FY 2002 Mountain Columbia proposal 199004402

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 does not adequately reflect input provided by the ISRP during Step One of the Three Step Review Process (ISRP 2000-1). The Step One review process included conversations with the project sponsors responsible for this project. The sponsors provided responses to a number of questions the ISRP posed. This process resulted in the ISRP's final recommendations, which specified a set of four conditions we thought needed to be met before the project moved to Step Two (or as part of the Step Two process). We also proposed two amendments to the Production Facility Master Plan that were to be considered by the tribe. The proposal should have discussed these, explaining how the conditions had been met and the proposed amendments dealt with. The ISRP notes that the proposal does state that the Coeur d'Alene Tribe proposes that the BPA fund a monitoring and evaluation program consistent with the recommendations of the NWPPC and the ISRP reviews of the project during the 3-step process. However, the response should specifically state how the proposed plan addresses the ISRP's Step One review regarding M&E.

About 10% of the proposed annual M&E budget is to monitor cutthroat trout abundance and rainbow trout catch from the put-and-take pond fisheries. The remainder ($303K) is for vaguely described data gathering on Coeur d'Alene Lake and tributaries that appears hugely redundant with work proposed by proposal 199004400. The proposal states that some of that work apparently would be done on Hangman Creek in the Intermountain Province (p 31 & 33); is that intended?

Despite previous reviews (FY 1999, 2000, 3-Step), the contents of this proposal and discussion during the presentation have led the ISRP to be increasingly convinced that the proposed hatchery program for adfluvial cutthroat trout does not appear to be scientifically justified. As Rieman and Apperson point out in their 1989 review of the status of westslope cutthroat trout in Idaho, no hatchery program has ever been successful for a stream-dwelling population of the subspecies. To be effective this program will need to be particularly well designed and executed. At this point in time, we are seeing more, rather than less cause to be skeptical of the possibility of success of this portion of the hatchery program.

The larger program is based on a premise that westslope cutthroat populations are depressed because of degraded habitat and, if the habitat is renovated, the populations will respond favorably. If that is the case, why is it logical to stock hatchery fish? Great effort in the proposal is put into overcoming what seems to be an assumption that stream conditions are limiting the target populations. What evidence is there to support that assumption? What consideration is given to possibility that space, food, predation, competition, or water quality in downstream waters is actually limiting population size?

We identify three alternative approaches to bolstering cutthroat populations as a basis for soliciting a response from the Tribe:

1. Enhance adfluvial cutthroat trout but without a hatchery. Three of the four study streams (Benewah, Alder and Evans creeks) seem especially poorly suited for adfluvial cutthroat trout restoration, because the migrating trout must transit through low gradient, warmer rivers or lakes such as Cave and Chatcolet lakes that hold abundant warmwater and coolwater predators before they enter Coeur d'Alene Lake. As the proposal notes, smallmouth bass are quickly expanding in the system following their illegal introduction a decade ago, and other predators seem abundant. A better approach to restoring adfluvial fish might be the continued focus of activities on Lake Creek and those few similar higher-quality (albeit off-reservation) tributaries that have existing adfluvial runs but no brook trout. These activities include a combination of habitat restoration, fish translocation, and selective lakeshore predator removal at critical periods to increase trout survival.
2. Concentrate on resident cutthroat (with habitat restoration, as is currently being done under proposal 199004400) instead of the adfluvial form. The probability of increasing their population size appears good, much better than the high risks involved with adfluvial fish and, as we pointed out in our review of 22 February 2000, doing this may also enhance adfluvial runs.
3. Acquire adfluvial fish for stocking, but from an outside source such as IDFG. This would alleviate fiscal concerns, which are not central to the ISRP but should be considered. Under the current hatchery proposal, each of the cutthroat fingerlings that would be stocked into the four target streams would cost approximately $10. An alternative approach might be to purchase cutthroat fingerlings elsewhere for stocking by Tribal staff.

Other specific questions to be addressed the response:

Page 3, line 4:"Usable spawning habitat comprises 4.1% of the total stream area in 2nd order tributaries." Is this conclusion based on a biologist's view of what is "usable" or is it based on the areas used by fish when the spawning population is large? Spawning site selection is influenced by factors that cannot be seen even by experienced observers. A value of 4.1% of stream area may be excessive of actual fish needs.

What is the goal of the rainbow trout stocking (angler hours? return percentage?).

What does a limiting factor analysis in Coeur d'Alene Lake entail? What results expected from Objectives 3a, 3b, 3c will help to conclude what is limiting?

We anticipate potential further interaction with the personnel involved in this project after they respond to our comments.

Comment:

Comment:

The objectives of the program, as presented in the original proposal and the response, focus nearly exclusively on attempting to reestablish adfluvial westslope cutthroat trout to harvestable levels in the target streams. Despite relatively encouraging previous reviews (FY 1999, 2000, Step 1 review of the 3-Step process), the contents of this proposal, discussions during the oral presentation, and the review response have led the ISRP to be increasingly convinced that the proposed hatchery program for adfluvial cutthroat trout does not appear to be scientifically justified. The ISRP believes the project's objectives are not likely attainable for the following reasons.

In spite of the general lack of consideration of downstream mortality factors in the proposal and response, the proposers made a case for the adfluvial cutthroat using the Lake Coeur D'Alene littoral zone as a critically important part of their post-migration life cycle. The wide, shallow south-shore littoral zone of Lake Coeur D'Alene has a large population of primarily non-native predatory fish that are thought to exert significant predation pressure on the young adfluvial cutthroat trout. The proposal fails to address this ecological issue in any meaningful way; thus increased smolt outmigration from the proposed hatchery facility likely will simply feed a downstream predator trap. Consequently, the ISRP believes the proposed project will fail to meet its short- or long-term objectives. This point was the basis of the ISRP general comment in Step 1 of the 3-Step review for the project to focus on resident life history patterns:

"The approach to restoration of Coeur d'Alene westslope cutthroat trout populations on reservation lands might be most successful if it focused on stream habitat restoration and on the resident, rather than the adfluvial, life history pattern. While an overall project goal is to increase adfluvial fish, which due to their larger size present the best harvest opportunity consistent with the tribe's goals, a biologically viable approach might be to focus on increasing resident westslope cutthroat trout abundance in tributary streams - including reintroduction into streams where they have been extirpated or are at very low numbers." (ISRP 2000-1: Review of Coeur d'Alene Tribe Trout Production Facility Master Plan, page 3).

Although this predator problem was raised as "general comment" in the 3-Step rather than a specific condition, after this provincial review process the ISRP has become increasingly convinced of the potential severity of this problem and now raises the adfluvial component as a critical shortcoming of the proposed approach.

The second issue is the assessment of the fish abundance goals set for fully recovered trout populations in the four target streams. The goals provided (described in the "sister" proposal 199004400 Implement Fisheries Enhancement Opportunities on the Coeur d'Alene Reservation) are those generated by the Tribe's Habitat Quality Index model. It appears that these target values would guide the use of hatchery supplementation (proposed here) and habitat restoration (proposed in 199004400) to achieve maximum fish density in each square meter of stream, especially in the lower stream portions that historically were probably only passage corridors. Thus, the review panel is concerned that these fish abundance goals might be inflated and unattainable.

An additional problem that emerged in the presentation was that the proposers data strongly support habitat as a primary limiting factor for their fish, in which case a hatchery-stocking program is counterproductive. The statements in the 3-Step materials that suggest it will take 50-100 years for habitat recovery to occur are unsubstantiated with the data, and the data the proposers presented in Kalispel suggest the opposite; that habitat actions have very quick effects. The proposers have provided inadequate evidence that the current environment can support the numbers of fish they want to add, and they have good evidence that wild fish increase well when habitat factors are not limiting. Adding hatchery fish to a system that cannot support more fish now is likely to further reduce the remaining wild native fish (apparently healthy in a few streams).

In the preliminary review, we noted that we anticipated potential future interaction with personnel in this project following the response loop; however, after reviewing the response the ISRP did not consider further communication necessary to make this recommendation.

CBFWA Comment: This project is requesting a placeholder for a hatchery facility that is currently moving through the 3-step process. Several questions were raised about the proposal during the provincial review process that will be addressed during the 3-step process. The scientific validity of this project will be determined during the 3-step process. The objectives stated in the proposal are tasks and do not indicate the overall objective of the proposal. Monitoring and evaluation are proposed but whether they will meet objectives cannot be determined if those objectives have not been presented. The proposal is for a supplementation hatchery to provide harvest for the CDAT. The hatchery is clearly being developed using the best scientific foundation for the subbasin and should be commended for that. It is difficult to apply these criteria based on science when the ultimate goal of the project is for harvest benefit. IDFG and MDFWP support much of the proposal, but has difficulty supporting the supplementation component of putting fish into the streams based on the cost effectiveness aspect.

Comment:

• Adequate water quantity and water quality
• Predation of juvenile cutthroat in Lake Coeur d'Alene
• Effects of project 199004400 on rejuvenated populations
• Cost effectiveness

Comment:

The ISRP (p. 30) recommends no funding for the Coeur d'Alene Tribe's proposed trout production facility (199004402). The central criticisms are the basis for artificial production assumptions and predation in Lake Coeur d'Alene. The project sponsors ask that the Council allow the current proposal to continue in "Three-step" review, notwithstanding the ISRP's criticisms.

Council recommendations: The Council concluded that the ISRP's criticisms are so severe that further consideration of the existing artificial production proposal will be unsuccessful if returned to the ISRP for review. The ISRP has had enough experience with this proposal concept that its findings here should be considered final.

The Council recommends a complete review and revision for the project concept. It recommends that the Coeur d'Alene tribe consider the challenges observed for an artificial production approach and develop a new conceptual design. This would be a "step one" review in the Council process for new artificial production projects. The existing budget reserved for project construction would be reallocated to other resident fish needs. The tribe anticipates the need for approximately $132,000 of their remaining Fiscal Year 2001 budget to initiate a study on the food habits of the predatory fishes and alternative site analysis. However, it is premature to establish any assumption of future capital funding for the Coeur d'Alene program. Instead, additional funding should be a component of the Council's decisions in the "three-step" decision sequence. Future funding is also dependent on the submittal of a narrative, statement of work, budget, study designs and schedules for reviews, but would focus on planning in Fiscal Year 2002 and construction in 2003. This submittal would be reviewed and approved by Bonneville and the Council staffs. Funding in Fiscal year 2001 and 2002 is conditioned on the implementation of the predation study and alternate site evaluations only, future funding is dependent on the step submittal and favorable review process.

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