FY 2003 Mainstem/Systemwide proposal 200303300

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:

But a key question is whether the research is likely to lead to useful results and implementable mitigation? Do pesticides in question exist in sufficient quantities in the environment such that those concentrations are likely to have measurable effects and can be partitioned and separated from other large and known sources of salmon mortality. Although a variety of pesticides are used and detectible in the environment, what are the concentrations and identities that are expected at levels in which salmon would be affected. If there is evidence, it should be cited.

Is the model realistic? The use of a copper based model and surrogate for organic pesticides seems convenient but not necessarily realistic. No evidence was provided to show copper concentrations exist in the Columbia River or most tributaries of the levels likely to be toxic or have sub-lethal impacts. Copper does exist in the Clarkfork River in high concentrations. There the homing instincts of rainbow trout and bull trout, two potradromous species, seem extremely well developed (Schmetterling, personal communication, MDFWP) in this extremely copper contaminated system. Milltown Dam is one of the most studied and evaluated cleanup sites on EPA's superfund list.

Is the work directly applicable to salmon? The proposed work is physiological research (driven by good ecological issues). The question arises is what is the actual relevance of the studies to the real world of salmon. For example, how applicable is the zebrafish model to salmon and what evidence is there that the rapid development rate of zebrafish embryos (a tropical species) represents much slower development of coldwater salmon embryos?

Are natural concentrations and mortalities significantly detectable to warrant the research? The discovery of microscopic anatomical or physiological anomalies after exposure to high concentrations of a toxin in a rapid developing model (zebrafish) in vitro may present unrealistic results and lead to unwarranted conclusions (Type 2 statistical error- i.e. find problems that don't actually exist for example, that pesticides from lab data extrapolated to the wild indicate a mortality component for wild salmon when there may be none). Response?

Are there potential affects on other species of fish and if so, what would be consequences to salmon? The authors hypothesize that predators may gain some advantage over smolts with impaired olfactory senses; however, should such a pesticide condition occur, why wouldn't the predators species have similar impairment?

Does evidence exist in nature that shows any unusual patterns of straying that might be connected with pesticides? The authors hypothesize olfactory impairment from pesticides may be a source of straying. Is there even anecdotal evidence that specific basins, sub-basins or tributaries with higher levels of pesticides (even use, if not data) show higher rates of straying than other basins?

Can we really get at the question of genetic consequences of pesticides? The authors hypothesize that genetic integrity of certain weak stock ESU's may be compromised by straying. The introduction of artificial selection to 95% of the salmon migrants via various artificial propagation (hatchery) techniques and selective harvest of the past 50 years seems gargantuan compared to the potential problem of incremental straying from a pesticide source. A simpler hypothesis is that if pesticides are entering the salmon's life cycle, it is likely that those individuals and populations are carrying an additional genetic or environmental load. If this is true, a more direct approach to warrant the physiological studies proposed herein would be to find at least one watershed that has physiological detectable concentrations of copper (or other toxins) and then emulate that condition in the lab. At the same time, the problem of toxicity can be addressed as a preventative measure while research confirms the extent of the mechanism and the extent of the problem in the lab.

If any results suggested that pesticides were an additive component of lifecycle mortality, how would such a finding be extrapolated over all populations and with all other causes of mortality? This becomes statistically daunting when in even a healthy system, 95-98% of the smolts do not return, mostly for unknown causes.

Alternative Research Designs. Is there any possibility of an alternative experiment that would use salmon, perhaps in populations known to be exposed to certain toxins; e.g. are there known exposed and control populations in nature that could be used as subjects of this study? The current approach asks us to extrapolate from zebrafish to salmon and do theoretical population modeling using a large suite of hypothetical variables about olfactory impairment and gene flow. The ISRP would be more enthusiastic if the model were with salmon and in a location where pesticide is actually found in known concentrations of concern in the environment?

Summary.

1. Please address the basic evidence that pesticides in the environment are having a measurable and detectable impact on the return rates of salmon. Of the 100 pesticides identified, how many exist at concentrations are physiologically affecting sub-populations of salmon. Please identify evidence of specific impairment or straying or genetic or environmentally detectable load on any population. Address the concern that the model of zebrafish in the lab has several limitations to direct application to salmon in the wild. Address alternative approaches using salmon, potentially in nature.
2. If a potential connection between copper and salmon is found, how significant is this source of mortality versus dozens of other sources not only of other pesticides, but also of dams, harvest, predation, ocean losses etc. Normal mortality rates are already above 95%. This speaks to the previously defined experiment, as the treatment and control will be exposed to all these cumulative impacts.
3. The research seems extremely interesting to basic science, but please elaborate more directly on the likelihood that results will be directly applicable to the management of the FCRPS and salmon recovery. For example, hypothesize some expected and quantifiable impact, and what might be done about it. Wouldn't it be simpler to keep concentrations of harmful chemicals at sub-physiological impairment levels? This is EPA's mission and the toxicological research is usually in the realm of EPA chemical use and approval domains. Shouldn't this research wait for more details about natural concentrations of toxins? Some fascinating observations were cited by the authors about physiological and behavioral responses to predator alarm pheromones. What types of research can be done to develop more wild-like traits in hatchery reared smolts? Does this area of physiological research hold potential large benefits to salmon?

Comment:

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Comment:

The response was thorough and provided convincing evidence that embryonic development is a highly canalized physiological phenomenon in all vertebrates and thus the zebrafish model is relevant; i.e. zebrafish are an accepted standard for such screening tests, and as such are logical to use. The proponents make a persuasive case for the rapidity of the zebrafish assay compared to salmon. They also clarified that copper is a primary ingredient of many pesticides and therefore relevant.

The ISRP's concern with the proposal is with the next step, that is, making the link to salmonids and other Columbia River basin fish, but this is not what they propose. The authors hypothesize olfactory impairment from pesticides may be a source of straying, but do straying, physiological, or behavioral anomalies exist differentially in the basin and could those be related to pesticide concentration? No data exist according to the authors; thus, the hypothesis that straying is affected by pesticide would need to be corroborated. Whether pesticides exist in quantities sufficient to affect salmon and especially salmon embryos in the wild remains hypothetical. The authors present evidence that some of the pesticides are detectable in agricultural basins at ppb levels of concentrations. Are these sufficient levels to raise concerns to warrant in vitro tests on zebrafish? The authors indicate that if, after three years of research on zebrafish, there is significant justification they will then proceed to transfer hypotheses directly to salmon. The ISRP would be more enthusiastic about the priorities of this research if there were field evidence for the hypothesized issue, i.e. observed data that the problem exists to which the proposed research might explain or mitigate the problem in salmonid populations

The research seems extremely interesting to basic science, but potentially a long shot, based on the likelihood that results will be directly applicable to the management of the FCRPS and salmon recovery. Near-term benefits to salmon are unlikely because of the long-term nature of the studies including the need for connections in the field.

Some fascinating observations were cited by the authors about physiological and behavioral responses by salmon to predator alarm pheromones. Although not the intended subject of this research, the ISRP would be interested in research that can be done to develop more wild-like traits in hatchery-reared smolts. Does this area of physiological research hold potential large benefits to salmon?

We agree with CBFWA's suggestion that this research should be funded through other sources like EPA.

Comment:

Comments
NMFS proposal. Inappropriate to comment.

Already ESA Required?
No

Biop?
Yes

Comment:

This is no longer a focused “pesticide proposal” but a general water quality and land use proposal (the title is misleading). This change of focus is good in one sense, as it broadens the topic to other important features of water quality and the factors that affect them. The proposal further emphasizes salmon and drops zebra fish assays, which the ISRP had earlier questioned for relevance. However, in broadening the topics, the proposal lost clear focus and directed project planning. It lacks critical detail needed for evaluation of the soundness of its science and its likelihood of success. Even the water quality features to be analyzed are vague, and the proposal says that it is not going to be limited to those listed in the RPAs. The thrust is on two subbasins that partially match the three proposed for monitoring in the other proposals of this “integrated set.” If this collection of proposals is to be an integrated set, then why is this one proposing work in the Wenatchee and Yakima, when the others in the set propose work in the Wenatchee, John Day, and Upper Salmon? It is not clear how these proposals link together.

A working group including the RME group, EPA, State DEQs, etc., might be formed to plan and design a call for proposal on water quality before going forward with this proposal. The relationships of water quality to life history characteristics and life-cycle success of salmonids could be a good topic for a targeted solicitation.

The proposal lacks critical detail. As was commented upon by the ISRP for the first proposal, there is no evidence presented that pesticides (or any other water quality parameter) are actually a problem. We see only informed speculation. Are levels seen in the field within the range that cause mortalities, lowered growth, etc.? The ISRP recommends that a workgroup composed of state and federal agencies familiar with water quality problems be convened to scope work on water quality before a targeted solicitation for the work is advanced.

In Part I, the proposal does not make clear the relationship to RPA 183 (Part II cites RPAs 180, 181, 183, and 198, not just 183, as justification). This is critical for the context of the proposal, especially its urgency in the Action Effectiveness process. A seemingly excessive amount of funding is requested just to select sites ($370k). There are only very brief objectives provided in Part I, where the scope of the project should be clear through an outline of objectives. No cost sharing is anticipated in Part I, although Part II notes a large amount of cooperation with other agencies.

Part II notes that this proposal is tied to proposals 35019, 35020, and 35048 as a package, but there is no indication of what the linkages are. Is there an overall set of objectives for which each proposal has a part? If so, what parts do the other proposals play? As commented on for Part I, establishing a justification in RPAs and among related proposals is essential.

The ESUs selected for study are important, but the ISRP wonders whether they are the most appropriate for such a study. They have to be considered as pilot studies for the rest of the Columbia River basin.

Use of a life-cycle model is a good idea, as is attention to aspects of water quality that have not often been studied in the Fish and Wildlife Program. Use of specific quantitative models, parameterized with field-measured life-history data and linked to field-measured environmental characteristics (such as presence and levels of various pollutants or other determinants of water quality) could provide a powerful approach to better understanding the health of and threats to salmon in the Columbia River Basin. However, the strength of such a study would depend critically in details of sample design, measurement, and analytical details that are not given in the proposal.

The part of the proposal to “develop a new laboratory infrastructure for salmon health research” is not clear. It seems that the lab is to be funded for a major renovation of facilities. However, the amount of funds required is not carefully spelled out and contrasted with the funds for actual research and monitoring.

As an overall monitoring proposal, the CBFWA proposal (35033) is superior.

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