FY07-09 proposal 200705400

Jump to Reviews and Recommendations

Section 1. Administrative

Proposal titleEntiat River - UPA - Stillwater Restoration Project
Proposal ID200705400
OrganizationChelan County Conservation District (SWCD)
Short descriptionEnhance instream habitat complexity and reduce sediment delivery to salmonid spawing habitat from rapidly eroding streambank using LWD placement in 0.5 miles of the Stillwater Reach of the Middle Entiat AU. Riparian revegetation will occur along 0.1 mile
Information transferPublic Access: Chelan County Conservation District Web-Site. EKO-system project tracking portal (in development). Conservation District newsletters and reports.
Proposal contact person or principal investigator
Contacts
ContactOrganizationEmail
Form submitter
Rich Malinowski Chelan County Conservation District rich.malinowski@wa.nacdnet.net
All assigned contacts
Rich Malinowski Chelan County Conservation District rich.malinowski@wa.nacdnet.net
sarah walker Chelan County Conservation District sarah-walker@wa.nacdnet.org

Section 2. Locations

Province / subbasin: Columbia Cascade / Entiat

LatitudeLongitudeWaterbodyDescription
47 86.24 120 42.08 Entiat River Stillwater Restoration

Section 3. Focal species

primary: All Anadromous Salmonids
secondary: Chinook Upper Columbia River Spring ESU
secondary: Steelhead Upper Columbia River ESU
secondary: Westslope Cutthroat
secondary: Pacific Lamprey
secondary: Bull Trout
secondary: Mountain Whitefish
secondary: Other Resident

Section 4. Past accomplishments

YearAccomplishments

Section 5. Relationships to other projects

Funding sourceRelated IDRelated titleRelationship
BPA 200500300 Entiat Four Mile-Wells The Entiat 4 Mile diversion is located in the lower Entiat Assessment Unit of the Entiat subbasin, and will benefit Upper Columbia steelhead, spring Chinook and bull trout. The goal of this project is to prevent juvenile fish from being diverted into an out-of-stream irrigation system and to eliminate impacts due to the annual maintenance of an instream pushup dam. The objectives include eliminating a surface irrigation diversion and replacing it with two wells, which will provide BPA and the Bureau of Reclamation (Reclamation) with a Federal Columbia River Power System (FCRPS) BiOp metric credit of one (1). Wells were chosen over a new fish screen based on biological benefits and costs. Long-term biological benefits are provided by completely eliminating the surface diversion and the potential for fish entrainment in a fish screen. Construction costs for a new fish screen were estimated at $150,000, which does not include other costs associated with implementing and maintaining a fish screening project. Construction costs for a well are estimated at $20,000 each. The diversion currently consists of a pushup dam that diverts water into an off-channel pond. Water is then pumped into a pressurized system for irrigation. There are 3 different irrigators who use water from this surface diversion, and each has multiple water rights. Some irrigated acreage was taken out of orchard production less than 5 years ago. Therefore, approximately 144 acre-feet will be put into a water trust so it is not subject to relinquishment. No water will be set aside for conservation savings. The project is part of the Entiat Watershed Planning Unit's overall approach to salmonid population restoration within the lower Entiat AU.
BPA 200500400 Whitehall Wells The Whitehall Diversion project is located in the Entiat subbasin, lower Entiat Assessment Unit, and will benefit Upper Columbia steelhead, spring chinook and bull trout. The goal of this project is to prevent juvenile fish from being diverted into an out-of-stream irrigation system. The objectives include eliminating four unscreened surface irrigation diversions and replacing them with three wells, which will provide BPA with a HIP BiOp metric credit of four (4). One of the surface water diversions and associated sump and pump for irrigation water lies within the off-channel area proposed for restoration. Completion of the Whitehall wells project will enable full off-channel restoration. This project is part of the Entiat Watershed Planning Unit's overall strategy for restoration of salmonid populations within the lower Entiat AU.
BPA 200301700 Integrated Status/Effect Progr The Entiat Effectiveness Monitoring Study will measure the extent to which the Bridge-to-Bridge Habitat Restoration Project in the lower Entiat River affects (a) fish habitat, (b) fish habitat utilization, and (c) the productivity of salmonid fishes in the Entiat Subbasin, and will test aspects of the Monitoring Strategy for the Upper Columbia Basin (Hillman 2004) that pertain to effectiveness monitoring. Surveys of fish habitat and fish habitat utilization supported by this Study will be synthesized with separately-funded, yet compatible, agency monitoring programs to include all of the indicators specified for study in Hillman (2004). Coordination with landowners and the local Watershed Planning Unit are built into this Study design. The Study will monitor treatment and control reaches of the Entiat Subbasin, and utilize an ecological landscape classification system that has been recently developed (by BPA and Upper Columbia Salmon Recovery Board) to support effectiveness monitoring, and quantify Project-related changes in several indicators: Ideally, the Study will be implemented over a 10 year period. This duration is dependent upon funding. To start, a minimum of five years participation has been solicited from willing private landowners. An extended monitoring time frame is necessary to account for at least two salmonid generations (4-5 years per generation), to capture pre and post-restoration project conditions, interannual variability, long-term channel adjustments resulting from the restoration project, and possible changes to restoration project features that might arise from periodic factors like large runoff events.
PCSRF - WSRFB 00-1167 Jon Small Off-Channel Rearing WDFW, trout unlimited and a private landowner created a rearing pond, fed by a groundwater upwelling, and off-channel connection to the mainstem Entiat River within the lower Entiat Assessment Unit. The project was designed and implemented to increase juvenile salmonid off-channel rearing and overwintering habitat, and address a primary limiting factor for salmonid production in the lower Entiat River. Similar off-channel rearing pond connection will occur in the Lower River Off-Channel Restoration.
PCSRF - WSRFB 04-1503 Entiat R. BridgeToBridge Reach The Chelan County Conservation District is the Project Sponsor for the “Bridge-to-Bridge” (B-to-B) reach restoration project in the lower Entiat River (~RM 3.2 to RM 4.4). Other project partners include Chelan County, WDFW, USFWS, members of the UCSRB Regional Technical Team, and BOR. This area is the highest priority restoration area in WRIA 46. Past activities that have altered the lower Entiat River include logging, dams, stream clearing; channelization, filling & flood control protection works. Riparian vegetation has been removed by fire & development. The B-to-B effort addresses lack of off-channel rearing habitat, temperature extremes & habitat simplicity. It will restore geomorphology, floodplain function, habitat complexity/diversity, off-channel habitat and shading, benefiting adult & juvenile Chinook, steelhead & coho. At the end of Phase 3, the reach will be restored to its geomorphic potential (e.g. now 0.3 pools/mi., restored to 9 pools/mi.). The EWPU supports this 3-phase project, developed via 10 years of planning. Actions proposed are based on geomorphic, biologic, hydrologic & thermal analyses. Funding for Phase 1 will be used to: (a) restore ~1000 contiguous ft. of riparian vegetation to improve stream temperatures, bank condition, cover, nutrient inputs; (b) enhance juvenile off-channel rearing habitat via rock/LWD placement in ~700 ft. irrigation ditch; (c) install 2 instream structures to direct flow to the off-channel habitat and restore resting pools in the lowest portion of the reach. A ditch outfall structure will also be added.
Other: BPA 200705500 UPA - Lower Entiat River Off-Channel Restoration The Lower Entiat River Off-Channel Restoration site is a 0.28 mile long irrigation channel that lies within the Lower Entiat River Assessment Unit (RM 0.0-16.2) of the Entiat subbasin. The ESA listed salmonids that utilize the mainstem Entiat River within the Lower AU and project portion of the subbasin include endangered Upper Columbia River spring Chinook (Oncorhynchus tshawytscha), as well as endangered steelhead (Oncorhynchus mykiss) and threatened bull trout (Salvelinus confluentus). Non-listed salmonids such as summer Chinook and Coho, and resident fish species such as westslope cutthroat trout are also in the mainstem adjacent to the off-channel area. The existing irrigation channel will no longer be necessary after successful implementation of the Whitehall Diversion project (Bonneville Power Administration Project ID 200500400; see Section D, Relationship to Other Projects), which was recently authorized through FY2005 within-year funding. Decommissioning of the sump and pump that lie in the middle of the off-channel area will enable improvements to the existing off-channel habitat. Juvenile use and a Coho redd were observed in the off-channel area in 2005 during project site reconnaissance The primary objective of the Lower Entiat River Off-Channel Restoration is to enhance juvenile off-channel rearing habitat conditions, the most primary limiting factor for salmonid production in the Lower Entiat AU. Other project goals include: • Remove Fish Passage Barrier • Replace Diversion Structure • Improve substrate by placement of spawning gravels in channel. • Improve rearing habitat by connecting small pond to channel and adding LWD. • Increase canopy and riparian area in disturbed areas. The Lower River Off-Channel Restoration will provide the BOR/BPA with BiOp Metrics for the following criteria: 0.28 miles of Increased Stream Habitat Complexity 0.10 miles of habitat accessed 1 Fish Barrier/Passage Removed 6 Large Woody Debris pieces
Other: BPA 200731800 UPA - Knapp-Wham Hanan Detwiler Irrigation System Consolidation The Chelan County Conservation District and BOR are working with the Knapp-Wham and Hanan Detwiler partnership irrigation systems to consolidate and improve their irrigation systems. The KW and HD ditch companies are the largest water users in the lower Entiat River, and the primary candidate for irrigation system improvements within the Entiat subbasin. An appraisal report has been completed by BOR; preliminary and final design work is being conducted via Bureau of Reclamation funding and technical assistance. The Hanan Detwiler and Knapp-Wham Ditch Companies are located in the Entiat watershed, and serve irrigators with water from the Entiat River. The irrigators served by the ditches are primarily commercial orchardists, with apples and pears being the main crops. Both ditch companies have diversions that require significant annual in-stream maintenance, and may also act as partial barriers to fish passage during periods of low flow. The two ditches, which are both adequately screened (as per WDFW) have expressed interest in consolidating their operations. This would mean using just one point of diversion (Knapp-Wham) to serve the two systems, and eliminating part or all of the Hanan Detwiler Ditch and serving its irrigators with the Knapp-Wham system, wells, or a combination of both. At a minimum, this project will replace completely eliminate one diversion that constitutes a partial barrier and creating a single point of diversion with improved passage and habitat enhancement aspects for endangered species. The ESA listed species that use this reach of the Entiat are Spring Chinook, Summer Steelhead, and Bull Trout. Additionally, up to approximately 2 CFS or more of carriage water would be eligible to be put in trust.
Other: BPA 200723100 UPA - Entiat subbasin riparian enhancement program This programmatic application will help restore streamside riparian vegetation within the Entiat subbasin to: increase habitat complexity and LWD recruitment; stabilize localized areas of accelerated bank erosion; and increase site-specific shade to help reduce summer stream temperatures and provide winter insolation. The project also includes fencing in specific tributaries to exclude sheep from streams that provide ESA listed salmonid habitat

Section 6. Biological objectives

Biological objectivesFull descriptionAssociated subbasin planStrategy
Fine sediment <0.85mm in spawning gravels <20% Stabilize and restore erodible streambanks banks along 0.56 miles of the Middle Entiat Au by placing approximately 365 LWD/wood pieces instream and revegetating 0.1 mile of bank to minimize sediment delivery to critical spawning habitat for ESA listed salmonids and other fish species. Entiat Decrease or maintain sediment loads to <12% fines (0.85mm) in spawning gravels throughout the Middle AU.
In-channel diversity exists; lg LWD >20 piece/mile Increase instream habitat complexity via strategic placement of approximately 365 pieces of LWD/wood in 0.56 mile reach to benefit sub-adult ESA listed salmonids that utilize the Stillwater area of the MIddle AU, and help moderate severity of high flow events. Entiat • Maintain/enhance in-stream structural diversity and complexity to provide refuge to juveniles during high flow events. • Protect/increase in-stream structures (complex log structures) • Increase stream bank stability via active/ passive restoratation
Riparian areas provide LWD, are >80% intact Riparian revegetation will be performed along 0.1 mile of the Stillwater area of the Middle Entiat AU to restore native species and habitat functions, and help provide long-term stream bank stability. Entiat • Improve degraded riparian areas to a minimum of 75% of the estimated historic condition, where feasible • Increase/maintain the number of large trees and natural LWD recruitment. • Reduce impacts to riparian areas from development and livestock mgmt

Section 7. Work elements (coming back to this)

Work element nameWork element titleDescriptionStart dateEnd dateEst budget
Manage and Administer Projects Manage & Administer Project Manage ground efforts and manage subcontractors associated with implementing project. 11/30/2006 11/30/2008 $15,877
Biological objectives
Metrics
Produce Design and/or Specifications Produce Design and/or Specifications Develop engineering designs for instream habitat placement and riparian planting guide. 1/1/2007 3/30/2007 $12,421
Biological objectives
Metrics
Produce Environmental Compliance Documentation Produce Environmnetal Compliance Documentation J.A.R.P.A. Permit State Biological Collection Permit NEPA Permit Land-Owner Agreements 3/1/2007 3/30/2007 $10,375
Biological objectives
Metrics
Collect/Generate/Validate Field and Lab Data Upper Columbia Salmon Recovery Board Level 1 Surveys Fish Survey Riparian Survey Macro-Invertebrate Survey Gravel Survey Photo History 12/1/2006 5/30/2008 $16,144
Biological objectives
Metrics
Increase Instream Habitat Complexity Increasing habitat niches and structures through LWD placement The placement of 125 root-wads and 230 cut-logs along the eroding bank to complete the tasks of enhancing critical salmonid juvenile and rearing habitat, decrease the amount of siltation occuring, and maintain the existing spawning gravels in the downstream vicinity. 11/15/2006 11/15/2008 $180,219
Biological objectives
In-channel diversity exists; lg LWD >20 piece/mile
Metrics
* # of structures installed: 125 root-wads, 230 cut-logs
* # of stream miles treated: 0.57miles
* End lat of treated reach: 4786.05
* End long of treated reach: 12042.14
* Start lat of treated reach: 4786.24
* Start long of treated reach: 12042.08
Plant Vegetation Planting of native vegetation to stabilize eroding banks and create canopy. Installing willow, alder, native plants to intiate the root growth neccessary to prevent further erosion of the bank. Planting larger pine and fir trees will increase the percentage of canopy in the diminished canopy reach. 11/15/2006 11/15/2008 $35,217
Biological objectives
Fine sediment <0.85mm in spawning gravels <20%
Metrics
* # of features: 2500 native plants
* # of acres of planted: 0.45 acres
* # of riparian miles treated: 0.57miles
Increase Instream Habitat Complexity Instream improvements and riparian plantings will increase biological productivity By placing these LWD's instream the biological activity will increase in macro-invertebrate interactions, debris caught in the LWD's will increase in numbers to eventually begin a stable biological community, and the number of fish in the area will be greatly enhanced. The riparian plantings will generate biological activity through avian, mammal, and invertebrate usage. 11/15/2006 11/15/2008 $0
Biological objectives
Riparian areas provide LWD, are >80% intact
Metrics
* # of acres treated: 0.5 acres
Plant Vegetation 0.5 miles of riparian area will be restored and replanted with native species. The designed planting of 2500 native shrubs and trees will be completed along 1,250 feet of river bank. 11/15/2006 11/15/2008 $0
Biological objectives
Metrics
* # of acres of planted: 0.55 acres
* # of riparian miles treated: 0.3 miles
Plant Vegetation Stabilize upland areas above eroding banks The planting of 2500 native plants in the upland and riparian area to stabilize eroding soils. The plants will also create the needed shade in the area for decreasing water temperatures. 11/15/2006 11/15/2006 $0
Biological objectives
Metrics
* # of acres treated: 0.55 acres
Maintain Vegetation Annual Replanting/Pruning for 2 years Review Plant Survival Rates Schedule & Conduct Replanting/Pruning 4/1/2008 11/30/2008 $10,666
Biological objectives
Metrics
Produce/Submit Scientific Findings Report Produce Status Report Produce Annual Reports, Biological Reports, Physical Data 12/30/2006 12/30/2009 $8,586
Biological objectives
Metrics
Produce/Submit Scientific Findings Report Pisces Status Reporting Pisces Status Reporting 12/30/2006 12/30/2008 $19,818
Biological objectives
Metrics

Section 8. Budgets

Itemized estimated budget
ItemNoteFY07FY08FY09
Personnel [blank] $27,408 $12,180 $3,272
Fringe Benefits [blank] $11,604 $5,178 $1,386
Supplies [blank] $178,937 $9,300 $3,100
Travel [blank] $5,004 $275 $125
Overhead [blank] $44,591 $5,387 $1,576
Totals $267,544 $32,320 $9,459
Total estimated FY 2007-2009 budgets
Total itemized budget: $309,323
Total work element budget: $309,323
Cost sharing
Funding source/orgItem or service providedFY 07 est value ($)FY 08 est value ($)FY 09 est value ($)Cash or in-kind?Status
Bureau of Reclamation Engineering Surveys $9,375 $0 $0 In-Kind Confirmed
US Fish & Wildlife Service Technical Review $750 $0 $0 In-Kind Confirmed
US Forest Service Localized Expertise $9,930 $8,880 $8,880 In-Kind Confirmed
WA Dept. of Fish & Wildlife Engineering Design $9,000 $0 $0 Cash Confirmed
Totals $29,055 $8,880 $8,880

Section 9. Project future

FY 2010 estimated budget: $0
FY 2011 estimated budget: $0
Comments:

Future O&M costs:

Termination date:
Comments:

Final deliverables:

Section 10. Narrative and other documents

ISRP Response - 200705400-Entiat River-UPA Stillwater Restoration Project Jun 2006

Reviews and recommendations

FY07 budget FY08 budget FY09 budget Total budget Type Category Recommendation
NPCC FINAL FUNDING RECOMMENDATIONS (Oct 23, 2006) [full Council recs]
$0 $0 $0 $0 Expense ProvinceExpense Do Not Fund
NPCC DRAFT FUNDING RECOMMENDATIONS (Sep 15, 2006) [full Council recs]
$0 $0 $0 $0 ProvinceExpense

ISRP PRELIMINARY REVIEW (Jun 2, 2006)

Recommendation: Response requested

NPCC comments: The ISRP believes the proposal has merit, but is requesting that the following concerns be addressed before a funding recommendation can be made. This project adopts an engineered approach to stabilizing the channel and streambank in the Stillwater area. If stronger evidence had been presented that bank erosion was having a detrimental impact on the channel at and below the project site, the proposal would have been more persuasive. Establishing the potential significance of the project would also require a more complete description of the sediment problems in the watershed. The significance of erosion at the project site cannot easily be judged without this context. The basic premise of this project is that the production of sediment from the eroding banks is impacting habitat quality and biological productivity at the project site. The only evidence provided is the level of fine sediment in the gravel. Bank erosion is attributed to past land-use practices and a lack of riparian vegetation, but it was not clear whether or not this area would erode regardless of past problems. The following questions were not addressed in the proposal, and the ISRP would like a response to them in addition to other concerns listed in the comments. Is erosion at this site an important source of gravel for downstream spawning areas? Are sediment sources upstream producing sufficient material to supply gravel and maintain channel form? A large portion of the budget will go toward placing approximately 125 rootwads and 240 cut logs in large woody debris (LWD) complexes to be spaced 10 feet apart. The reason for the 10-feet spacing is that it is believed to be necessary to prevent additional streambank erosion. There was no attempt to relate the proposed LWD additions to conditions in a similar, but relatively undamaged part of the Entiat or otherwise similar alluvial river valley. This regular spacing is not likely to occur naturally, and unless the LWD structures are very securely anchored, movement of the structures during high flow events is almost sure to happen. The objectives did not make clear whether either the structures or riparian plantings would be repaired after natural disturbances. The objectives tend to be generic, and in some cases the linkage between the project elements and the desired outcome is not clear. For example, the proposal indicates one of the biological outcomes is an increase in nutrient delivery to the channel as a result of riparian tree plantings. Although an increase in organic matter delivery to the stream with the re-growth of riparian trees and shrubs is likely, nutrient input may actually decline as a result of uptake by the new vegetation. Also, there is some confusion regarding the level of wood being added to the project reach. The background information provided at the beginning of the proposal indicates a desired level of large wood of about 20 pieces per mile of channel. However, this project plans to add a total of 365 pieces to about a half-mile of channel. We recognize increasing wood abundance is secondary in this project to bank armoring, but some indication of possible consequences of increasing wood levels to more that 15X the stated objective should be explored in the proposal. High flows are likely to alter the distribution of LWD structures and may affect the survival of some replanted riparian areas. Reducing sedimentation from the exposed streambank is a valid objective, but the solution could become costly to maintain if natural disturbance-mediated changes are not tolerated. Not enough detail is provided on the monitoring component of the project to evaluate it. However, the information that is provided raises some concerns. Many of the variables that are proposed are highly variable, both spatially and temporally (e.g., gravel fines, macroinvertebrates, and fish). The proposal implies that pre-treatment information on these parameters will be collected one time. There is very little possibility that a measurable response could be detected based on a single pre-treatment sample. Additional details should be provided to justify the work


ISRP FINAL REVIEW (Aug 31, 2006)

Recommendation: Not fundable

NPCC comments: The ISRP believes this proposal, while well intended, still has some serious deficiencies. The responses to the ISRP comments do not provide sufficient context to determine whether or not the project would address a significant problem in the Entiat watershed. The information on fine sediment in the gravels provides an indication that sediment levels are high at the site, but whether or not that sediment is being produced from the eroding banks at the project area is not clear. The McNeil core sample data are limited to the Stillwater reach, and there was little information on conditions elsewhere in the Entiat subbasin. Because sediment data are available for RM 0.5-34 since the early 1990s (a period that included several high intensity wildfires in the drainage), it would have been very helpful to have included a discussion of the role of fire in delivering sediment to the mainstem Entiat and what we know about how that sediment has been routed in the ensuing years. Without this spatial and temporal context it is difficult to ascribe the relatively high fines in the Stillwater reach to either bank erosion or fluvial delivery of other sediment from sources in the upper basin. The photographs certainly suggest bank erosion is a problem, but there was no way of determining its significance relative to other factors. Project sponsors suggest that the work is needed to reduce bank erosion from feet per year to inches per year. Supporting evidence is needed for this statement as well as for the comment that gravel recruitment from upstream sources is adequate. The statement that spawning gravel is recruited primarily from upstream and deposited at the study site also was not well substantiated. What is the composition of the eroding banks at the project site? Do they contain gravel? If they do and they are eroding rapidly, these banks may be an important source of gravel. Implementing the project without a better understanding of gravel recruitment would be risky. The response states that closely spaced (10 ft.) log structures along the streambank are needed to prevent scour pockets from forming. While scour pockets may be deemed undesirable from a sediment standpoint, it would have been useful to have included a discussion of its implications for fish habitat. If preventing bank erosion is the primary objective, why not just use rip-rap? The ISRP realizes rip-rap is almost always an undesirable solution and shouldn't be used in this instance, but the response could have been clearer if the LWD additions had been described in terms of their overall benefits to fish habitat (vis-à-vis sediment and rearing space). In that way, it would have been possible to explain why so many LWD pieces were being proposed, or if project sponsors were willing to reduce the quantities a bit to more closely emulate natural LWD loading. Additionally, given the width of the floodplain at this site (600 ft.), it is not unnatural for logjams to break up and re-form during high flow events. These natural disturbances are usually quite good for maintaining ecologically functional floodplains. It is understandable that the project would want to protect riparian tree plantings from floods for the first few years, but artificially anchoring LWD may have undesirable, and expensive, long-term consequences. Some provision for LWD movement may be worthwhile. The ISRP's comment about changes in nutrient input was not addressed. Nutrient input does not necessarily require overland flow. Dissolved nutrient input occurs through subsurface flow, and riparian root systems are likely to intercept some of the nutrients moving through the soil to the stream, at least during the growing season. The benefits associated with re-establishing vegetation along the channel are likely to outweigh any negative effects associated with nutrient interception. But the claim that the vegetation will increase nutrient delivery to the channel may not be true. The M&E section of the proposal remains weak. It is not clear that the ISEMP monitoring effort will measure parameters that are relevant to assessing the project's effectiveness. One of the primary objectives is the reduction of fine sediment in spawning gravel, but summer snorkel surveys provide only very indirect evidence that spawning conditions have changed. The gravel samples will provide some indication, although the connection between fine sediment concentrations in the gravel and sediment coming from the banks at the project site would need to be made to be certain that any reduction was related to the bank armoring. The most relevant biological measure would be an assessment of egg to fry survival, but there was no indication that this will be measured. If the monitoring effort is limited to implementation monitoring, as the response states, then the focus should be streambank and riparian vegetation. Instream performance measures will require a much more significant effort to detect real change. Hopefully, the ISEMP program will pick the instream metrics up, but this proposal should have concentrated on the streambanks and riparian zones and, especially, the success of revegetation efforts and the performance of the log structures. In summary, while the ISRP believes this site deserves protection, the proposal should have provided an improved context for the restoration proposal, more attention to simulating natural wood loading in the Entiat River floodplain, and a more focused M&E plan.