Within-Year Modification Request Form for FY 2008

 
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Table of Contents
Part 1. Administration and Budgeting
Section 1: General Administrative Information
Section 2: Description
Section 3: Related Projects
Section 4: Planning and Design
Section 5: Construction/Implementation
Section 6: Operations and Maintenance
Section 7: Monitoring and Evaluation
Section 8: Total Budget
Section 9: Project Documents
Part 2. Current Status of Modification Request
Part 3. Comments on this Modification Request


Part 1 of 3. Administration and Budgeting
Section 1: General Administrative Information
Process Information:
Date Proposal Submitted & Finalized Status BOG Meeting Date
August 22, 2008 Finalized September 10, 2008

Modification Type: FY 2008 Within-Year Ongoing
BPA Project Number: 199604300
BPA Project Name: Johnson Creek Artificial Propagation Enhancement Monitoring and Evaluation
COTR/BPA Project Manager: Jonathan McCloud
Agency, Institution or Organization Requesting Rescheduling: Nez Perce Tribe
Funding Type: expense
Project Leader: Craig Rabe
Province: Mountain Snake
Subbasin: Salmon
 
Contact Person
First Name: Craig
Last Name Rabe
Address: 125 S. Mission Street, PO Box 1942
City, State Zip: McCall, ID 83638
Phone: 208-634-5290
Fax: 208-634-4097
Email: craigr@nezperce.org

Administrative Contacts
Primary Administrative Contact Secondary Administrative Contact:
Name Jonathan McCloud Name Kelly Wasson
Address: 905 NE 11th Ave., PO Box 3621 Address: PO Box 305
City, State Zip: Portland, OR 97232 City, State Zip: Lapwai, ID 83540
Phone: 503-230-3509 Phone: 208-843-7317
Fax: 503-230-3285 Fax: 208-843-7319
Email: jmmccloud@bpa.gov Email: kellyw@nezperce.org
Note: Contact is this projects COTR Note: Contact is NPT Finance Director

Section 2a: Description (Species Information)
Target Species Oncorhynchus tshawytscha (chinook)

Provide explanations as to why the following alternative funding solutions are not feasible and will jeopardize the project:
Reduction in existing scope of project: This proposal is to address the anticipated 2009 funding shortfall associated with a 15% reduction in the Johnson Creek Artificial Propagation Enhancement, Monitoring and Evaluation project (JCAPE). The 15% reduction associated with the "in lieu of" 2009 funding decision affects the JCAPE monitoring and evaluation scope considerably. Both O&M and M&E work are performed under the JCAPE project. The JCAPE FY 08 budget was $1,009,770. The 15% reduction would reduce the project’s budget by $151,465. The M&E portion of this project would be reduced by $151,465 as the O&M portion will continue to be funded at the FY 08 level. This reduction will result in an estimated 33% loss in salaries used to employ personnel who collect/generate/validate field and lab data, an estimated 89% loss in non-administrative funds available for subcontracting (genetic tissue analysis), and an estimated 27% loss in funds used to cover project operations. These losses will invariably compromise our ability to analyze/interpret the data required to evaluate the effects of supplementation.

Changes to the billing structure of marks and tags (specifically coded wire tags (CWT) and visual implant elastomer tags (VIE)) have occurred concurrently with the proposed 15% reduction in the JCAPE M&E budget, which will have a compounding effect on funds available for operation. The CWT and VIE tags were previously itemized under an Equipment line item (non-administrative costs) and were not subject to associated indirect rates. The billing structure has recently changed where costs for marks and tags ($34,000 annually) now fall under the Operating Costs (Materials line item) category and are subject to the NPT indirect rate of 22.69% ($7,714) resulting in an additional outlay of funds that would otherwise be earmarked for project operations and/or salaries.

Deferral of existing work elements to later date: The reduction in funds available for personnel, project operations, and subcontracting could mean certain key work elements would not be completed in 2009, which would in turn affect subsequent years' deliverables. Because the JCAPE project analyzes the hatchery and natural Chinook population by brood year (a brood year typically encompasses 5 years of data), any omission of information in a given year will impair our ability to make subsequent conclusions associated with the performance of the given brood year. If funds are not sufficient to cover costs associated with salaries for field personnel/operations, it's likely the project will have to defer entirely or partially certain work elements such as: WE 158 (Mark/tag animals: Mark Juvenile and Adult Summer Chinook Salmon), WE 157 (Collect/generate/validate field and lab data: Operate Juvenile Screw Traps, Collect DNA, Scale, Snout & Fin Ray Samples from Juvenile & Adult summer Chinook Salmon in JC, Conduct Redd Counts, Prespawning, and Carcass Surveys), or other work elements that are commensurate with the levels of fund reduction.

Section 2b: Description (Location Information)
Location(s) at which the action will be implemented
Latitude Longitude Location Description
44.924834 -115.483024 Juvenile screw trap
44.907755 -116.118447 McCall Fish Hatchery
44.901861 -115.488414 Johnson Creek adult weir
44.773333 -115.540000 Johnson Creek mid-point

Is this/Are these the same study location(s) that was/were identified in the original proposal? Yes

Condition/situation creating the need for the modification:
Is the situation the result of a catastrophic event that occurred within the existing location? No
Has a habitat/population/mechanical/structural dilemma developed in the proposed study location since the contract was signed with BPA? No

Section 2c: Description (Work Element Information)
What work elements in the existing proposal does the proposed modification address?
Work Element Work Element Title
157: Collect/Generate/Validate Field and Lab data Conduct redd counts, prespawning, and carcass surveys
157: Collect/Generate/Validate Field and Lab data Collect DNA, Scale, Snout & Fin Ray Samples from Juvenile & Adult summer Chinook Salmon in JC
158: Mark/Tag Animals Mark Juvenile and Adult Summer Chinook Salmon
157: Collect/Generate/Validate Field and Lab data Operate Juvenile Screw Traps
162: Analyze/Interpret data Evaluate Effects of Supplementation Using Performance Measure Evaluation

Proposed action to achieve the objective(s) The work elements noted above represent those that will likely be modified or eliminated if funding for the project is reduced due to the 'in lieu of' decision. Actions to achieve the objectives, as they pertain to the work elements that may be modified, are defined in the 2007-09 project proposal.

Does not implementing this modification jeopardize the ability to achieve existing biological objectives of this project, as well as other projects? Yes

Explain: As discussed above, the JCAPE M&E project collects information on the performance of hatchery and natural juvenile and adult Chinook salmon each year. If budgetary constraints limit the capacity of the project to continue its seamless collection of biological information from a given life history stage (i.e., either juvenile or adult) during a given year, we will be limited in our ability to accurately compare the relative performance of hatchery and natural fish within the respective broodyear (BY). For instance, if the project is unable to trap juvenile Chinook in the Spring of 2009 due to personnel shortfalls, abundance and survival data from BY07 Chinook smolt and BY08 Chinook parr will be absent. The lack of this information will restrict our ability to draw conclusions around the effectiveness of the supplementation program, which is the project's primary charge.

Section 2d: Description (BiOp Information)
NMFS and/or FWS Biological Opinion that this funding request addresses Strategy
NMFS &/or USFWS
How proposed actions will address the BiOp
(i.e., substrategy / limiting factor / metric to be achieved)
NMFS 2000 hatchery The objectives of this proposal are specifically related to the action plans identified in the 2000 FCRPS Biological Opinion (NMFS 2000). Co-managers, such as the Nez Perce Tribe, are expected to develop monitoring techniques to help resolve a wide range of uncertainties related to supplementation and “reform existing hatcheries and artificial production programs”. Many of the supplementation activities and monitoring and evaluation activities related to supplementation programs and designated in Actions 9, 20, 47, 107, 118, 169, 174, 175, 177, 180, 185, 188, and 189 of the FCRPS Biological Opinion (NMFS 2000) will be executed in part through the objectives of this proposal.
NMFS 2004 hatchery

The JCAPE project is either directly or indirectly related to the following statements presented in the revised 2004 Biological Opinion on Remand (NMFS 2004):

• The UPA proposes to engage in tributary and estuary habitat and hatchery improvement projects under various Congressional authorities as offsets for the unavoidable adverse effects of the FCRPS.

• The UPA proposes to engage in scientific research and monitoring of effects on ESA-listed anadromous fish resulting from the operation of mainstem FCRPS projects on the Columbia and Snake Rivers.

• During the 2004 status review of the Snake River spring/summer Chinook ESU, NOAA concluded that the artificial propagation programs did provide benefits to the ESU in terms of abundance, spatial structure, and diversity, but that the programs had neutral or uncertain effects in terms of overall ESU productivity (Section 4.3.1.3, p. 4-4).

• For NOAA Fisheries’ proposed hatchery listing policy, development of environmental impact statements, and recovery planning efforts, ‘research designed to clarify interactions between natural and hatchery fish and quantify the effects of artificial propagation on natural fish will play a pivotal role in informing these efforts’ (Section 5.3.5, p. 5-46).

• BPA proposes to continue the safety-net planning project, and if necessary, intervene with artificial propagation for severely depressed and declining populations. NOAA has determined that the safety net program for the Snake River spring/summer Chinook ESU is effective at reducing the short-term risk of extinction (includes captive broodstock for Tucannon, and Grande Ronde (Catherine Creek)), captive rearing in Lemhi, East Fork, and West Fork Yankee Fork, Johnson Creek supplementation. The captive broodstock programs and Johnson Creek action increased abundance of the target populations (Section 6.3.2.3, p.6-66).

• The Action Agencies will continue to assess and enumerate pre-spawning mortality and reduced spawning success of adult upstream-migrating fish, which may be due to, or exacerbated by passage through the FCRPS (10.5.2.1, p. 10-10).

• Appendix F of the BiOp (Artificial Propagation Potential as a Non-Hydro Offset for FCRPS Operations: A Summary Assessment – Table F.2, Snake River spring/summer Chinook salmon).

USFWS hatchery The Johnson Creek Artificial Propagation Enhancement (JCAPE) project is part of a cooperative project between NPT, IDFG, and USFWS (LSRCP program) and is one of the high priority Tribal supplementation projects that have been around since the Early Implementation Plan (EIP) process through the Bonneville Power Administration. It has received a high priority ranking through CBFWA and has been reviewed and recommended through the U.S. v Oregon Production Advisory Committee process. NMFS has deemed the project as critical to recovery of ESA-listed salmon (Stelle 1996, 1999). Additionally, this program has undergone intense scrutiny and review through the NMFS ESA Section 10 Permit Application process and an Independent Scientific Review through the NPPC 3-Step Process.

The JCAPE program completed the three-step review process (December, 2005)required by the Northwest Power and Conservation Council (NPCC) that was intended to address elements and conditions placed on the project over the past six years as part of project selection process.

Activities associated with the JCAPE have been authorized under ESA Section 10 and Section 7 Permits and Biological Opinions. These documents include ESA Section 10 Permit No. 1134, Permit No. 1147, and Permit No. 1250 and FWS Section 7 Biological Opinion 501.1100, 1-4-98-F4 (bull trout).

NOAA 2008 hatchery JCAPE is specifically mentioned under RPA 41 (Hatchery Strategy 2) and 50 in the final BiOp for 2009 funding.

Hatchery Strategy 2, is designed to: "Preserve and Rebuild Genetic Resources Through Safety-net and Conservation Actions to Reduce Short-term Extinction Risk and Promote Recovery". Action 41 (Table 7 RPA Table, p. 58), is designed to: "Implement Safety Net Programs to Preserve Genetic Resources and Reduce Short-term Extinction Risk (The Action Agencies will continue to fund the operation of on-going “safety net” programs that are providing benefits to ESA-listed stocks at high risk of extinction by increasing genetic resources and will identify and plan for additional safety-net programs, as needed). Specific mention of the JCAPE project occurs in Table 7: "For Snake River Spring/Summer Chinook: Fund the Johnson Creek/South Fork Salmon River safety net supplementation program, as described in the existing Section 10 permit."

RPA 50 falls under the Research Monitoring and Evaluation Actions, RM&E Strategy 1 (Monitor Status of Selected Fish Populations Related to FCRPS Actions). The Fish Population Status Monitoring Action (RPA 50) states that "The Action Agencies will enhance existing fish population status monitoring performed by fish management agencies through the specific actions listed below. In addition, ancillary population status and trend information is being obtained through several ongoing habitat and hatchery improvement projects (see project tables in Attachment B.2.6-1)." The JCAPE project is identified in Attachment B.2.6-1, Table 8, as a status monitoring project that should maintain its current funding levels. Specific verbiage, as it pertains to the JCAPE project, states: " Fund status and trend monitoring as a component of the pilot studies in the Wenatchee, Methow, and Entiat river basins in the Upper Columbia River, the Lemhi and South Fork Salmon river basins, and the John Day River Basin to further advance the methods and information needed for assessing the status of fish populations. (Initiate in FY 2007-2009 Project Funding, review and modify annually to ensure that these projects continue to provide a means of evaluating the effectiveness of tributary mitigation actions)." For marking, specific verbiage states: "Fund marking of hatchery releases from Action Agencies funded facilities to enable monitoring of hatchery-origin fish in natural spawning areas and the assessment of status of wild populations. (Annually)


Section 2e: Description (Objectives)
Objectives of this proposed project
Objective
(abbreviation)
Full Description
Maint./Enhance Nat. Prod. The key performance measure is progeny-per-parent ratio (P:P) quantified within Johnson Creek for natural-origin fish and hatchery-origin fish independently. This is a derived value. Calculation of P:P relies on annual run reconstructions and requires quantification of adult abundance to Johnson Creek (escapement), index of spawner of abundance (redd counts), spawner abundance (spawner), fish per redd, hatchery fraction, age class structure, age-at-return, adult spawner sex ratio, prespawning mortality, and in-tributary harvest. We use microsatellite-based parentage assignment and exclusion analyses to determine the reproductive success of wild, natural, and supplementation origin spring/summer Chinook salmon in Johnson Creek. Doing so informs management decisions regarding supplementation by quantitatively evaluating the long and short-term effects of supplementation on production and productivity.

The key performance measures to determine and compare the spawning distribution of hatchery and natural origin Chinook salmon in Johnson Creek is adult spawner spatial distribution of female carcasses. Two primary performance measures describing life stage specific survival rates are examined; juvenile emigrant survival to Lower Granite Dam and smolt-to-adult return rate (SAR) for natural-origin fish and hatchery produced fish in Johnson Creek. An additional (derived) performance measure of smolts per redd is used to index population productivity.

Maint. Life Hist./Gen. Div. A suite of four performance measures is used to monitor life history characteristics of natural-origin adults and test for changes due to hatchery supplementation. Key performance measures are age-at-return, size-at-return, sex ratios, and adult run-timing. A suite of three performance measures is used to monitor life history characteristics of hatchery and natural-origin juveniles and test for divergence of the hatchery production group from natural production characteristics. Key performance measures are age-at-emigration, size-at-emigration, and emigration timing. A variety of performance measures will be used to document genetic effects of supplementation on the Johnson Creek natural population. This will be accomplished by characterizing the genetic structure and variability within the population using microsatellite analyses. Indices of genetic differentiation will be calculated and patterns of genetic change will be examined through time in the population.
Coord./Communicate Findings It is imperative that planning and communication occur for the successful implementation of the JCAPE program. An annual Statement of Work (SOW) will guide activities for the M&E and O&M components and will be based on frameworks presented in the JCAPE M&E Plan and Annual Operating Plan and integrated into the PISCES format. We will implement a five-year review process for incorporating JCAPE M&E information into the adaptive management process.

Section 3: Is This Funding Request Related to Other Projects in the Basin?

Other projects that are related to this request
Project # Project Title/Description Nature of Relationship
198909802 Idaho Supplementation Studies in Idaho Rivers The data collected by ISS is directly required for the JCAPE M&E evaluations as reference stream comparisons. Additionally, data collected by JCAPE M&E is used by ISS as a treatment stream.
199703000 Listed Stock Chinook Salmon Escapement Monitoring This project collects data on adult abundance and migration timing of Chinook salmon and is directly required for the JCAPE M&E evaluations as a reference stream comparison.
200301700 Integrated Status and Effectiveness Monitoring Program for Salmonids and their Habitat ISEMP relies on JCAPE adult escapement, juvenile production, probabilistic habitat, and redd survey data to enable analysis of monitoring data in the South Fork Salmon River.
199703800 Salmonid Gamete Preservation Project Johnson Creek is one of the critical streams that provide a significant portion of the total wild gametes preserved every year.
199005500 Steelhead Supplementation in Idaho Rivers Johnson Creek provides life history data through a PIT tag marking program that is used by this project.
198201300 Coded Wire Tag Recovery The JCAPE M&E project assists the CWT Recovery project by uploading CWT recoveries to RMIS
198335000 Nez Perce Tribal Hatcheries This project shares knowledge with JCAPE on development of incubation and rearing techniques, production operations, and results from monitoring and evaluation studies.
199800702 Lostine Supplementation This project shares knowledge with JCAPE on development of incubation and rearing techniques, production operations, and results from monitoring and evaluation studies.
199801005 Pittsburg Landing, Capt. John Rapids, Big Canyon Acclimation Facilities This project shares knowledge with JCAPE on development of incubation and rearing techniques, production operations, and results from monitoring and evaluation studies.

Section 4: Estimated Budget for Planning & Design phase for this request (request amount only)

Work element-based estimated budget
Planning & Design
Objective Work Element Work Element Title Work Element Description Description of Metrics Task Duration
in FYs
Estimated Budget Subcontractor?

Outyear work element-based estimated 2009 - 2012 budget for this proposal
Planning & Design
Work Element Work Element Outyear Description Starting FY
numbers only
Ending FY
numbers only
Estimated cost

Outyear totals
Planning & Design

Section 5: Estimated Budget for Contruction/Implementation phase for this request (request amount only)

Work element-based estimated budget
Contruction/Implementation
Objective Work Element Work Element Title Work Element Description Description of Metrics Task Duration
in FYs
Estimated Budget Subcontractor?

Outyear work element-based estimated 2009 - 2012 budget for this proposal
Contruction/Implementation
Work Element Work Element Outyear Description Starting FY
numbers only
Ending FY
numbers only
Estimated cost

Outyear totals
Contruction/Implementation

Section 6: Estimated Budget for Operations & Maintenance phase for this request (request amount only)

Work element-based estimated budget
Operations & Maintenance
Objective Work Element Work Element Title Work Element Description Description of Metrics Task Duration
in FYs
Estimated Budget Subcontractor?

Outyear work element-based estimated 2009 - 2012 budget for this proposal
Operations & Maintenance
Work Element Work Element Outyear Description Starting FY
numbers only
Ending FY
numbers only
Estimated cost

Outyear totals
Operations & Maintenance

Section 7: Estimated Budget for Monitoring & Evaluation phase for this request (request amount only)

Work element-based estimated budget
Monitoring & Evaluation
Objective Work Element Work Element Title Work Element Description Description of Metrics Task Duration
in FYs
Estimated Budget Subcontractor?
Maint./Enhance Nat. Prod. Collect/Generate/Validate Field and Lab Data Collect DNA, scale, snout & fin ray samples from juvenile and adult Chinook salmon Collect biological samples form adult and juvenile chinook salmon for use in aging, origin determination, and genetic studies comparing natural and hatchery fish. No metrics for this work element 4 $25,244 No
Maint. Life Hist./Gen. Div. Collect/Generate/Validate Field and Lab Data Conduct redd counts, prespawning, and carcass surveys Conduct redd counts and carcass surveys of adult summer Chinook on Johnson Creek and Burnt Log Creek (a tributary to Johnson Creek). Redd counts will be used as a a measure of adult escapement. Record redd locations and document the number of live fish and their origin (hatchery or natural) during each survey. Collect pertinent biological information (length, sex, DNA, retained eggs, marks/tags) from all Chinook salmon carcasses interrogated. In addition, remove various structures from carcasses for aging, collect length, sex, DNA, egg retention information, and examine for the presence of fin clips, coded wire tags, radio tags, VI tags, and other tags. Remove snouts from carcasses containing coded wire for laboratory analysis. Primary R, M, and E focal area (status and trend monitoring) 4 $22,483 No
Maint./Enhance Nat. Prod. Collect/Generate/Validate Field and Lab Data Operate Juvenile Screw Traps Operate juvenile screw trap to estimate the number of summer Chinook salmon parr, pre-smolt, and smolts migrating out of Johnson Creek. Record data on fork length, weight, number of juveniles captured, and marked fish recaptured to estimate brood year production. This will provide annual estimates used to test the effect of supplementation over time. This WE will be conducted concurrently with WE 158 to provide marked fish to compute migration estimates. This work element includes post-season repair and maintenance to screw traps and other field equipment as needed. Primary R, M, and E focal area (status and trend monitoring) 4 $25,244 No
Maint./Enhance Nat. Prod. Mark/Tag Animals Mark juvenile and adult Chinook salmon Utilize the latest in PIT tag and marking techologies to mark juvenile summer Chinook salmon for use in survival and juvenile fish estimation studies. In addition marks will be utilized as a distinguishing mark for hatchery fish for comparisons between natural and hatchery fish. No metrics for this work element 4 $25,244 No
Coord./Communicate Findings Analyze/Interpret Data Conduct genetic parentage analysis to determine and compare relative reproductive success of hatchery and naturally produced Chinook salmon We use microsatellite-based parentage assignment and exclusion analyses to determine the reproductive success of wild, natural, and supplementation origin spring/summer Chinook salmon in Johnson Creek. Doing so informs management decisions regarding supplementation by quantitatively evaluating the long and short-term effects of supplementation on production and productivity. No metrics for this work element 4 $53,250 Yes

Outyear work element-based estimated 2009 - 2012 budget for this proposal
Monitoring & Evaluation
Work Element Work Element Outyear Description Starting FY
numbers only
Ending FY
numbers only
Estimated cost
Collect/Generate/Validate Field and Lab Data Collect biological samples form adult and juvenile chinook salmon for use in aging, origin determination, and genetic studies comparing natural and hatchery fish. 2009 2012 $100,976
Collect/Generate/Validate Field and Lab Data Conduct redd counts and carcass surveys of adult summer Chinook on Johnson Creek and Burnt Log Creek; collect bio. info., record marks/tags/fin clips; collect snouts 2009 2012 $89,932
Collect/Generate/Validate Field and Lab Data Operate juvenile screw trap to estimate the number of summer Chinook salmon parr, pre-smolt, and smolts migrating out of Johnson Creek. Repair/maintain traps during off-season. 2009 2012 $100,976
Mark/Tag Animals mark juvenile summer Chinook salmon for use in survival and juvenile fish estimation studies. In addition marks will be utilized as a distinguishing mark for hatchery fish for comparisons between natural and hatchery fish. 2009 2012 $100,976
Analyze/Interpret Data Use microsatellite-based parentage assignment and exclusion analyses todetermine the reproductive success of wild, natural, and supplementation origin spring/summer Chinook salmon in Johnson Creek. 2009 2012 $213,000

Outyear totals
Monitoring & Evaluation
FY 2009 FY 2010 FY 2011 FY 2012
$151,465 $151,465 $151,465 $151,465

Section 8: Total Budget Modification Request

Itemized Estimated Budget
Item Note FY 2008 Cost
Personnel Fisheries Technicians $43,363
Fringe Benefits [blank] $7,953
Supplies Materials, Repairs/Maintenance $2,000
Travel Includes Perdiem $1,100
Overhead Indirect @ 22.69% $6,435
Other Training $2,000
Other PIT Tag Costs $35,364
Other Subcontract with CRITFC for Genetics $53,250

Total Estimated Budget Modification
Total FY 2008 budget modification $151,465
Total FY 2008 budget for this project, including modification request $1,009,770

Outyear Budget Totals
  2009 2010 2011 2012
Monitoring & Evaluation $151,465 $151,465 $151,465 $151,465
Total Outyear Budgets $151,465 $151,465 $151,465 $151,465

Cost sharing associated with this modification
Organization Item or Service Provided Amount ($) Cash or in-kind?

Section 9: Narrative, Maps and Project Documents
No documents are associated with this request

Part 2 of 3. Current Status of Modification Request
Meeting Date Status Record Entry Date Decision Group Adjustment Category Urgency Status Budget Impact Reconsider Date
9/10/2008  8/22/2008  NA      Submitted  $151,465   
Decision Comments Next Steps
   
9/10/2008  9/2/2008  NA        $151,465   
Decision Comments Next Steps
updated to add amount requested for '09   
9/10/2008  9/10/2008  BOG  Budget  CAT-3b2: Loss of Monitoring and Evaluation Data  Under BOG Review  $151,465  11/22/2008 
Decision Comments Next Steps
Determination on 15% reduction - 15% reduction was taken on the M&E component with total project budget. This resulted in the $151,465 instead of $89,100.  This request will be pooled up for fourth quarter review, and a decision in the middle of November. 
9/10/2008  11/24/2008  BPA  Budget    BPA Approved  $151,465   
Decision Comments Next Steps
Council recommends and BPA approves the request of $151,465 which will be added to the '09 project year budget.   

Part 3 of 3. Comments on this Modification Request
There are no comments on this proposed modification.