiveness of enforcement), 4 (maximize the efficacy of enforcement) and 5 (maximize the accountability of enforcement). These may exist in the newly developed conservation enforcement work plan. 1. Purpose, Significance to Regional Programs, Technical Background, and Objectives The purpose of this project is to enhance the CCT conservation enforcement program for the protection of ESA-listed species, other anadromous species, and resident fish. Natural resource law enforcement is an integral and essential component of natural resource management. Enforcement of existing fish, wildlife, and habitat regulations is needed to ensure compliance rates and protect fish stocks, wildlife populations and their critical habitats. Coordination of state and tribal government operations, public awareness, and public participation are all benefits of natural resource enforcement. The CCT Natural Resource Enforcement division will provide two enforcement officers for enforcement activities on the Okanagan River, Columbia mainstem (Wells Pool) and tributaries. It will coordinate among all jurisdictions involved in the enforcement effort and will increase effectiveness and alleviate duplication of efforts. Officers will enforce fisheries and habitat regulations on reservation and ceded lands. The proposal states that existing enforcement activities will be enhanced through the enforcement of new mark-selective tribal fishing regulations for upper Columbia spring and summer Chinook and summer steelhead within tribal fishing areas covering about 1.5 million acres. The project will also address compliance issues associated with the live-capture selective gear project. The proposal states that an increased enforcement presence will act as a deterrent to illegal activity and public awareness programs will increase support and understanding of the goals of the program. The goal of CCT enforcement is to increase survival rates of both juvenile and adult salmonids and to protect critical habitats. In a brief technical background, the proposal ties its enforcement activities to larger regional conservation and recovery goals, particularly through the protection of ESA listed stocks. Along with assuring compliance of the Live Selective Gear Project, the CCT will release all ESA-listed stocks utilizing the live capture method. In addition, all natural origin Summer/Fall Chinook will be released. The proposal emphasizes coordination of state and tribal government actions, public awareness and public participation as benefits of enforcement. It is encouraging to see that the tribe supports the mark-selective fishery. The project has five objectives: 1. provide enhanced enforcement of laws and rules for the protection of anadromous and resident fish; 2. improve cost-effectiveness of fisheries and habitat enforcement; 3. optimize voluntary compliance of laws and rules to protect fish; 4. maximize the annual and long-term efficacy of enforcement efforts; and 5. maximize the accountability of the enhanced law enforcement program. 2. History: Accomplishments, Results, and Adaptive Management A brief financial history is provided. A review of conservation enforcement objectives and performance measures relative to those of other conservation enforcement projects (e.g., WDFW, ODFW and lower river tribes) was performed, and on this basis the plan for enforcement and RME was refined. New objectives and performance measures were established for protection of in-stream habitat, riparian zones, fish screening, salmon and steelhead fisheries. These new criteria were then adapted to best meet the tribal conservation enforcement program opportunities, efficiencies and effectiveness. A conservation enforcement work plan has been developed with a schedule of enforcement activities based on priority species, seasons, fishery locations and habitats for conservation enforcement. The first year of focused conservation enforcement has been completed. More than 1000 patrol hours were logged during this initial period in the Chinook and steelhead fisheries, 20 citations issued, and 374 contacts made. No arrests or seizures occurred. The proposal states that the project has been in place for one year and as yet has not made adaptive management changes. However, the description of project accomplishments describes adaptive changes that have been made to RME methods and design. The proposal states that an organized evaluation of desired and actual achievement (budget, personnel, equipment, coordination, contacts, warnings, arrests, seizures and critical habitat protected) will analyze the impact of the program. 3. Project Relationships, Emerging Limiting Factors, and Tailored Questions for Type of Work (Hatchery, RME, Tagging) Project relationships are described in general terms; no specific relationships to programs or projects are described, despite the obvious connection to the live-capture selective gear project (#200810500). Other projects will be supported and enhanced by the role of CCT Natural Resource Law Enforcement. Fisheries habitat enhancement projects, hatchery satellite facilities and restoration programs will be supported by the enforcement of regulations and a reduction in illegal activities such as poaching and vandalism. Wildlife mitigation acquisition projects will be maximized by reducing activities which illegally alter and impact habitats. Limiting factors for the Subbasin are described but are not related to this project or assessed in terms of how they might affect project success. 4. Deliverables, Work Elements, Metrics, and Methods Deliverables are described only for Objectives 1 and 3, and only in general terms. Objectives 2 (increase cost-effectiveness of enforcement), 4 (maximize the efficacy of enforcement), and 5 (maximize the accountability of enforcement) do not have deliverables, despite the description of Objective 5 as tied to performance indicators. Metrics and methods are not described for any of the five objectives.