1. Purpose: Significance to Regional Programs, Technical Background, and Methods

 

The proposal describes a well-organized and long term watershed scale restoration program that integrates upslope, floodplain/riparian, and instream treatments. It is a very successful partnership between Nez Perce tribe (NPT), the U.S. Forest Service, Potlatch Corp, and others. Work accomplished over the past 15 years, by the project, makes it a regionally important program. Additional detail and supporting information would provide the reader with better insights into the setting for the project. A location map and information on factors such as geology, ownership, legacies of historical land use would be useful.

 

A solid conceptual and technical background is provided, and there is a generally clear explanation and use of a variety of plans and assessments to drive selection of restoration work. It remains a little unclear on how projects were identified and prioritized in the first 10-15 years. Also, the proposal states that additional assessments for fish passage and road condition are needed. This seems a bit odd given that the project has been underway for over 15 years. There is a reference to protocols to be used, but a better explanation of why these are needed, how long they will take, and how the information will be used would be useful.

The proposal also notes that an MOA is being developed that will commit the U.S. Forest Service to provide at least 20% of the project cost presumably to qualify to receive BPA funding. This does not appear to be a requirement for any other state or federal agencies involved in the program and would be useful to find out the rationale given that a large share of the accessible habitat in this area is on NFS lands.

Five of the eight objectives provide a quantitative description of desired results however, there is no time element provided describing when the results are anticipated. Also, it is noted that a minimum level of increase in habitat productivity of 12-14% is needed in this watershed. There is no estimate or discussion of how the proposed work contributes toward reaching that increase or how much additional treatment is needed after the current round of funding (2014-18).

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

This project has a long list of project accomplishments that appear well linked to analysis of watershed, key processes, and habitat conditions. It has a long history and demonstrates a large amount of varied implementation and effectiveness monitoring that has been conducted. There are a number of results discussed that are based on the monitoring including: stream temperature reductions, reductions in substrate embeddedness and sediment source areas (roads), and an increase in habitat accessible to adult and juvenile salmonids.

There is a good discussion of how evaluation of results has led to changes/improvements in a variety of treatments including fish passage, road decommissioning and improvement, and riparian planting. An adaptive management approach of “assess, design, implement, monitor, evaluate, adjust, and repeat” is being used. To help evaluate biological responses to restoration work the project will use data collected by the Nez Perce Clearwater National Forest, IDFG, and BLM who are performing on the ground monitoring in the basin. Photos of completed actions were helpful, but dates taken should be indicated. It is not possible, however, to tell if the project is meeting expectations.

There is acknowledgement of previous ISRP comments regarding development of a more robust adaptive management approach, and it is stated that the NPT is in the process of developing a more formal plan that will be completed by December 2014. Some questions regarding project monitoring include:

1) The current discussion of fish data is not clearly described, but it is good to see data included. A better description is needed of the intent and protocols for snorkeling surveys that are conducted on an annual basis to assess population abundance, species composition, and age distribution. All values are based on presence/absence observations and are not necessarily reflective of true population estimates.

2) There are no clear indications of success from efforts to reduce sedimentation, although there is perhaps a minor positive change to water temperature. It is suggested that a treatment versus reference site comparison is needed.

Evaluation of Results

This project appears to be well thought out and coordinated, technically sound, and able to identify a number of possible, ecological results tied to major limiting factors. The project partnership has made good use of multiple funding sources and technical skills and resources from the primary partners. It remains a little less clear whether there has been a comprehensive review of treatments and results and a strategy for the identification and prioritization of future work needed to achieve the stated 12-14% increase in habitat productivity. Given its long history, it would be interesting to see an estimate of what is needed to accomplish this.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Climate change and invasive species were identified as emerging limiting factors. There is an excellent discussion regarding climate change, its likely effects to this watershed, and actions that have and will be taken in response. This discussion could serve as a model for other proposals as they examine implications of climate change. The sponsors are planning for possible effects by designing culvert and fish passage project for 100 year flood events and feel floodplain reconnections, riparian plantings, and other actions will help dampen the effects of warmer temperatures and altered precipitation patterns. Additional information and discussion on climate change effects to upland vegetation and future forest health and fire risk would have been useful. Also, some discussion of future development on private and industrial forest land and potential effects on this effort would have added to the discussion. Brook trout are identified as an invasive species that could negatively interact with native salmonids. No strategies are suggested for how this species should be managed in the future to reduce its potential impacts.

4. Deliverables, Work Elements, Metrics, and Methods

There is a list of 10 deliverables that include reasonable stated methods and metrics. Actions are listed that will be used to accomplish each deliverable and specific planned projects are mentioned. A couple of exceptions include riparian planting where only the number of plants to be planted is provided rather than riparian/floodplain area or length and a section on assessments which includes fish passage and road condition, each with no description of numbers or geographic area to be assessed. Given the large amount of work that has already occurred, it would have be useful to include a better discussion of why future assessments were needed, where they are to occur, when they will be completed, and how they will be integrated in to the ongoing list of project work.

Specific comments on protocols and methods described in MonitoringMethods.org

This includes a very good discussion about past monitoring and the use of results to inform the direction of the program. Five RM&E protocols are listed. Four of them plus their associated methods were developed by Washington State’s Salmon Recovery Funding Board. There is also a very complete discussion which addresses integration of ISEMP, CHAMP, and AEM in the future. It is unclear how PIBO monitoring, which has been ongoing for a number of years, will be coordinated or integrated into future CHAMP monitoring and whether the several years of data will be used. It appears that not doing this would be a waste of a significant long term data set and a missed coordination opportunity.

Status and details regarding the "to be completed" NPT Monitoring plan. These comments are contained in the discussion of programmatic comments

It is unclear whether there has been a comprehensive review of treatments and results and a strategy for the identification and prioritization of future work needed to achieve the stated 12-14% increase in habitat productivity. Given its long history, it would be interesting to see an estimate of what is needed to accomplish this. There are fish passage and road condition assessments that have to be completed and prioritized into the broader program of work. There is a reference to protocols to be used, but a better explanation of why these are needed, how long they will take, and how the information will be used would be useful. A more complete documentation of plans for this work would be useful and perhaps a review of completed documents accomplished in the future (1-2 years).

The sponsors need to provide a more serious discussion of past restoration project results and provide more details regarding anticipated benefits to fish and wildlife resources in a plan for future work.

1. Purpose: Significance to Regional Programs, Technical Background, and Methods

 

The proposal describes a well-organized and long term watershed scale restoration program that integrates upslope, floodplain/riparian, and instream treatments. It is a very successful partnership between Nez Perce tribe (NPT), the U.S. Forest Service, Potlatch Corp, and others. Work accomplished over the past 15 years, by the project, makes it a regionally important program. Additional detail and supporting information would provide the reader with better insights into the setting for the project. A location map and information on factors such as geology, ownership, legacies of historical land use would be useful.

 

A solid conceptual and technical background is provided, and there is a generally clear explanation and use of a variety of plans and assessments to drive selection of restoration work. It remains a little unclear on how projects were identified and prioritized in the first 10-15 years. Also, the proposal states that additional assessments for fish passage and road condition are needed. This seems a bit odd given that the project has been underway for over 15 years. There is a reference to protocols to be used, but a better explanation of why these are needed, how long they will take, and how the information will be used would be useful.

The proposal also notes that an MOA is being developed that will commit the U.S. Forest Service to provide at least 20% of the project cost presumably to qualify to receive BPA funding. This does not appear to be a requirement for any other state or federal agencies involved in the program and would be useful to find out the rationale given that a large share of the accessible habitat in this area is on NFS lands.

Five of the eight objectives provide a quantitative description of desired results however, there is no time element provided describing when the results are anticipated. Also, it is noted that a minimum level of increase in habitat productivity of 12-14% is needed in this watershed. There is no estimate or discussion of how the proposed work contributes toward reaching that increase or how much additional treatment is needed after the current round of funding (2014-18).

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

This project has a long list of project accomplishments that appear well linked to analysis of watershed, key processes, and habitat conditions. It has a long history and demonstrates a large amount of varied implementation and effectiveness monitoring that has been conducted. There are a number of results discussed that are based on the monitoring including: stream temperature reductions, reductions in substrate embeddedness and sediment source areas (roads), and an increase in habitat accessible to adult and juvenile salmonids.

There is a good discussion of how evaluation of results has led to changes/improvements in a variety of treatments including fish passage, road decommissioning and improvement, and riparian planting. An adaptive management approach of “assess, design, implement, monitor, evaluate, adjust, and repeat” is being used. To help evaluate biological responses to restoration work the project will use data collected by the Nez Perce Clearwater National Forest, IDFG, and BLM who are performing on the ground monitoring in the basin. Photos of completed actions were helpful, but dates taken should be indicated. It is not possible, however, to tell if the project is meeting expectations.

There is acknowledgement of previous ISRP comments regarding development of a more robust adaptive management approach, and it is stated that the NPT is in the process of developing a more formal plan that will be completed by December 2014. Some questions regarding project monitoring include:

1) The current discussion of fish data is not clearly described, but it is good to see data included. A better description is needed of the intent and protocols for snorkeling surveys that are conducted on an annual basis to assess population abundance, species composition, and age distribution. All values are based on presence/absence observations and are not necessarily reflective of true population estimates.

2) There are no clear indications of success from efforts to reduce sedimentation, although there is perhaps a minor positive change to water temperature. It is suggested that a treatment versus reference site comparison is needed.

Evaluation of Results

This project appears to be well thought out and coordinated, technically sound, and able to identify a number of possible, ecological results tied to major limiting factors. The project partnership has made good use of multiple funding sources and technical skills and resources from the primary partners. It remains a little less clear whether there has been a comprehensive review of treatments and results and a strategy for the identification and prioritization of future work needed to achieve the stated 12-14% increase in habitat productivity. Given its long history, it would be interesting to see an estimate of what is needed to accomplish this.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Climate change and invasive species were identified as emerging limiting factors. There is an excellent discussion regarding climate change, its likely effects to this watershed, and actions that have and will be taken in response. This discussion could serve as a model for other proposals as they examine implications of climate change. The sponsors are planning for possible effects by designing culvert and fish passage project for 100 year flood events and feel floodplain reconnections, riparian plantings, and other actions will help dampen the effects of warmer temperatures and altered precipitation patterns. Additional information and discussion on climate change effects to upland vegetation and future forest health and fire risk would have been useful. Also, some discussion of future development on private and industrial forest land and potential effects on this effort would have added to the discussion. Brook trout are identified as an invasive species that could negatively interact with native salmonids. No strategies are suggested for how this species should be managed in the future to reduce its potential impacts.

4. Deliverables, Work Elements, Metrics, and Methods

There is a list of 10 deliverables that include reasonable stated methods and metrics. Actions are listed that will be used to accomplish each deliverable and specific planned projects are mentioned. A couple of exceptions include riparian planting where only the number of plants to be planted is provided rather than riparian/floodplain area or length and a section on assessments which includes fish passage and road condition, each with no description of numbers or geographic area to be assessed. Given the large amount of work that has already occurred, it would have be useful to include a better discussion of why future assessments were needed, where they are to occur, when they will be completed, and how they will be integrated in to the ongoing list of project work.

Specific comments on protocols and methods described in MonitoringMethods.org

This includes a very good discussion about past monitoring and the use of results to inform the direction of the program. Five RM&E protocols are listed. Four of them plus their associated methods were developed by Washington State’s Salmon Recovery Funding Board. There is also a very complete discussion which addresses integration of ISEMP, CHAMP, and AEM in the future. It is unclear how PIBO monitoring, which has been ongoing for a number of years, will be coordinated or integrated into future CHAMP monitoring and whether the several years of data will be used. It appears that not doing this would be a waste of a significant long term data set and a missed coordination opportunity.

 

Modified by Dal Marsters on 6/11/2013 11:49:42 AM.

The proposal provides a well designed and thoughtful approach for the restoration of the Lochsa. It is process-based and provides a multi-disciplinary approach to implementing whole watershed restoration. It builds on a long standing and successful partnership between the NPT and the U.S. Forest Service and others. It has a solid track record of performance and has made positive changes over time, many apparently prompted by past ISRP review. The proposal provides a very complete and science-based approach for restoration that could be used as a template for other proposals in the basin. It is excellent to see such an improvement on experimental design and analysis.

The following paragraph from the Results section seems to hold several key issues. The ISRP believes the issues raised pertain to program-wide RME issues but feels the issues are worth stating here for the project sponsors to consider. "As shown in the Significant to Regional Programs and Technical sections, a substantial quantity of fisheries data has been collected in, and assessments developed for, the Lochsa River watershed. As these data were collected by other agencies for supplementation monitoring, fisheries abundance monitoring, U.S. Forest Service Clearwater National Forest Plan and EA/EIS and TMDL development,they provide useful baseline information but are not response signals to discrete restoration activities. As such, while this information is displayed to reflect data currently available within the project area, it is not suitable for evaluating efficacy of ongoing implementation actions. Future PRLWP implementation, compliance and action effectiveness monitoring will be addressed through the programmatic monitoring plan currently under development by the NPT Watershed Division and the programmatic action effectiveness monitoring program currently under development by BPA. Additionally, the PRLWP is hopeful that CHaMP surveys may be conducted in future years to address the relative lack of status and trend data available for the project area." We agree that fish population changes reflect many things going on in the fishes' universe and stream habitat is just a part. BUT changes in fish survival prior to smolting, their growth, and their distribution in rearing habitat are clearly the best indicators of habitat quality and quantity, including how it is altered and protected by the sponsors. So is it not the best indicator of what is really limiting and thus the best indicator to guide future actions?

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

This project is an important component of the effort to restore fish and habitat in the Clearwater subbasin. It is a merging of three prior individual projects (1996, 2002, and 2007) to increase administrative and financial efficiencies. It is a partnership effort between the Nez Perce Tribe and the U.S. Forest Service but involves others including the Idaho Department of Environmental Quality which has established TMDL's for sediment and thermal loading. There is a long record of cost sharing and development of a strong multi-disciplinary staff by the sharing of a wide array of diverse technical skills including engineering, soils, hydrology, and forestry in addition to fisheries scientists.

About 95% of the drainage is in National Forest System ownership and 5% in private industrial forest land, mainly in the headwaters. The proposal is clearly designed to establish a strategic foundation for restoration using an impressive array of the current science and literature regarding landscape and ecosystem restoration. There is a clear linkage discussing the prioritization of key processes to target for restoration including sediment introduction and transport and thermal loading of the streams and the development of priority projects using a variety of assessment tools and plans. A solid case is made that high road densities and steep slopes and erosive soils lead to high rates of sediment delivery to streams, particularly via mass wasting. The proposal employs a ridgetop to ridgetop approach of whole watershed treatments, and there is good use of citations throughout the introduction and description of objectives.

There is excellent use of the selected technical tools in the development of treatments and project plans including LIDAR imagery for roads analysis, temperature modeling for identification of priority treatment areas, and GRAIP modeling to select the most cost effective suites of road treatments for decommissioning and improvement.

There is very good use of past project-scale monitoring and evaluation to inform location and design of treatments. A particularly good example is the assessment of log sills which were installed in the 1990s for restoration and how information from that work has been used to alter the overall focus of the program such as targeting upslope sediment sources mainly due to roads and to confirm the viability of wood structures when used in the stream environment and the modification of their design to ensure juvenile fish passage.

An objective of at least 16% increase in habitat quality by 2018 is provided, but there is no discussion of how or when that is to be measured and by whom. It mentions a target of 3% for 2010-2012 but does not provide any information on if, or how well, that objective was met. It is offered that some increase in habitat quality has been found using 6 habitat attributes through PIBO monitoring, but the proposal is silent on whether that monitoring will continue or if/how it will be coordinated and integrated with CHAMP.

Second, the proposal talks about the benefits of focusing restoration in priority areas citing Reeves et al. 1995 and Frissel and Bayles 1996 that discusses identification of refugia and then building upon them. The proposal also discusses a Watershed Condition Framework and Action Plans that uses selection and focus of essential work in a single focus watershed. The proposal, however, does not identify which watersheds or Assessment units are the highest priority and which have been selected for near term treatment.

Seven objectives are identified, presumably for the time period 2014-2018. Three of these utilize quantitative measures and the remainder only provided metrics that will be used to measure them. There is no discussion of how these will be used or weighted in determining success or how or when that is to be done.

It appears that a good deal of project location, prioritization, and design is contingent upon ongoing assessments, especially for road decommissioning/improvement and fish passage restoration, yet there is no timeline provided for their geographic focus, timing or expected completion. Their phased completion for priority watersheds or their completion for the whole watershed would seem to be critical to ensure that the full suite of conditions are known at the time of project identification. Additionally, there is little quantification for each of the 13 deliverables that are identified which is likely a result of this situation.

The project has seven objectives. Each has a stated goal, but quantitative success or end points are often lacking. Objective 4 for example, is to restore vegetative diversity. Success is defined as number of acres planted, percent survival of transplanted plants, and control of noxious weeds. However, no quantitative end points are provided, how many acres might be planted per year, what is the survival goal of transplanted plants, what type of plant diversity and density per unit of area are being sought after, and how many acres might be treated for weeds on a yearly basis. Details like this help flesh out these objectives and provide a means for the project to assess its performance.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

The current project started in 2007 but is a combination of 3 projects that were being implemented separately with the oldest dating to 1996. A good deal of excellent ecological assessment, restoration, and implementation and effectiveness monitoring has been completed. It appears that there is some indication that past treatments are resulting in improved conditions, especially fish passage habitat quality (PIBO trend) and fine sediment less than 2mm (PIBO). Also, numerous improvements to the location and design of road, culvert, and instream LWD are reported as a result evaluating and utilizing data from past monitoring as well as the use of new science and technology including LIDAR, GRAIPS and ARC GIS Model Builder to improve the location and design of various road restoration treatments. Additionally, there have been changes in project direction and scope and a refinement of limiting factors through completion of the FCRPS BiOp and use of an expert panel.

There is a good discussion of the sponsor's response to past ISRP comments. Specific changes associated with monitoring and application of results and design of fish passage at road-stream crossings are described. Percent fines are measured at pool tail-outs, an approach that is probably more appropriate biologically than is often done by other projects, but seems to remain a consistency issue. "Despite ongoing sediment reduction efforts in the Imnamatnoon subwatershed, no conclusions can be drawn in relation to the WRP restoration efforts, due to location and the limited number of sample sites." It is also not clear how complete the response has been in addressing definitions for determining habitat diversity and complexity.

Evaluation of Results

There is a solid track record of results including an improved understanding of the watershed and implementation of a whole watershed suite of integrated, restoration treatments; evaluation and application of past monitoring to improve the design and effectiveness of many restoration treatments; and application of new science and techniques to improve the design and scope of the restoration program.

There appear to be serious impediments to completion of priority work relating to reducing road densities in key areas, with much of those areas in a checkerboard of private and National Forest Service ownership, and in the re-alignment and/or decommissioning of numerous valley bottom, stream adjacent roads which are reported to have significant socio economic issues. These are reportedly being worked on.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Three emerging limiting factors were identified, climate change, invasive species, and spills of fuel or chemicals. The potential effects of all of these limiting factors were clearly presented. Specific strategies to mediate their potential effects were not presented, however. Instead, it is hoped that restoring natural functions, for example, longitudinal and lateral connectivity in the riparian zone, eliminating passage barriers, and decommissioning roads will lessen the potential impacts of these factors. Another potential source of limiting factors, the failure to purchase private forest lands in the upper Lochsa was not specifically mentioned as an emerging issue. Some discussion should be directed to what steps the project may take if private forest lands cannot be purchased and instead are logged or developed. Impacts from these activities could compromise many of the downstream actions being proposed.

4. Deliverables, Work Elements, Metrics, and Methods

The project has 13 deliverablesand includes a number of important items, not often included in other proposals including the treatment of dispersed recreation sites, an outreach and education component and a program for conservation easement and land acquisition. However, mostof these are not described in quantitative terms apparently due to the fact that many projects are waiting the completion of various assessments or have not been fully-identified and designed. Explanations for why the work needs to be accomplished are provided, and in some cases, a general description of methods is also given. Elsewhere in the proposal specific goals, for example the number and location of planned culvert replacements, are provided. None of the actual work goals that would fall under a deliverable are mentioned making it difficult to determine how work will actually proceed over the course of the project. This type of detail should be included in the deliverables. Additionally, one deliverable covers project management. The activities described in deliverables 2, 5, and 7 should be combined into this deliverable as all of them appear to deal with project management topics.

Specific comments on protocols and methods described in MonitoringMethods.org

There has been a wide variety of past implementation and effectiveness monitoring. There are good examples of how this has provided findings that have had direct relevance in improving current project location, design, and effectiveness. It is mentioned that habitat status and trend information has been useful in this regard and is being provided by the PIBO monitoring program. Unfortunately, there is no discussion of the future status of this monitoring as the program begins using CHAMP.

There is recognition of new programmatic monitoring (AEM, CHAMP and ISEMP) and reported development of a watershed restoration monitoring plan to detail future integration into the ongoing program. This plan is to be delivered in the next 6-8 months, but there is no discussion as to its current status. This is mentioned in Programmatic Comments and review of this plan by ISRP would likely be beneficial.

===========QUALIFICATIONS FOLLOW================

This is a well-written proposal that reflects current science and the application of landscape scale/whole watershed restoration. The ISRP's qualifications listed below can be addressed in contracting and evaluated in future reviews.

More details are needed about specific, quantitative accomplishments that are expected over the life of the proposal. Currently, these are not provided for most deliverables. The objectives and deliverables need to be expanded to indicate explicit end points. The total amount of work that is expected to occur is clearly stated, it simply needs to be allocated to project years and specific deliverables.

A listing of the current focus watersheds that are a priority for treatment, a discussion of how they were selected and a summary of the strategic considerations would be useful.

It is pointed out that roads and associated issues are the primary factors limiting habitat productivity and that a large share of the worst road issues are on private land or located in valley bottom areas, both having major socio-economic issues impeding their correction. It would be useful to see a discussion as to whether the target of 16% habitat improvement can be achieved without treating these areas, and what groups of other treatments, on other areas, could provide the greatest benefit. Basically, this would be an alternative strategy/contingency plan to be followed if negotiations for a conservation easement or purchase are unsuccessful.

Additional detail is needed on monitoring and evaluation as tied to the NPT Plan that is currently in development. This is discussed in more detail under Programmatic Comments.

Consideration should be given to having the ISRP review the watershed restoration monitoring plan that will be completed within a year.

The proposal provides a well designed and thoughtful approach for the restoration of the Lochsa. It is process-based and provides a multi-disciplinary approach to implementing whole watershed restoration. It builds on a long standing and successful partnership between the NPT and the U.S. Forest Service and others. It has a solid track record of performance and has made positive changes over time, many apparently prompted by past ISRP review. The proposal provides a very complete and science-based approach for restoration that could be used as a template for other proposals in the basin. It is excellent to see such an improvement on experimental design and analysis.

The following paragraph from the Results section seems to hold several key issues. The ISRP believes the issues raised pertain to program-wide RME issues but feels the issues are worth stating here for the project sponsors to consider. "As shown in the Significant to Regional Programs and Technical sections, a substantial quantity of fisheries data has been collected in, and assessments developed for, the Lochsa River watershed. As these data were collected by other agencies for supplementation monitoring, fisheries abundance monitoring, U.S. Forest Service Clearwater National Forest Plan and EA/EIS and TMDL development,they provide useful baseline information but are not response signals to discrete restoration activities. As such, while this information is displayed to reflect data currently available within the project area, it is not suitable for evaluating efficacy of ongoing implementation actions. Future PRLWP implementation, compliance and action effectiveness monitoring will be addressed through the programmatic monitoring plan currently under development by the NPT Watershed Division and the programmatic action effectiveness monitoring program currently under development by BPA. Additionally, the PRLWP is hopeful that CHaMP surveys may be conducted in future years to address the relative lack of status and trend data available for the project area." We agree that fish population changes reflect many things going on in the fishes' universe and stream habitat is just a part. BUT changes in fish survival prior to smolting, their growth, and their distribution in rearing habitat are clearly the best indicators of habitat quality and quantity, including how it is altered and protected by the sponsors. So is it not the best indicator of what is really limiting and thus the best indicator to guide future actions?

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

This project is an important component of the effort to restore fish and habitat in the Clearwater subbasin. It is a merging of three prior individual projects (1996, 2002, and 2007) to increase administrative and financial efficiencies. It is a partnership effort between the Nez Perce Tribe and the U.S. Forest Service but involves others including the Idaho Department of Environmental Quality which has established TMDL's for sediment and thermal loading. There is a long record of cost sharing and development of a strong multi-disciplinary staff by the sharing of a wide array of diverse technical skills including engineering, soils, hydrology, and forestry in addition to fisheries scientists.

About 95% of the drainage is in National Forest System ownership and 5% in private industrial forest land, mainly in the headwaters. The proposal is clearly designed to establish a strategic foundation for restoration using an impressive array of the current science and literature regarding landscape and ecosystem restoration. There is a clear linkage discussing the prioritization of key processes to target for restoration including sediment introduction and transport and thermal loading of the streams and the development of priority projects using a variety of assessment tools and plans. A solid case is made that high road densities and steep slopes and erosive soils lead to high rates of sediment delivery to streams, particularly via mass wasting. The proposal employs a ridgetop to ridgetop approach of whole watershed treatments, and there is good use of citations throughout the introduction and description of objectives.

There is excellent use of the selected technical tools in the development of treatments and project plans including LIDAR imagery for roads analysis, temperature modeling for identification of priority treatment areas, and GRAIP modeling to select the most cost effective suites of road treatments for decommissioning and improvement.

There is very good use of past project-scale monitoring and evaluation to inform location and design of treatments. A particularly good example is the assessment of log sills which were installed in the 1990s for restoration and how information from that work has been used to alter the overall focus of the program such as targeting upslope sediment sources mainly due to roads and to confirm the viability of wood structures when used in the stream environment and the modification of their design to ensure juvenile fish passage.

An objective of at least 16% increase in habitat quality by 2018 is provided, but there is no discussion of how or when that is to be measured and by whom. It mentions a target of 3% for 2010-2012 but does not provide any information on if, or how well, that objective was met. It is offered that some increase in habitat quality has been found using 6 habitat attributes through PIBO monitoring, but the proposal is silent on whether that monitoring will continue or if/how it will be coordinated and integrated with CHAMP.

Second, the proposal talks about the benefits of focusing restoration in priority areas citing Reeves et al. 1995 and Frissel and Bayles 1996 that discusses identification of refugia and then building upon them. The proposal also discusses a Watershed Condition Framework and Action Plans that uses selection and focus of essential work in a single focus watershed. The proposal, however, does not identify which watersheds or Assessment units are the highest priority and which have been selected for near term treatment.

Seven objectives are identified, presumably for the time period 2014-2018. Three of these utilize quantitative measures and the remainder only provided metrics that will be used to measure them. There is no discussion of how these will be used or weighted in determining success or how or when that is to be done.

It appears that a good deal of project location, prioritization, and design is contingent upon ongoing assessments, especially for road decommissioning/improvement and fish passage restoration, yet there is no timeline provided for their geographic focus, timing or expected completion. Their phased completion for priority watersheds or their completion for the whole watershed would seem to be critical to ensure that the full suite of conditions are known at the time of project identification. Additionally, there is little quantification for each of the 13 deliverables that are identified which is likely a result of this situation.

The project has seven objectives. Each has a stated goal, but quantitative success or end points are often lacking. Objective 4 for example, is to restore vegetative diversity. Success is defined as number of acres planted, percent survival of transplanted plants, and control of noxious weeds. However, no quantitative end points are provided, how many acres might be planted per year, what is the survival goal of transplanted plants, what type of plant diversity and density per unit of area are being sought after, and how many acres might be treated for weeds on a yearly basis. Details like this help flesh out these objectives and provide a means for the project to assess its performance.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

The current project started in 2007 but is a combination of 3 projects that were being implemented separately with the oldest dating to 1996. A good deal of excellent ecological assessment, restoration, and implementation and effectiveness monitoring has been completed. It appears that there is some indication that past treatments are resulting in improved conditions, especially fish passage habitat quality (PIBO trend) and fine sediment less than 2mm (PIBO). Also, numerous improvements to the location and design of road, culvert, and instream LWD are reported as a result evaluating and utilizing data from past monitoring as well as the use of new science and technology including LIDAR, GRAIPS and ARC GIS Model Builder to improve the location and design of various road restoration treatments. Additionally, there have been changes in project direction and scope and a refinement of limiting factors through completion of the FCRPS BiOp and use of an expert panel.

There is a good discussion of the sponsor's response to past ISRP comments. Specific changes associated with monitoring and application of results and design of fish passage at road-stream crossings are described. Percent fines are measured at pool tail-outs, an approach that is probably more appropriate biologically than is often done by other projects, but seems to remain a consistency issue. "Despite ongoing sediment reduction efforts in the Imnamatnoon subwatershed, no conclusions can be drawn in relation to the WRP restoration efforts, due to location and the limited number of sample sites." It is also not clear how complete the response has been in addressing definitions for determining habitat diversity and complexity.

Evaluation of Results

There is a solid track record of results including an improved understanding of the watershed and implementation of a whole watershed suite of integrated, restoration treatments; evaluation and application of past monitoring to improve the design and effectiveness of many restoration treatments; and application of new science and techniques to improve the design and scope of the restoration program.

There appear to be serious impediments to completion of priority work relating to reducing road densities in key areas, with much of those areas in a checkerboard of private and National Forest Service ownership, and in the re-alignment and/or decommissioning of numerous valley bottom, stream adjacent roads which are reported to have significant socio economic issues. These are reportedly being worked on.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Three emerging limiting factors were identified, climate change, invasive species, and spills of fuel or chemicals. The potential effects of all of these limiting factors were clearly presented. Specific strategies to mediate their potential effects were not presented, however. Instead, it is hoped that restoring natural functions, for example, longitudinal and lateral connectivity in the riparian zone, eliminating passage barriers, and decommissioning roads will lessen the potential impacts of these factors. Another potential source of limiting factors, the failure to purchase private forest lands in the upper Lochsa was not specifically mentioned as an emerging issue. Some discussion should be directed to what steps the project may take if private forest lands cannot be purchased and instead are logged or developed. Impacts from these activities could compromise many of the downstream actions being proposed.

4. Deliverables, Work Elements, Metrics, and Methods

The project has 13 deliverablesand includes a number of important items, not often included in other proposals including the treatment of dispersed recreation sites, an outreach and education component and a program for conservation easement and land acquisition. However, mostof these are not described in quantitative terms apparently due to the fact that many projects are waiting the completion of various assessments or have not been fully-identified and designed. Explanations for why the work needs to be accomplished are provided, and in some cases, a general description of methods is also given. Elsewhere in the proposal specific goals, for example the number and location of planned culvert replacements, are provided. None of the actual work goals that would fall under a deliverable are mentioned making it difficult to determine how work will actually proceed over the course of the project. This type of detail should be included in the deliverables. Additionally, one deliverable covers project management. The activities described in deliverables 2, 5, and 7 should be combined into this deliverable as all of them appear to deal with project management topics.

Specific comments on protocols and methods described in MonitoringMethods.org

There has been a wide variety of past implementation and effectiveness monitoring. There are good examples of how this has provided findings that have had direct relevance in improving current project location, design, and effectiveness. It is mentioned that habitat status and trend information has been useful in this regard and is being provided by the PIBO monitoring program. Unfortunately, there is no discussion of the future status of this monitoring as the program begins using CHAMP.

There is recognition of new programmatic monitoring (AEM, CHAMP and ISEMP) and reported development of a watershed restoration monitoring plan to detail future integration into the ongoing program. This plan is to be delivered in the next 6-8 months, but there is no discussion as to its current status. This is mentioned in Programmatic Comments and review of this plan by ISRP would likely be beneficial.

===========QUALIFICATIONS FOLLOW================

This is a well-written proposal that reflects current science and the application of landscape scale/whole watershed restoration. The ISRP's qualifications listed below can be addressed in contracting and evaluated in future reviews.

Modified by Dal Marsters on 6/11/2013 9:38:20 AM.

The sponsors were indeed correct in their concern that part of the results section of the original proposal was not seen by reviewers prior to their preliminary response; reviewers were not aware during the initial review of a comment in the “Notes” section or the availability of a hotlink.

The sponsors’ response was comprehensive and adds sufficient detail to the original proposal to effectively address nearly all of the issues raised by the ISRP. There was a good deal of additional data provided, and it is apparent that the sponsors want to work in a strategic manner. Selection of three top priority watersheds is an excellent start.

The summary of the prioritization process to rank activities (to work initially in highest ranked Assessment Units according to the 2009 Strategy document, then work from the top of a subwatershed down, with focus on major limiting factors) is more informal than that used in other areas (where many more jurisdictions are involved). Detail of how the rankings were generated was not described, except to indicate that they are generated from the Expert Panel process.

What seems incomplete is a better discussion and listing of the full suite of priority work requiring completion in these watersheds before moving into the next tier of priority watersheds. Currently, work is focused on three limiting factors and is reportedly achieving the benchmarks established by the technical team. How it was determined that the planned work will meet these benchmarks (stated as percentage increases) remains a bit of a mystery. In the response, only water temperature was discussed. A similar discussion is needed to address flow increases and for riparian vegetation/floodplain restoration. Further, there needs to be additional discussion on addressing fish passage (see Qualification) and increased sedimentation. These limiting factors are rated nearly as high as the priority limiting factors (10% each vs. 15%) yet are really not incorporated beyond past work that has occurred.

There were no changes in the stated project objectives to include a time element, as recommended by the ISRP. Also, the description of ecological results from past restoration project work is very limited, despite nearly 10 years of work.

Goals for restoration were presented. The goals, if reviewers interpreted them correctly, were ambitious. However, habitat monitoring will not occur until 2018, and therefore it will take considerable time before we will know how much of the proposed goal has been achieved. Plus, we know little about monitoring efforts that might occur in 2018.

Evaluation of Results

The following documents were prepared under the project:
1) a comprehensive watershed analysis using the Oregon Watershed Assessment Manual
2) Clearwater Subbasin Assessment and Plan
3) the Lapwai Creek Watershed Ecological Restoration Strategy
4) Road Erosion Survey - Lapwai Creek Watershed
5) Lapwai Creek Watershed Ecological Restoration Strategy that prioritizes where restoration work should occur within the Lapwai Creek watershed.

The projects implemented by the sponsor between 2009 and 2012 are as follows:

•  1,5800.0 feet of riparian exclusion fence
•  850.0 ft of levee removal
•  720.0 ft of bank stabilization
•  25.0 acres planted to native grasses
•  9.0 acres of riparian shrub and tree planting
•  7.0 acres of restored wetland

For fish passage, it is stated that 60% of the historical habitat has been blocked and that two of the highest priority projects, out of a total of twelve, have been completed and two additional ones are awaiting agreement with the Bureau of Reclamation (BOR). Reviewers note that priority passage work other than that identified with BOR does not seem to be incorporated into the current five year plan and this seems out of line with a comprehensive restoration program. The ISRP realizes that passage projects might indeed be planned but not mentioned in the proposal or, if perhaps habitat above barriers also needs restoration, the sponsors might choose to focus first on that habitat. This issue can be resolved during the contract process.

A response is requested on the following items:

1) Describe how deliverables were ranked in the prioritization process.

2) Give examples of restoration actions that were considered but not implemented.

3) Provide responses to additional questions embedded in review comments.

This is a generally well-organized project. However, a response is requested to provide additional detail on past results and prioritization of future actions. The presentation and site visits were helpful on these issues, but they should be better documented in a response.

It was not clear how each of the specific deliverables were ranked in the prioritization process and how much effect the deliverable might have, for example move road rest stops to non-creek side. The selection of focus stream assessment units appears to have been a solid strategic approach, and additional information describing the suite of planned activities in these areas would have been useful. What are the alternative restoration actions that were considered and not adopted?

This is a good proposal in many respects that includes quantitative deliverables for a variety of specific habitat projects. The deliverables are categorized under three objectives that relate to limiting factors in the watershed, as described by previous efforts. However, the sponsors did not discuss the extent to which each limiting factor will be improved after completing the deliverables. Are these proposed projects the highest priority projects? This type of information would provide managers with some information on how much more effort is needed.

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

This is a coordinated proposal, along with its companion proposal from the Nez Perce SWCD, for a tributary that is a primary producer of A-run steelhead in the Clearwater River system. It is well organized and provides solid focus on three high priority stream assessment units within Lapwai Creek. This proposal provides good technical background information that demonstrates the significance of the project objectives to regional programs.

A list of 10 limiting factors is presented, and it is stated that the proposal will address the primary ones. These are not listed. Three main objectives are provided: restore flow/wetlands, reduce stream temperature and improve habitat diversity. To some extent, quantitative deliverables and objectives were presented so reviewers and stakeholders have a good idea of what may be accomplished by this effort. However, temperature and habitat objectives are stated in quantitative terms but have no stated time frame for accomplishment. Objectives are basically reasonable, but the temperature goal of reducing temperature below 16 C, a State of Idaho water quality metric is overly conservative, especially in view of actual Lapwai Creek fish data: the Nez Perce SWCD proposal states "Significantly, wild steelhead of the Lower Clearwater basin have seemingly adapted to survive abnormally warm water temperatures. High juvenile steelhead densities have been recorded within monitoring sites in which summer water temperatures exceeded 20º C (68º F) on a daily basis." Reviewers challenge the NPT Watershed staff to craft more meaningful success criteria for habitat attributes like temperature as these projects evolve.

Importantly, the proposal is based upon and justified by the Lower Clearwater Watershed Ecological Restoration Strategy developed jointly with the SWCD. The Strategy was apparently developed in 2009 and is reported to, and does address a number of issues previously raised by ISRP. Because of this critical dependence of the proposal on that document, a serious effort should have been made to facilitate its access for reviewers. It was available in the Project Documents section but that required additional effort to locate it. Ideally excerpts from the Strategy would have been incorporated into the proposal. Next best would have been a hot link directing reviewers to specific sections.

The proposal notes that there has been little hatchery influence in Lapwai watershed, yet coho have been recently introduced. Approximately 400 adults return per year, but no mention of hatchery/natural origin components is included. The proposal does not mention how ecological interactions between coho and steelhead might affect steelhead recovery.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

The project has been ongoing since 1999. Accomplishments during each year were very briefly mentioned. Instead of providing detail, sponsors make the statement that "Projects implemented since 2009 have followed the guidance produced by the Lapwai Creek Watershed Ecological Restoration Strategy." This is reassuring but does not contain enough detail to be helpful to reviewers.

There is not a formal Adaptive Management strategy, but there is a discussion of lessons learned for project and management activities. The discussion on management considerations is vague as to lessons learned or changes in organization or approach. The proposal did describe how sponsors have learned from previous projects, for example use larger plants and water them as a means to increase survival. The project should document percentage survival of its planting efforts.

The adaptive management section also describes use of expert panels to prioritize actions, following the Restoration Strategy. A commendable inclusion was incorporation of the assessment of both current and potential, as a percent of optimal, status of limiting factors addressed by a project. Examples of this would have been very helpful. For example, reconnecting and restoring wetlands is a primary strategy for increasing water storage and increasing base flows, but there is no discussion of the extent to which past treatments appear to be doing that.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

There is an efficient division of duties with the NPT dealing with Tribal and public lands and the SWCD addressing private lands.

The use of the general and aquatic limiting factors shown above in the assessment provides a starting point for the identification and treatment of problems affecting anadromous populations throughout the Clearwater. Climate change and non-native species were identified as emerging limiting factors. The project has been in operation for more than 10 years. It would be interesting to know whether or not there seems to be improvement in some of the overall habitat metrics and even steelhead productivity. In other words, based on the restoration plan and analysis of limiting factors, has the program achieved 5% or 50% of its habitat goals? What is the timeline for achieving the habitat goals?

4. Deliverables, Work Elements, Metrics, and Methods

There are three primary deliverables that are stated in clear, quantitative terms. However, they appear to address only the first year of implementation. Other deliverables were described in a couple of sentences and are impossible for reviewers to evaluate without more detail, photos, and maps. The deliverables should have been more closely linked to limiting factors, including to what extent each deliverable might help reduce that limiting factor. Is the impact small or significant, in the opinion of the sponsors? Some detail is needed on why the secondary deliverables received their given priorities.

A fish passage assessment was completed in either 2004 or 2005 and will presumably provide a foundation for future project work.

Monitoring (and associated methods) is largely associated with other programs within the Tribe and by other agencies, and therefore there was little discussion of methods. There is a clear description of future incorporation of AEM and CHaMP into watershed activities. It is noted that BOR has the lead responsibility for fish population monitoring although there is little discussion how this work links to the location and application of various restoration treatments.

Modified by Dal Marsters on 9/27/2013 11:01:14 AM.

General comments concerning Nez Perce Tribe proposals to "protect and restore" various watersheds:

Justifications need to address several questions for each individual project:

1. What was the historic and current status and importance of the focal species population(s) in this watershed?
2. What was the historic and current condition of the habitat?
3. What is the potential to restore this watershed?
4. And if restored, what contribution will this project make to the focal species' future?

The sponsors are encouraged to formulate a separate proposal to monitor and evaluate all such projects together with the entire budget devoted to this activity. This would provide consistency across projects, facilitate discovering the best methodologies to implement and monitor such projects, ensure the foundation for successful adaptive management, and reduce the monitoring burden on implementation teams. Linking to the Nez Perce Tribal Fish Hatchery monitoring would be an efficient way to deal with fish response while habitat factors could be evaluated separately, thus accounting for the fact that single habitat projects alone may be difficult to link to future fish response. The exception to this would be the relatively simple before/after monitoring of fish use and abundance above and below current passage barriers, which could be monitored as part of the individual habitat projects.

Removing passage barriers can - but not necessarily will - result in increased fish production. Thus the ISRP seeks justification of each specific project based on the quality and quantity of habitat above a barrier (not just miles of stream) and the potential increase in fish use and benefit. Risks associated with exotic fish species should also be included. A quantitative evaluation of habitat quality and quantity above each barrier should play a major role in prioritizing barrier replacement/removal projects. Similar logic can be followed for other projects (such as road decommissioning or weed management).

Several proposals included weed control, but no species or strategies were included. The only identifiable budget items were herbicide-related, which alone does not constitute a supportable strategy. Establishment or improvement of desirable alternative vegetation was not described. The sponsors should ensure that integrated pest management practices are followed and include quantifiable population or species distribution goals. Projects should employ a landscape level perspective. Developing such a program may require a cooperative effort with other landowners and agencies involved in invasive species control.

ISRP comments specific to this proposal 199607702:

The project's purpose is to rehabilitate stream and riparian processes in the Lolo Creek watershed that were damaged by human activities: logging, road building, mining, farming, and grazing. Chinook salmon and steelhead are the focal species that are to benefit from improved habitat. Five other salmonid species are involved. The sponsors see disrupted sediment regimes as a major problem. To resolve it, they will focus work on road obliteration and streambank stabilization. The latter involves bioengineering methods and riparian plantings. They also will replace culverts that block fish passage.

The ISRP agrees that the project will benefit the focal and non-focal species and recommends that it is fundable.

Note: Some of the sponsors' response to ISRP comments was done in ways that required much time-consuming further review. The main problem was brief reference to lengthy attached documents instead of writing direct answers.

The ISRP found that the proposal adequately analyzed problems and showed significance to regional programs and relationships to other projects.

The proposal's project history section was inadequate. It did not include quantified evidence of the project's physical and biological results. The ISRP asked for a response on effectiveness of project activities in terms of habitat created or improved and in terms of fish produced. The sponsors did not rewrite the project history but instead attached a 94-page report on (rather preliminary) physical and biological monitoring of Lolo Creek—and asked for ISRP comments on it. The report contains much data and some brief analyses from measurements of 11 parameters, covering the years 2003 to 2005, apparently the first period in which this monitoring was done for the 10-year-old project. Therefore, little or no time-trend information exists, but it was helpful to see the report's methods. In the future, it would be more helpful for the sponsors to summarize pertinent material from such reports in the proposal itself.

The sponsors added that their project is minimally funded for biological M&E, and they referred to fish population monitoring being done under project #198335003. It would be appropriate for the sponsor to present and interpret data from that other project in the present project's proposal.

In addition, the sponsors attached reports on monitoring of the road decommissioning effort and of culvert replacement (41 pages in total). Again, the results embodied in these reports should have been incorporated in the narrative proposal's project history.

The ISRP commented that the general thrust of the objectives is sound, but their organization and clarity could be improved. The difference between certain objectives was unclear and needed to be rethought and reorganized and clarified in a response. The sponsors did this in editing their revised proposal. (But instead of describing the changes in the response document, they just said there that they had done it, forcing reviewers to spend much time and expense searching and comparing texts of the original and revised proposals to find out what the changes were.)

The proposal inadequately described monitoring and evaluation (M&E) plans. In particular, the methods for biological M&E were unacceptably sketchy. ISRP asked sponsors to present a thorough M&E program, including the appropriate statistical design. In response, the sponsors pointed to lack of direction and agreement within the Columbia Basin on monitoring strategies, again referenced the monitoring report for 2005, and said they would appreciate ISRP "input." They say that the NPCC limitation of 5% of project budget for M&E will prevent them from implementing "the monitoring plan in the future, to its full capacity." Review of their attached monitoring reports indicates that judicious sampling design improvements by statistical consultants (possibly including omission of some parameters) might reduce the M&E program's size without hampering effectiveness. This project's M&E value may be much reduced by lack of pre-construction measurements.

The ISRP recommended that, in the response loop, the Nez Perce Tribe prioritize and rank the numerous proposals submitted under "protect and restore" titles. This was covered in response attachments.

This is an ISRP response to the fix it loop for proposal 199901700 Protect and Restore Lapwai Creek Watershed (NPT) and 200207000 Lapwai Creek Anadromous Habitat (NPSWCD) - integrated sister projects to address habitat restoration and protection on Lapwai Creek on tribal and private land, respectively.

The sponsors addressed the questions raised by the ISRP in the preliminary review. The adequacy of the answers varied by question. The ISRP thanks the sponsors for the time and effort in producing the revised proposal narrative and explanations of the projects' history.

The ISRP had many questions for the sponsors, so the evaluation of the response to each is beyond the space and time available in this fix it loop review. Briefly, the proposal(s) were to execute tasks related to both inventory and assessment of fish populations and habitat, and habitat restoration implementation. From the proposal it was not clear to the ISRP how important to the focal species the watershed was; the focal species current status in the watershed; the role the watershed could contribute to the focal species' status if restored; if the watershed could be restored; and how long it would take.

Replies were provided to the ISRP's questions and a revised narrative was produced. The answers to the questions and the narrative revision go a long way to clarifying for the ISRP the status and progress of anadromous fish species (primarily steelhead) and restoration potential in this watershed. Much more is needed however, before the ISRP can confidently assess whether the proposed activities in the Lapwai Creek system are scientifically sound, have quantifiable biological objectives that are measurable, and will benefit fish and wildlife (A-run steelhead).

Sponsors indicate that it became apparent early in the project history (1999) that insufficient data existed to effectively address improving the status of anadromous fish in Lapwai Creek. Little was known about the status of the fish or the habitat. In the intervening period the sponsors state they have treated "hot spots" of habitat degradation, and nearly completed inventories of habitat conditions and fish population status. They report that inventory work will be completed in 2006 and that evaluation and analysis should be prepared in 2007.

In the current revised narrative the biological objectives are tasks. The sponsors provide an ultimate goal: "to protect and restore the ecological and biological functions of the Lapwai Creek Watershed to assist in the recovery of anadromous and resident fish species," and this is reasonable. What is needed is a specific goal, with a timeframe for changes in habitat conditions and fish population abundance and productivity. Sponsors clarify for the ISRP their understanding of compliance and effectiveness monitoring, and inform the ISRP that they appreciate the necessity of effectiveness monitoring, but that it is beyond the willingness of Council and BPA to fund those data collections and analysis. The ISRP understands the constraints placed on sponsors, but also believes sponsors need to be creative in developing methods to determine whether their restoration efforts are providing a benefit. Can riparian habitat be evaluated by photopoints or aerial photography and be cost effective, how can stream flow and stream temperature be monitored? How can adult fish in and smolts out be measured?

Sponsors indicate that stream habitat and watershed inventories, and fish population abundance will be completed soon and final assessments available in 2007. Based on that commitment, these projects are Fundable in Part (incrementally). In 2007, fundable only for completion of the inventory and assessments. Possibly fundable in 2008 and 2009 for restoration actions contingent upon a proposal narrative that uses those assessments to establish biological objectives, strategies and actions to get to those objectives, and an approach to measure whether progress is being made in achieving the objectives.

For full comments on "restore and protect" type projects, please see heading "General comments concerning Nez Perce Tribe proposals to protect and restore various watersheds" at the beginning of the ISRP comments on project # 199607702, Protect & Restore Lolo Creek Watershed.