FY 2002 Mountain Columbia proposal 199206100

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

Reason for change in estimated budget

Inflation in land prices have increased the costs associated with meeting our goals and objectives. There is also a rate of error associated with developing cost estimates two years in advance of contracting. Generally it is not known exactly what properties will have been purchased and what the costs will be that far in advance. This is a consistent problem with land acquisition projects.

Reason for change in scope

N/A

Cost sharing

Reviews and recommendations

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

Comment:

A response should include specific description of the procedures by which active restoration and other O&M are decided, including description of the monitoring programs by which these efforts are evaluated. The sample design for restoration, O&M, and M&E activities should be specified. Examples of past successes or failures in meeting biological objectives (i.e. those linked as closely as possible to benefit to fish and wildlife) and of modification of O&M as dictated by M&E could contribute to justifying the project.

Comment:

Comment:

The ISRP's initial review noted that a response should include specific description of the procedures by which active restoration and other O&M are decided, including description of the monitoring programs by which these efforts are evaluated. The sample design for restoration, O&M, and M&E activities should be specified. Examples of past successes or failures in meeting biological objectives (i.e. those linked as closely as possible to benefit to fish and wildlife) and of modification of O&M as dictated by M&E could contribute to justifying the project.

Comment:

- Recommend full funding for the Implementation, O&M and M&E portions contingent on the sponsor submitting a complete M&E plan as outlined in the cover document of the report (Page 1, Section 1). Past performance has been acceptable on the implementation and O&M portions of this project. The funding should be continued based on the development of an M&E plan.

- A do not fund decision would create a new situation with regard to ownership and management of the acquired property. The MOA states that in the event the property is not managed in accordance to the goals and expectations of the MOA, BPA may take over management of the property. This may necessitate that BPA take ownership of the property and to find another property manager. We are not inclined to own and operate land for wildlife activities and would need to seek another agency or organization to perform those functions. This could prove to be a contentious action.

Comment:

The Albeni Falls Wildlife Mitigation Project (199206100) is recommended by CBFWA for a 2002 budget of over $6 million and a three-year budget totaling over $19 million. The ISRP (p. 33) concluded its review with a "do not fund" recommendation. The Panel's criticisms centered on lack of information on past results and the potential effectiveness of proposed restoration measures. The Panel also used this project as an example of a "trust fund" type wildlife mitigation project, and expressed its difficulty in evaluating these types of proposals without an understanding of the basis or criteria for the selection of individual parcels purchased under the umbrella plan (ISRP p. 5).

Council recommendation: These two issues need broader attention from the Council. This project is one of several wildlife habitat acquisition projects that received "do not fund" recommendations from the ISRP largely because of M&E concerns and the question about lack of information about how subsequently acquired parcels will be evaluated. These types of proposals address continuing mitigation requirements for habitat lost by the development of the federal hydropower system, and have been approved by the Council in prior years as consistent with the wildlife provisions of the program. The project sponsors believe they have developed their proposals consistent with the standards of the Council program, but their proposals are severely criticized by the ISRP for general lack of specificity for the criteria to select properties for acquisition, long-term maintenance and monitoring approaches. The ISRP noted this issue in its overall comments (p. 5). It said,

"the inherent difficulty with a land and water acquisition fund from the perspective of scientific review is that specific projects are not identified, described and justified prior to fund allocation. Thus, projects or purchases can only be reviewed retrospectively. Front-end accountability can be facilitated through development of specific criteria that rank or prioritize potential land or water acquisitions according to their potential benefits to fish and wildlife."

Noting that the Program calls for establishing a land and water acquisition fund and that discussions of funding allocation and criteria are continuing, the ISRP asked the Council for guidance "on how to effectively review projects that fall within the trust fund approach".

With regard to the first issue, the adequacy of monitoring and evaluation of this project and, as far as that goes, all wildlife mitigation projects, the staff notes that the wildlife managers have collectively developed and submitted a proposed basin-wide approach to monitoring and evaluation for wildlife mitigation projects. It does not appear that either the Council or the ISRP have responded formally to the wildlife managers on the proposal. One of the premises of that monitoring and evaluation strategy proposal is that it is based on and consistent with standards established in the 1995 fish and wildlife program. Those provisions were not superseded by the 2000 amendments to the program, and thus, are still applicable.

With regard to the second issue, the Council notes that there are criteria established in the 1995 program that guides the development of both the large umbrella type wildlife mitigation projects such as the Albeni Falls project, as well as the subsequent individual parcel acquisitions that take place to implement them (see section 11.2.D.1). Those criteria were not superseded by the 2000 amendments, and are not, at least at this time, substituted by new standards or procedures that will be developed to implement the new land and water acquisition program that was called for in the 2000 amendments. The Council, does note, however, that there is some question as to whether or not project sponsors have in fact been consistently bringing individual parcel acquisitions taking place under the larger mitigation plans back through the CBFWA wildlife process for review against those program criteria.

The Council recommendation for the Albeni Falls project is to recommend funding subject to two conditions:

1. Submission of a revised monitoring and evaluation plan to the ISRP, and its approval of that plan. The plan may be project specific for the Albeni Falls project, or it may be a basin-wide monitoring and evaluation proposal for all ongoing wildlife mitigation projects. Council staff will work with the wildlife managers and the ISRP to advise both of any applicable standards existing in the fish and wildlife program that would apply to such M&E plans. The ISRP would need to approve the plan(s). The Council received a monitoring and evaluation plan from the Kalispell tribe on October 5, 2001, and has forwarded that plan to the ISRP for review. A Council funding recommendation is dependant on a favorable review, and resolution of issue 2. below.
2. An agreement between the Council, CBFWA, and Bonneville on a uniform process and criteria for the evaluation of individual acquisition proposals for wildlife mitigation that take place under larger, previously Council approved umbrella wildlife mitigation plans such as Albeni Falls. Council staff will ensure that the agreement is consistent with any procedures, standards and/or criteria adopted in the fish and wildlife program. As noted above in the discussion of the Salish-Kootenai project in the Flathead, the ISRP has reviewed an approach proposed by the Salish-Kootenai tribe that may serve as a model for other large umbrella initiatives. The Council will direct its staff to facilitate the sharing of the information developed by the Salish-Kootenai tribe that the ISRP approved with the Kalispell tribe for its consideration and use. The Council suggests that the model developed by the Salish-Kootenai tribe be considered for programmatic application.

Finally, Council staff is in the process of working with Bonneville and the wildlife managers to convene a workshop to agree upon and formalize a uniform process and criteria for evaluation of individual acquisitions and monitoring and evaluation.

A final Council recommendation is not provided at this time but will be made as soon as possible after the ISRP review and the tribes' response to the ISRP's concerns about standards for parcel evaluation and selection.

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Sponsor comments: See comment at Council's website