Local or MSRT Comments: OSPT proposes reducing the budget by $13K from FY07 proposed to eliminate work in lower priority areas. Flatlined out years to FY07.

The sponsors claim that declining survival is the result of factors other than potential failure of habitat restructuring. They should show that the result is related to these other factors. Ineffective habitat treatment was not eliminated as the cause. Returning adults and number of redds are subject to out-of-basin factors as well as habitat factors that affected survival as juveniles. To be effective, habitat restoration measurements need to be viewed in the context of natural watershed conditions and fish population monitoring, as well as compared to similar measurements from a reference stream without

restoration. Until data are presented to show it to be otherwise, it is faith rather than science that permits a conclusion that changes in habitat have caused increased run-strength. The data presented in response Figure 1 provided no meaningful answer to questions regarding the habitat work. To gain some scientific credibility, sponsors could at least try to provide comparative data from an untreated system to help account for out-of-basin affects. Pointing to modeled results from EDT is not enough. EDT permits formulation of a hypothesis regarding habitat quality, a hypothesis that then needs to be tested.

The response from the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) was not as thorough or as useful as that from related work by ODFW on 198710002, with whom they supposedly coordinate. However, one assumes the same response within 19871002 applies here. The separation of tasks by the two agencies remains confusing, and one of convenience rather than purpose, despite the reasons given. The call for presentation of results in terms of fish response has gone unheeded in both responses. There remains the need to fully develop the effectiveness evaluation of habitat improvement work, and there seems a need for professional assistance towards this process. There is no evidence that an increase in salmonid carrying capacity or productivity is a result of this work. They note, “The obvious increase in the total number of spawners is no doubt due partially to improved habitat…” But without treatment and control data this cannot be confirmed. Indeed, it is the other reasons stated (removal of passage barriers in addition to out of basin factors), particularly the latter, for which variation in adult returns likely exists, and as noted in the former fisheries literature. To repeat, the limiting factors appear to primarily relate to out of basin factors and fish passage within the basin and to flows. The relationship with irrigation and pumping of water remains confusing. An on-site subbasin review is needed.

This project and others like it are individual parts of what the Council has referred to as the “Umatilla Initiative.” As such, none of them is a stand-alone project that can be subjected to scientific peer review on its own merits, but the projects need to be reviewed in the larger context of a plan for restoration of anadromous fishes in the Umatilla Basin. The ISRP’s recommendation of “Not Fundable (Qualified)” for the set of projects that constitute the Umatilla Initiative is explained under project 198343600, Umatilla Passage O&M.

The proponents wisely report data and link up to the M&E projects in the basin, but they seem to not be adaptively managing based on the data. Other results suggest that limiting factors are outside of the basin (see figures 3-5 on project 198902401). Sponsors need to convince reviewers that the strategies employed here over the many years are worth continuing from the perspective of steelhead and chinook salmon benefits. They should provide smolt-per-spawner data (see 198902401). This is the key response variable for habitat work, when presented relative to spawner abundance, and is especially instructive when compared to untreated controls. Other possible designs for evaluation are possible.

Given alteration of stream characteristics in the Umatilla Basin, it is logical to assume that productivity of the system for salmonids is less than it once was. This project puts together actions and agreements in an attempt to recover some of that lost productivity. The approach, however, is always subject to questions regarding whether or not the "right" thing is being done from the perspective of the fish. The results of this work as found and described in project 20072009 show declining survival from egg to smolt over the past decade (Figs. 3-5). In light of these results, sponsors of this work need to provide a convincing case for continuing this work as presently outlined.

Among the objectives listed is "Develop alternative water source". The method described is to sink wells and pumps. Has any thought been given in the Umatilla Basin to purchase of water rights and/or lands with such rights with the objective of replacing the "Power Repay" project, which is extremely expensive and becoming more so? For $1.5 million a year, which is the current cost of the electricity to pump Columbia River water, a considerable acreage might be purchased or otherwise put out of production, so as to reduce the need for irrigation removals, the volume of which obviously exceed the base flow of the Umatilla River.

See 198710002 - Umatilla Subbasin Fish Habitat Improvement Project - many comments there also apply here.