FY 2002 Blue Mountain proposal 27013

Section 1. Administrative

Project location

Reasonable and Prudent Alternatives (RPAs)

Section 2. Past accomplishments

Section 3. Relationships to other projects

Section 4. Budget for Planning and Design phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Planning and Design phase

Section 5. Budget for Construction and Implementation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Construction and Implementation phase

Section 6. Budget for Operations and Maintenance phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Operations and Maintenance phase

Section 7. Budget for Monitoring and Evaluation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Monitoring and Evaluation phase

Section 8. Estimated budget summary

Itemized budget

Total estimated budget

Cost sharing

Reviews and recommendations

This information was not provided on the original proposals, but was generated during the review process.

Comment:

The proposal references no biological or ecological literature (primary or otherwise) in support of this plan to purportedly improve habitat for fish and wildlife, particularly for bull trout migration. No biologist is shown among project personnel. The COE report has an Appendix C on "Biological Assessment" for which the only literature referenced is a paper a parasite of chinook salmon, the NMFS 1995 proposed recovery plan for Snake River salmon, and a 1998 Oregon reference on a plant, the Ute ladies' tress. The latter source was not listed in the "References Cited" section of Appendix C, although six other literature items did appear on that list—but were not shown not in the text. Among those six items, listed as "cited" but actually not referenced, were two well-known papers on bull trout life history and ecology (Fraley and Shepard 1989; Rieman and McIntyre 1993). Strangely, the COE report's Appendix A on "Fisheries Criteria for the headcut Stabilization Design" states: "Very little is known about the life history and habits of bull trout," at which point no literature is referenced. These referencing deficiencies and wording indicate that the COE report's sections on fish are based almost purely on rough professional judgment rather than available science.

Because an expanse of land devoid of residences or other buildings exists on each side of the stream, there is ample lateral space to create a lower flood plain and to re-meander the stream within a well-vegetated riparian zone (the irrigation ditch along the right bank could be relocated). Creating a significant meander corridor would result in a much more natural restoration and far more habitat for fish and wildlife. Neither the proposal nor the COE report considers this alternative, therefore, the proposal is inadequate. The only action alternatives described are further (primarily hard structure) engineering of the present artificially straightened course. These would all result in a rigidly stabilized channel bearing little resemblance to naturally productive habitat for salmonids.

The COE report states (p. 1-1) that the project is to be done under Section 1135 of the Water Resources Development Act of 1986"to modify the structure and operation of water resource projects to improve the quality of the environment in the public interest." Under the heading, Purpose, it emphasizes the goal of meeting "specific habitat needs" of 3 ESA-listed fishes (p. 1-1); says the "intent of this project is to implement measures that would help restore a migration corridor and rearing habitat for fish, enhance riparian vegetation, and stabilize the river channel and its banks" (p. 2-1); and explains that in a headcut section the primary goal is fish passage improvement, and that in a downstream section the primary goals is to improve winter holding and rearing habitat (p. 2-1). The objectives of protecting the bridge and irrigation ditch are not mentioned in the purpose section. They are at least alluded to elsewhere in the COE report, but not prominently.

The major fish habitat need cited in the COE report is to provide passage for salmonids. However, at present, the headcut area envisaged for alteration presents no more of a challenge to salmonids that need to migrate upstream than do rapids and falls that salmonids normally surmount elsewhere. In the oral presentation and COE report, it was stated or implied that the channel must be altered to permit upstream passage of juvenile bull trout, the weakest swimmers among the system's salmonids. This asserted need was not substantiated and is not consistent with the life history of that species. The migratory (fluvial) bull trout mature in the Snake River (perhaps also the Grande Ronde's lower reaches), swim upstream past the headcut as adults to spawn in upper parts of the system, and return downstream. After rearing near and below the headwaters, juveniles move downstream; some may disperse into various parts of the river system (pers. comm. Bruce Rieman, US Forest Service) but in general the juveniles move toward the larger rivers where they mature. They have no known need to swim upstream through the headcut until spawning migration when they are large and can surmount such features. Resident bull trout inhabit more upstream areas lifelong and need not pass the headcut. Moreover, the COE report's own analysis (Table 3-1, p. 3-13) showed that the present probability of upstream passage for juvenile bull trout is 50 percent; this indicates that, although no juveniles need to pass, about half of them probably could—and that positive selective pressure would operate on the population if any of the young fish did have good reason to try the challenge. Clearly, no need exists here for better than present fish passage.

The proposal conveys a misimpression that urban development constricts the corridor available for restoration of a proper flood plain and meandering stream. The proposal says: "Residential development has intensified on both sides of the river channel, reducing the tolerance for channel meanders and out-of-channel flooding." Site inspection reveals, however, that residences, though sometimes within sight of the bank, are few and are set back many yards from the river. The proposal fails to accurately describe the river as bordered by wide areas of relatively undeveloped land.

Under geomorphologic problems, the proposal lists "atypical river parameters" as a category and shows "high width/depth ratio; high raw, vertical banks" as the items involved. Lack of normal meandering should also be included under this category.

The proposal's objective, "Provide for a Consolidated Low Flow Channel," has as its task: "Channel alignment and geometry have been designed to result in a narrower, deeper, and more meandering channel within the present river corridor." Though not truly in the form of a task statement, this implies that the project would create a more meandering channel. Drawings for the "recommended alternative" plan in the COE report indicate that little, if any, additional meandering would be created.

Another objective is "Address Annual Gravel Removal Done in Lower Section of Project Reach." Its "task" says: "Annual gravel bar scalping will only occur where recruitment warrants protection for stream restoration features." The purpose of gravel removal and why any should be permitted in the stream or its riparian zone should be explained.

Scientific documentation for fish habitat aspects of the COE report's designed channel and its artificial structures are lacking, hence also in the proposal.

The proposal states that "The Corp [sic] of Engineers have contracted with Lee Silvies to design the proposed facilities to replicate a more natural condition within the project reach," and that this "experienced hydrologic engineer, will provide on-site direction for structure construction and placement." However, Lee Silvies is not found in proposal Sect. 10, Key Personnel, and nowhere in the proposal are his or her education and other qualifications presented.

The proposal mentions no watershed assessment.

The proposal indicates that design was not completed before the proposal was submitted: "The U.S. Army Corp of Engineers and local sponsors . . . will complete a Design and Specifications document within the next two months for the proposed project."

Comment:

Comment:

The CBFWA comments in general complement the ISRP concerns and opinion. The ISRP reviewers note in particular the CBFW comments that the project "is not designed as a fish and wildlife project, would not remedy the problems of the cause" and that "The trajectory of the fish population would not benefit from the project."

Comment:

Comments
Although the project purports to improve fish passage and habitat through the replacement of the headgate structure, establish rock cross vane structures, rock weirs, fill and stabilize scour pool improving habitat, stream bank stabilization and large woody debris placement, the primary intent of the proposal is to forestall channel headcutting that threatens to undermine a bridge and irrigation ditch diversion. The proposed project fails to remedy the problem's cause, the channel straightening, and portrays minimal benefits to fish. In fact, the project as now planned, would perpetuate various features of the present channel that adversely affect fish habitat.

Already ESA Req? No

Biop? Yes

Comment:

BPA RPA RPM:
--

NMFS RPA/USFWS RPM:
500

Comment: