FY 2000 proposal 20135

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

Other budget explanation

Schedule Constraints: Availability of sturgeon stocks/sizes/ages, and/or the identification of donor populations may delay the release of fish in 1999 and the subsequence evaluation and monitoring of growth, survival, and carrying capacity of the reservoirs.

Reviews and recommendations

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

Comment:

Comments: Justification of this project is predicated solely on mitigation. It seeks to evaluate the potential for a fishery by simply beginning to introduce and harvest fish. The proposal asserts that there will be virtually no impact to naturally spawning populations, but no data are given to justify the claim. The proposal further asserts that natural spawning of sturgeon is limited by reservoir conditions, but that conditions are suitable for rearing; again, no data are cited to support this claim. The proposal cites project 8605000 as a cooperative effort to evaluate sturgeon status and to provide plans for enhancement and restoration. This project must have abundant data by now, but none are described. The proposal identifies what is to be done, but does a poor job of justifying the work and is often confusing in presentation. For example, hypotheses listed on page 7 are different from those listed on pages 10-12. The proposal lacks description of how hypotheses will be tested. The goal of harvest of 250 white sturgeon is not ecologically explained or justified, nor is the stocking rate that is intended to achieve it. The proposed project would add 900 fish before developing a management plan. There should be at least a tentative management plan before stocking fish. Additionally, the stock source for the sturgeon is not identified. The proposal states that stocking densities are low relative to historical levels, but does not explain how low or explain how stocking density would relate to current reservoir conditions or other fish populations.

There is no description of alternative ways to solve the problem of lost fish harvest nor is there a discussion of dangerous or unwanted side-effects of the project. Previous experience with other species in the Columbia River basin would suggest that this type of program rarely justifies expense and is often associated with unexpected and unwanted side effects. The authors state that development of alternative white sturgeon fishing opportunities through augmentation may reduce the pressures on impacted populations, but they do not provide any support for this assumption. There are numerous examples with salmonids that suggest it is not always the case, and considering that angling pressure for sturgeon is already increasing, it may actually accelerate the expanding interest in sturgeon fishing. Frequently, as anglers become more reliant on hatchery production, they have less interest in protecting wild fish. Furthermore, once a fishery based on hatchery fish is developed, it is very difficult to shut it down if negative effects are detected; again, there are numerous examples with salmonids. Rather than focusing on mitigation, efforts to restore wild populations of wild sturgeon in the Upper Snake River should be expanded. If this work is done, many of the scenarios listed as assumptions should be recast as hypotheses and tested (e.g., emigration out of the reservoirs will be minimal and will not pose a risk to natural spawning sturgeon populations). The proposal is poorly referenced, and no description is given of what skills and experience personnel will be expected to have.

Reviewers asked several specific questions: What will be the objectives of the management plan? Why will augmentation begin before the plan is reviewed and approved? How can release of fish in the summer of 1999 follow the recommendations of the plan if the plan is not approved? How will post-release monitoring and evaluation (p.10) be conducted?

The CBFWA evaluation concluded that "There are no specific biological objectives." It is unclear that this project would have benefits to fish or wildlife, and potential effects on other fish are not adequately described or addressed.

Comment:

Comment:

Technical Criteria: yes

Programmatic Criteria: yes

Milestone Criteria: no- There are no specific biological objectives.

General Comments: Coordinate with IDFG and ODFW about non-tribal sturgeon harvest.

Comment:

The responses from CBFWA and from the NPT do not address these concerns adequately from the viewpoint of scientific soundness. There is not scientific justification for initiating a sturgeon stocking program in the absence of a management plan (which is stated to be developed) and in the absence of a sound data collection plan designed to test hypotheses about how well the stocking program is meeting its biological goals and avoiding generating unwanted damaging side effects.

Whether or not this is called a research proposal (the responses state that the work is mitigation, not research), it must generate research-type data in order to have scientifically acceptable monitoring and evaluation. The usefulness of data to test hypotheses depends on having hypotheses, or questions, specified in advance so that the appropriate data set is defined before collection. Further, often, pre-treatment (i.e. before fish stocking), initial (i.e., time of first fish stocking), and continuing data are needed to understand the outcome of work such as this; the design and sampling need to be planned before the work is begun.

Similarly, sound application of science dictates that unwanted side effects would be scoped in advance of beginning the stocking program and that this information would be subject to outside review by other scientists. It is not scientifically adequate to plan to raise and address these later. It is not adequate to assert that so few sturgeon are present that an introduction program cannot harm them; what about other fish species and what about other elements of the food chain. The response that full augmentation will be delayed misses this essential point. Past manipulations of lake and riverine food chains make clear that this extended food web analysis must by considered and that food web responses must be monitored.

The response refers to the management plan in future tense. It sounds like funding for the development of a management plan was received previously, and the plan was supposed to be developed with IDFG an ODFW during FY 1999. When will it be completed? Why isn't it referenced or central details presented for scientific review? Additionally, a master plan and NEPA documents are scheduled to be completed and approved prior to the initiation of fish stocking. Without these documents, it is impossible to complete a comprehensive review of the project. A decision concerning further funding and implementation of the program should be contingent on a favorable scientific review of the management plan, master plan, and NEPA documents.

The respondents' claim that public review in the FWP amendment project provides justification to the work, however, this does not supply information about scientific soundness.

Comment:

Comment:

Discussion/Background: The project would provide fishing opportunities in Hells Canyon and Oxbow reservoirs to mitigate for the loss of white sturgeon in the Columbia and Snake River basins due to hydropower development. The project is in pre-Step 1 of the 3-step process. Project proponents were supposed to develop a detailed management plan in the first year of the project, in consultation with IDFG and ODFW. The plan has not been developed, due to a late start in project contracting, and likely will not be developed until March or April of 2000. Contracting for this project runs through March 2000, so there are funds available to complete the management plan. There is also an ongoing evaluation of sturgeon fisheries and viability in both reservoirs by Idaho Power Company as part of the FERC Hells Canyon Complex relicensing process. CBFWA assigned the project to Tier 1.

ISRP Review: Do not fund (both reviews). On its second review, ISRP criticized the scientific justification and basis for the proposal. Specific concerns addressed the lack of a management plan and a sound data collection plan. They also questioned beginning a stocking program prior to scoping the possible side effects to other sturgeon and resident fish as a result of that stocking.

Policy Issues: The Nez Perce tribe provided policy justification to the Council in their letter of November 10, 1999. The Nez Perce tribe cited Council Criteria b of Director Lohn's memo of October 26, that ISRP comments are expressly critical of a strategy or objective that has been approved in an adopted program measure. The Nez Perce tribe cites Measures 10.4 and 10.4A.5 as providing justification for the project. Measure 10.4 addresses sturgeon mitigation in the basin as a valid strategy. Measure 10.4A.5 authorizes funding for an evaluation of a consumptive sturgeon fishery in Oxbow and Hells Canyon reservoirs, in consultation with the Nez Perce Tribe, ODFW and IDFG. The Council must approve a plan prior to implementation.

Council Analysis and Recommendation:: The Council adopted the recommendation included as Section 10.4A.5 in the 1995 program amendments. The Findings include an explanation of modifications the Council made to the recommendation. Specifically, the Council called for an evaluation of production and release of sturgeon, rather than immediate implementation. The evaluation should address three points:

"
1. Is it possible to produce a successful sturgeon fishery, given what is known and not known about sturgeon production and the precise environment into which these fish will be [introduced]?
2. Can the production and release of these fish occur without significantly reducing the productivity of wild sturgeon populations? [Given ISRP concerns, this evaluation should also address productivity of other resident fish.]
3. Whether this project addresses losses caused by the development and operation of the hydropower system, and, if so, are other entities also responsible?
"

On January 13, 1999 the Council sent a letter to the Nez Perce Tribe recommending Fiscal Year 1999 funding for the project and stipulating that future funding be conditioned upon "the development and peer review of a production master plan consistent with the Fish and Wildlife Program" and that "the Council specifically approve the master plan for the sturgeon fishery if warranted."

The "production" component of this project is in a preliminary assessment and feasibility stage; therefore, it is currently at the master planning level or Step 1 in the Three-Step Process. The sponsors have been coordinating and consulting with ODFW and IDFG on a technical level and have also included Idaho Power in their consultations. They intend to submit the master plan and any NEPA documents in March or April 2000. Submission of these documents will initiate the Council review process. To date, no step documents have been received. Until completion and approval of a master plan and support documents as part of the step 1 review process all activities associated with this project should be funded at a level for this specific task. This funding level will be maintained until Council receives and approves step 1 documents that clearly answers the questions as outlined in the Fish and Wildlife Program Findings (16-137 through139). In addition the issues raised by the ISRP in the Fiscal Year 2000 Response Review and the Artificial Production Review Report (document 99-15) policies need to be addressed and made part of the step 1 review. This documentation will then provide the direction needed to ensure that the master planning effort is developed in a productive manner to meet the intent of Section 10.4A.5. The Council believes that funding this project at the reduced level for planning activities, and its requirement that the ISRP's criticisms be addressed in the step 1 review is consistent with, and addresses the ISRP's bases for, its recommendation. Fund the project at a level that will assure completion of the master plan. Funding for three months of the project should provide the necessary funding to complete that task. Based upon the Fiscal Year 2000 budget, this funding level should be $36,000 (using the figures for project personnel, benefits and overhead).

---

REVIEW:
NWPPC Funding Recommendation (NWPPC 2000-6)
Recommendation:
Fund in part
Date:
Mar 1, 2000

Comment:

[Decision made in 12-7-99 Council Meeting]; Fund master plan and 3-step

---