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Response to Comments of the Independent Science Review Panel (ISRP) on Narrative Proposal (ISRP 2010-12)

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Response to Comments of the Independent Science Review Panel (ISRP) on Narrative Proposal (ISRP 2010-12) 1 Department of Energy Bonneville Power Administration P.O. Box 3621 Portland, Oregon 97208-3621 ENVIRONMENT, FISH AND WILDLIFE July 6, 2010 In reply refer to: KEW-4 Mr. Mark Fritsch Mr. Erik Merrill Manager, Project Implementation ISRP/ISAB Coordinator Northwest Power and Conservation Council Northwest Power and Conservation Council 851 SW 6th Ave, Suite 1100 851 SW 6th Ave, Suite 1100 Portland OR 97204-1348 Portland OR 97204-1348 Re: Upper Columbia Programmatic Habitat Project 2010-001-00 Response to Comments of the Independent Science Review Panel (ISRP) on Narrative Proposal (ISRP 2010-12) Dear Messrs. Fritsch and Merrill: Would you please forward this response to the ISRP for its further consideration of the proposed project referenced above? This response has three parts: Cover letter from the Bonneville Power Administration (Bonneville), including responses to some ISRP comments about the 14 existing projects that are ending. Submittal letter from the project proponents, the Upper Columbia Salmon Recovery Board (UCSRB), which includes detailed point-by-point responses to the ISRP’s comments. Revised narrative proposal from the UCSRB. All three documents are available in Pisces for public viewing under this project. I hope the ISRP and Council agree with us that the UCSRB has produced a very comprehensive and professional response. You may wish to read the UCSRB’s point-by-point responses before proceeding with this letter. The remainder of this letter complements the UCSRB’s response by addressing four ISRP comments about the 14 existing habitat projects in the Columbia Cascade Province and about the current review process (ISRP 2010-12): “At this point, the narrative does not…provide a summary of what has been learned from the 14 existing habitat projects….” (p. 2) 2 “[The ISRP] would like to see: 1. a concise and brief description of how existing habitat projects have been implemented and how well they are working in the subbasins of interest” (p. 2) “Since this programmatic proposal involves incorporating 14 projects that have had a history of funding, the technical justification and project history sections are insufficiently developed….The project history section needs to describe the status of the work completed…and what has been learned about the efficacy of recent actions.” (p. 4) “[The project proponents] should provide concrete examples of problems with the current review process and why the proposed process represents the best alternative.” (p. 5) [Note: I interpret “current review process” to refer to the regional categorical review and funding process for the Columbia Basin Fish and Wildlife Program.] We will consider the first three comments – those related to status and effectiveness of the current 14 projects – as a package, then apply the lessons learned to the current review process. The 14 Existing Projects Bonneville is in a better position than the UCSRB to speak to the history and performance of these projects. All of them were proposed and have been administered by entities other than the UCSRB, so the UCSRB bears no responsibility for them. Nevertheless, these projects compose a significant investment, and it is reasonable to wonder what they have accomplished and learned. Also, the projects are ending and will not participate in a future categorical review. In part for these reasons, Bonneville asked (and helped) the UCSRB to provide contextual summary information for these other projects in the Project History section of its original narrative proposal. Unfortunately, Bonneville’s guidance may have inadvertently created the impression that the UCSRB is somehow responsible for the 14 existing projects. No report cards exist for individual projects, let alone for a portfolio of projects like these. Certainly, annual progress reports are generally and publically available, while metrics, status reports, and a wealth of other details are provided in Pisces and Taurus. However, this information cannot be easily compiled and meaningfully measured against the work originally proposed or against other benchmarks. The ISRP may be asking for a meaningful overview. Table 1 (at the end of this letter) provides summary information that may partially satisfy the ISRP’s interests about implementation, accomplishments (i.e., work completed), and post- implementation monitoring. The following text elaborates on Table 1 at some length. A couple of the 14 projects from the FY07-09 review process were not implemented, while others were rather productive: 2 projects were not contracted, either because the proponent did not reach agreement with the respective stakeholders (2007-055-00) or because of a lawsuit regarding quantity of water to be diverted (2007-172-00, both shaded grey in Table 1). 3 1 project was contracted, but only got as far as Environmental Compliance before being delayed by another agency’s land acquisition process. Partial funding for actual construction was provided by another source (2007-214-00, also shaded grey). 1 project has been contracted and is still working on assessments that were conditions from the FY07-09 ISRP review and Council funding recommendation (2007-034-00). 4 projects are completed or will be completed by the end of their FY09 contracts (2007- 237-00, 2007-251-00, 2007-318-00, and 2007-400-00; all shaded green in Table 1). 6 remaining projects have work ongoing through FY10 within the approved scope of their FY07-09 proposals. Bonneville could sustain these projects with FY10 start-of- year budgets because they are programmatic in nature; they cover a type of habitat work within a geographic area. We have learned that projects may not reach full implementation for many reasons, and it helps to remember the ontogeny of these 14 projects. They were developed and proposed in 2005 and 2006 at Bonneville’s request to satisfy a nascent obligation under the Endangered Species Act/Biological Opinion (BiOp), referred to as the Updated Proposed Action (UPA). Bonneville’s request represented a significant expansion of funding to improve habitat in the Upper Columbia, and project proponents – most of whom were new to the Fish and Wildlife Program – stepped forward into foreign and challenging proposal and contracting processes with little time to plan and prepare. Proponents were asked to forecast and to describe specific actions up to four years in advance of implementation…no small feat for habitat restoration and protection efforts. Landowners and stakeholders change their minds, obstacles arise during environmental compliance and land acquisition processes, key staff become unavailable, priorities and opportunities change, proposal processes are delayed, legal challenges arise, etc. So, the issue is not simply whether a project was successfully implemented or not, but how we – the ISRP, the Council, and Bonneville – can best adapt and sustain an essential effort when things inevitably go awry with project implementation. The accomplishments of implemented projects can be described in several ways. For example, Pisces provides reports of project/contract metrics. However, the Pisces metrics for these FY07- 09 projects represent only a couple of years of on-the-ground work, because much of FY07 was occupied by contracting and ramp-up (e.g., design, permitting), and because some FY09 work is not yet completed and/or fully reported (in part because of how variable contract cycles relate to FYs). So, Pisces metrics capture some quantitative accomplishments, allowing for lag times in implementation and reporting. Accomplishments beyond quantitative metrics – like lessons learned, post-implementation effectiveness, and adaptive management – are generally available in each project’s annual progress reports. For example, some of the information presented in Table 1 for post- implementation monitoring was gleaned from those reports, from contract work statements, and from the FY07-09 project proposals. So, there is abundant and accessible information – both 4 quantitative and qualitative – about these 14 projects, but the challenge is to assemble it and to distill meaning from it. The ISRP’s desire for summary information suggests a need for a function – a role – that does not presently exist in the Upper Columbia. In this retrospective case, the need is for someone to gather relevant information from across 14 relatively disjointed projects, 5 project proponents, 3 years, and several data sources, then to summarize that information into a clear synthesis of progress and effectiveness; in essence, they are looking for an entity to be responsible for a sizable habitat program in the Upper Columbia/Columbia Cascade Province. The UCSRB proposes to accept that responsibility beginning in 2011. For now, this letter is the best we can do. In addition to project implementation and accomplishments, covered above, we might benefit from a few additional notes regarding accomplishments and lessons learned: Riparian enhancement projects (2007-035-00, 2007-086-00, and 2007-231-00) are achieving plant survivals of roughly 90% through the 1st year and 80% through the 2nd year, attributable to effective irrigation. Drip irrigation is superior to sprinklers, which encourage weed growth. Weed mats, browse protection, and follow-up weed control are essential; mulching is useful. Economies of scale may be achieved when funding/contracting flexibility enables multiple related actions to be implemented in concert. For example, 17 culverts on Chumstick Creek (Wenatchee) were replaced with standard-sized
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