FY 2007 Solicitation Homepage

Project Proposal Request for FY 2007 - FY 2009 Funding

Proposal 200713900: Rock Creek Stabilization and Habitat Rehabilitation

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Table of Contents
Part 1. Administration and Budgeting
Section 1: General Administrative
Section 2: Project Location
Section 3: Project Species
Section 4: Past Accomplishments
Section 5: Relationship to Other Projects
Section 6: Biological Objectives
Section 7: Work Elements
Section 8: Budget
Section 9: Project Future
Section 10: Documents
Part 2. Reviews
Part 1 of 2. Administration and Budgeting
Section 1: General Administrative Information
Process Information:
Date Proposal Submitted & Finalized Status Form Generator
January 10, 2006 Finalized Russ Lawrence

Proposal Type: New
Proposal Number: 200713900
Proposal Name: Rock Creek Stabilization and Habitat Rehabilitation
Agency, Institution or Organization: Skamania County
Short Description: Rehabilitation of riparian area and habitat for the lower 5300 feet of Rock Creek, Stevenson, Skamania Co., WA
Information Transfer: Annual Reports to BPA, Project design, construction process success and lessons learned papers to be presented at symposia, exchange of fish counts and monitoring information with Washington and US fish and wildlife biologists
 
Project Proposal Contacts
Contact Organization Address Phone/Email Roles Notes
Form Submitter
Russ Lawrence StreamFix 19478 S. Starview Ln
Oregon City, OR 97045
Ph: 503-631-8184
Fax: [left blank]
Email: russ@streamfix.com
Form Submitter
All Assigned Contacts
Russ Lawrence LEE-PACE Engineers, Inc. 1300 John Adams Street
Oregon City, OR, 97045
Ph: 503.655.1342
Fax: 503.655.1360
Email: russl@lee.paceengrs.com
Project Lead
Technical Contact
Tod Lefevre Skamania County Public Works P.O. Box 790
Stevenson, WA, 98648
Ph: 509.427.9448
Fax: 509.427.4893
Email: lefevre@co.skamania.wa.us
Contract Manager

Section 2: Project Location
Sponsor Province: Columbia Gorge ARG Province: No Change
Sponsor Subbasin: Columbia Gorge ARG Subbasin: No Change
Location(s) at which the action will be implemented
Latitude Longitude Waterbody Location Description County/State Subbasin Primary?
45°41’37”N 121°53’32”W Rock Cr. Stevenson, Washington Skamania/Washington, Columbia Gorge No

Section 3: Focal Species
Focal Species:
Primary Secondary Additional Species
Chum Columbia River ESU
Chinook Mid-Columbia River Spring ESU
Coho Unspecified Population
Steelhead Middle Columbia River ESU

Section 4: Past Accomplishments
Past Accomplishments for Each Fiscal Year of This Project This proposal is for funding a new project, and has no past accomplishments.

Section 5: Relationships to Other Projects
Other Current Projects Related to this Project (any funding source)
Funding Source Related ID Related Project Title Relationship
Other: County Skamania Rock Creek Bridge assessment The County has engaged kpff Consulting Engineers et al. to develop alternatives for the further maintenance/ replacement of the Rock Creek Bridge

Section 6: Biological Objectives
Biological Objectives of this Proposed Project
Biological Objective Full Description Associated Subbasin Plan Strategy Page Nos
maintain winter steelhead at low viability level provide for a 40-74% probability of persistance level over 100 years Columbia Gorge increase pool/riffle habitat; increase LWD; decrease Width/Depth ratio; increase riparian corridor; enhance sediment transportation competence L30-L35
Restore upper Gorge Chum to medium viability level Providing a 75 to 94% probability of persistance over 100 years Columbia Gorge increase pool/riffle habitat; increase LWD; decrease Width/Depth ratio; increase riparian corridor; enhance sediment transportation competence L30 to L35
Restore upper Gorge coho to a high viability level Providing a 95% probability of persistance over 100 years Columbia Gorge increase pool/riffle habitat; increase LWD; decrease Width/Depth ratio; increase riparian corridor; enhance sediment transportation competence L30 to L35

Section 7: Work Elements
Work Elements and Associated Biological Objectives
Work Element Name Work Element Title Description Start Date End Date Estimated Budget
Produce Environmental Compliance Documentation NEPA and ESA compliance for project work for Rock Creek stabilization, habitat rehabilitation and riparian planting and monitoring. Complete a NEPA Checklist and write a Biological Assessment within the context of NOAA (Fisheries) section 7 consultation, for stream stabilization, habitat restoration and riparian planting and monitoring activities and submit to BPA’s Environmental Compliance Group. 10/1/2006 7/31/2007 $36,250
Biological Objectives Metrics
No Metrics for this Work Element

Increase Instream Habitat Complexity Rock Creek Stabilization and Habitat Rehabilitation Construction Implement designed stabilization and instream habitat complexity development activities for Rock Creek. 7/15/2008 9/30/2008 $173,850
Biological Objectives Metrics
* # of stream miles treated: 1 mile
* # of structures installed: 37
* End lat of treated reach: 45.6999
* End long of treated reach: 121.8994
* Start lat of treated reach: 45.6911
* Start long of treated reach: 121.8904

Plant Vegetation Plant vegetation in the riparian zone along the restored reach of Rock Creek Design planting plan to restore native vegetation in the project riparian zone. This will include the removal of invasive species such as Himalaya blackberries (Rubus discolor), Scotch broom (Cytisus scoparius) and other noxious invasive species. This work will include reloacting approximately one quarter mile existing paved parking at the top of the bank below the county bridge. This parking currently serves the County Fairgrounds and will be relocated to the West side of the facility. 11/15/2008 2/28/2009 $65,750
Biological Objectives Metrics
* # of acres of planted: 3.6
* # of riparian miles treated: 1 mile both banks

Realign, Connect, and/or Create Channel Restore sinuosity, and create and connect side channels in Rock Creek. Implement designs for sinuosity restoration and creation and connection of side channel activities for Rock Creek. 7/15/2008 9/30/2008 $256,180
Biological Objectives Metrics
* # of stream miles treated, including off-channels, after realignment: 1.25
* # of stream miles before treatment: 1.0
* End lat of treated reach: 45.6999
* End long of treated reach: 121.8994
* Start lat of treated reach: 45.6911
* Start long of treated reach: 121.8904

Remove vegetation Remove invasive species in the riparian zone along the restored reach of Rock Creek Remove invasive species such as Himalaya blackberries (Rubus discolor), Scotch broom (Cytisus scoparius) and other noxious invasive species in preparation for planting native riparian species in the riparian zone along the restored reach of Rock Creek 8/15/2008 9/30/2008 $16,318
Biological Objectives Metrics
* # of acres treated: 3.6

Maintain Vegetation Monitor and maintain trees and shrubs planted in the riparian zone along the restored reach of Rock Creek Perform riparian planting and monitoring actrivities including semi annual photo monitoring, watering plants, replacing plants as required 5/1/2009 9/30/2009 $5,100
Biological Objectives Metrics
No Metrics for this Work Element

Operate and Maintain Habitat/Passage Maintain stabilization and habitat enhancement structures and LWD in the restored reach of Rock Creek Annually inspect and maintain the stabilization and habitat enhancement structures and LWD in the restored reach of Rock Creek. 7/15/2009 9/30/2009 $22,050
Biological Objectives Metrics
No Metrics for this Work Element

Lease Land Conservation easement acquisition Acquire conservation esements from Skamania County and the City of Stevenson for riparian corridor development 10/1/2006 6/15/2007 $81,914
Biological Objectives Metrics
* # of acres of renewed lease: 0.4
* # of riparian miles protected: 0.24
* End date of lease: permanent
* Start date of lease: 06/15/2007

Manage and Administer Projects Rock Creek Stabilization and Habitat Rehabilitation project administration Project management and administrative work related to the contract excluding Environmental Compliance Documentation. This work will include Pisces Status reports (WE 185) and annual reports (WE 132). 10/1/2006 9/30/2009 $64,350
Biological Objectives Metrics
No Metrics for this Work Element

Produce Design and/or Specifications Rock Creek Stabilization and Habitat Rehabilitation Design Design, detail and develop construction specifications and bid documents for stabilization and habitat complexity development activities for Rock Creek. 1/2/2007 12/31/2007 $102,250
Biological Objectives Metrics
No Metrics for this Work Element


Section 8: Budget

Itemized Estimated Budget
Item Note FY 2007 Cost FY 2008 Cost FY 2009 Cost
Personnel Engineering, Permiting, Construction Administration $14,920 $21,640 $19,000
Supplies Project Maintenance $ 0 $ 0 $22,050
Fringe Benefits [blank] $3,730 $5,410 $4,750
Other Sub Contracts $125,164 $462,280 $145,068
Totals $143,814 $489,330 $190,868

Total Estimated FY 2007-2009 Budgets
Total Itemized Budget$824,012
Total Work Element budget$824,012

Cost sharing
Funding Source or Organization Item or Service Provided FY 2007 Est Value ($) FY 2008 Est Value ($) FY 2009 Est Value ($) Cash or in-kind? Status
City of Stevenson Conservation Easement $17,094 $ 0 $ 0 In-Kind Under Review
Skamania County Conservtion EAsement $64,820 $ 0 $ 0 In-Kind Confirmed
Skamania County Maint & Materials $ 0 $ 0 $16,600 In-Kind Confirmed
Skamania County Move Parking $ 0 $47,000 $ 0 In-Kind Confirmed
Totals $81,914 $47,000 $16,600

Section 9: Project Future
Project Future Costs and/or Termination
FY 2010 Est Budget FY 2011 Est Budget Comments
$32,050 $28,000 Final two years riparian plant and instream structure maintenance and reporting
Future Operations & Maintenance Costs
In the event a sediment pulse occurs of a magnitude to bury, or seriously fill the stability and habitat structures, Skamania County is prepared to excavate the material necessary to maintain the reaches stability and habitat values
 
Termination Date Comments
June 30,2011
 
Final Deliverables
Final report and documentation showing the project development, implementation and monitoring process and results.

Section 10: Narrative
Document Type Size Date
Narrative for proposal 200713900 doc 72 kb 1/10/2006

Part 2 of 2. Reviews of Proposal
Administrative Review Group (ARG) Results
Account Type:
Expense
No changes were made to this proposal


BPA's in lieu Funding Review of new project proposals (August 3, 2006) [Download letter and table]

BPA's in lieu Rating: 1.0
Approx. BPA share of total costs: BPA 85%
Status of Cost Share: Mixed
Notes: LWD etc to improve pool/riffle habitat; assume no other entity required to perform


NPCC Final Funding Recommendations (October 23, 2006) [Full NPCC Council Recs]

FY 2007 Budget
$ 0
FY 2008 Budget
$ 0
FY 2009 Budget
$ 0
Total NPCC Rec
$ 0
Budget Type:Expense
Budget Category:ProvinceExpense
Recommendation:Do Not Fund
Comments:


NPCC Draft Funding Recommendations (September 15, 2006) [Full NPCC Council Recs]

FY 2007 Budget
$ 0
FY 2008 Budget
$ 0
FY 2009 Budget
$ 0
Total NPCC Rec
$ 0
FY 2007 MSRT Rec
$ 0
FY 2008 MSRT Rec
$ 0
FY 2009 MSRT Rec
$ 0
Total MSRT Rec
$ 0
Budget Category:ProvinceExpense
Comments:

Local or MSRT Comments: See Washington guidance


Independent Scientific Review Panel Final Review (August 31, 2006) [Download full document]

Recommendation: Not fundable
NPCC Comments: The ISRP believes this proposal is not fundable for the following reasons:

The symptoms of this watershed problem seem to be a mile-long channelized length of Rock Creek with excessive sediment and with poor in-channel and riparian habitat. The existing conditions are not clearly described for reviewers who are not familiar with the site. No maps, drawings or photos are provided, but they are needed. This proposal characterizes the problem as inadequate sediment transport capacity, with an over-widened, shallow channel. It does not provide a description of the channel: floodplain dimensions, channel planform/sinuousity conditions or the condition of bank and floodplain vegetation.

The technical background section adequately describes in general terms what is proposed, but it does not provide enough information about the status of the fish using Rock Creek or the extent to which the current habitat conditions have departed from pre-development conditions. The proposal is to rehabilitate about one mile of stream. Approximately how many fish used this reach in the past, and how does that compare to its current capacity? A high degree of accuracy is not needed, but the proposal does not really address the issue of how Rock Creek productivity will benefit from the restoration efforts. Additionally, it would have been helpful to cite other projects that have used a similar hard engineering approach to habitat restoration and have been able to demonstrate a significant increase in salmon production.

The proposal mentions that the role of tributaries as important spawning and rearing areas is recognized in the Lower Columbia subbasin plan, but it is not clear if Rock Creek was specifically identified as a stream in need of significant restoration. Nearby Hamilton Creek is targeted as an important chum salmon spawning site in several plans, but particular references to Rock Creek are missing from this proposal. If chum salmon are the primary focal species for this project (they are identified as such in Section 3 of the cover pages), how much potential chum production can be achieved by rehabilitating a mile of stream?

The planting plan is vague; without reference to the engineering works, it gives the impression that planting is unrelated to the stream engineering works. The prescriptions are large rock and large wood jam structures, with no mention of use of woody vegetation for bank stabilization or channel narrowing. The relatively hard engineering approach proposed here is unlikely to achieve the stated objectives.

The concern is that this proposal will result in inappropriate alteration of a riparian corridor to a narrowed channel, with a resulting lack of spawning gravels in the channel owing to excessive sediment transport capacity. In this situation you might want to give more room for flood flows, not less; the flushing of sediments approach could scour the channel bed, resulting in headcutting.

This proposal does not provide enough information to justify the proposed actions. Of specific concern is that the project does not seem to address the cause of the problems. If flood flows are given proper access to the floodplain, then lower velocity flows will result in sediment sorting that will replenish spawning gravels by hydraulic forces. This can be achieved best by the use of bioengineered structures such as willow baffles for bank protection and finer sediment retention, connected with brush mattress design on the floodplain banks. This kind of approach will significantly increase habitat functions sustainably and cost-effectively, but a level of expertise is needed that is not evident on the team.

This project is essentially a band-aid on some other problems. In fact, the following quotes are from sections of the CGTB watershed plan and indicate an entirely different approach:

1. Restoration of degraded channel habitat in Rock Creek may require action outside the targeted reach, often extending into riparian and hillslope (upland) areas that are believed to influence the condition of aquatic habitats.

2. Sediment conditions in Rock Creek will remain moderately impaired to impaired until headwaters sediment sources are addressed.

The County should be complimented for their intent to increase fish habitat and asked to ensure the more watershed-based, passive approach indicated in 1 and 2 above.

In more detail, Table 8. “Prioritized measures for the Columbia Gorge Tributaries Basin” lists measures to improve fish habitat conditions. The 1st location is the lower mainstem Rock Creek up to Rock Creek Falls (RM 1), for anadromous access. However, the prioritized submeasures for Measure #1, Protect stream corridor structure and function are:

A. Protect floodplain function and channel migration processes

B. Protect riparian function

C. Protect access to habitats

D. Protect instream flows through management of water withdrawals

E. Protect channel structure and stability

F. Protect water quality

G. Protect the natural stream flow regime

Floodplain function and channel migration processes must be maintained together with increasing riparian structure and function. Protecting channel structure and stability should follow achievement of the previous priorities, especially by addressing the excessive sediments being delivered to the lower mainstem from upstream logging-related roads and landslides.

Rather than concentrate flows by altering channel structure in the best habitat reach in order to flush sediments through this lower reach, the published priorities would imply instead some type of a revegetation/ soil bioengineering approach to restore the stream systems' sediment sorting and storage capabilities. This can be achieved while decreasing the lower channel width/depth ratio and rebuilding the lost floodplain by trapping sediments. In addition, watershed restoration should address upstream logging- related landslides and road crossings.

Table 7 summarizes the Limiting Factors for habitat conditions on Rock Creek. The list does not include the proposal proponents' assertion that channel instability is the primary problem.

Considering the relatively high cost of the project, the likelihood of continued maintenance, and some questions about (1) applying these particular restoration procedures to this channel type, and (2) whether a passive restoration approach would be more appropriate and cost-effective in the long term, this proposal needs a better scientific justification and some prediction of the effects of the project on salmonid productivity.

Other review comments:

Relationships to other projects are inadequately described; the proposal does not seem to be integrated with fish and wildlife programs. More details, and references to ongoing salmon enhancement projects of similar intent in the Columbia Gorge, are needed.

The other work described is for maintenance and replacement of a bridge, already initiated by Skamania County. There does not appear to be any interdependency or collaboration between the two proposed projects.

The objectives are clear in terms of the number of instream structures that will be placed and streambanks that will be replanted with native trees, but there are a number of unanswered questions.

It appears that this proposal will attempt to turn a plane bed channel into a forced pool-riffle channel (using the classification terminology of Montgomery and Buffington). If, in fact, the Rock Creek watershed continues to experience episodic high intensity erosion events, it seems very likely that the hard engineered structures will require frequent, expensive maintenance as the stream naturally tries to return to a sediment-rich plane bed channel. Is the high initial cost and possibly frequent maintenance the best use of restoration dollars?

The types of structures described in the proposal are typical of a Rosgen-type restoration project where the objective is to create better salmonid rearing habitat but it seems the real target species is chum salmon, which may not really benefit from the pool habitat that may be created. The proposal mentions potential benefits for coho, Chinook, and steelhead but do we know whether these species actually use Rock Creek?

The objective of getting rid of the non-native riparian plant species and replacing them with native species is a good one. What will be done to ensure these native plants survive?

To achieve the objectives stated, the equipment and personnel are probably adequate, but again the size and number of large machines required are such that there will be a substantial impact on the local environment, compared with the alternative suggested above.

Plans appear to be limited to annual reports to BPA, with occasional presentations to the public. There is no mention of data archiving, or storage of time-series photos, and possible volunteer actions outside the scope of the project (photographs to be supplied to the client by schools taking part).

Unless funding for long-term maintenance of the engineered features of Rock Creek is guaranteed, benefits are likely to be short term and harm may possibly result. If the stream sinuousity is indeed “fixed” by this proposal, it will persist over the long-term, but this may be deleterious to the fish population.


Independent Scientific Review Panel Preliminary Review (June 2, 2006) [Download full document]

Recommendation: Not fundable
NPCC Comments: The ISRP believes this proposal is not fundable for the following reasons:

The symptoms of this watershed problem seem to be a mile-long channelized length of Rock Creek with excessive sediment and with poor in-channel and riparian habitat. The existing conditions are not clearly described for reviewers who are not familiar with the site. No maps, drawings or photos are provided, but they are needed. This proposal characterizes the problem as inadequate sediment transport capacity, with an overwidened, shallow channel. It does not provide a description of the channel: floodplain dimensions, channel planform/sinuousity conditions or the condition of bank and floodplain vegetation.

The technical background section adequately describes in general terms what is proposed, but it does not provide enough information about the status of the fish using Rock Creek or the extent to which the current habitat conditions have departed from pre-development conditions. The proposal is to rehabilitate about one mile of stream. Approximately how many fish used this reach in the past, and how does that compare to its current capacity? A high degree of accuracy is not needed, but the proposal does not really address the issue of how Rock Creek productivity will benefit from the restoration efforts. Additionally, it would have been helpful to cite other projects that have used a similar hard engineering approach to habitat restoration and have been able to demonstrate a significant increase in salmon production.

The proposal mentions that the role of tributaries as important spawning and rearing areas is recognized in the Lower Columbia subbasin plan, but it is not clear if Rock Creek was specifically identified as a stream in need of significant restoration. Nearby Hamilton Creek is targeted as an important chum salmon spawning site in several plans, but particular references to Rock Creek are missing from this proposal. If chum salmon are the primary focal species for this project (they are identified as such in Section 3 of the cover pages), how much potential chum production can be achieved by rehabilitating a mile of stream?

The planting plan is vague; without reference to the engineering works, it gives the impression that planting is unrelated to the stream engineering works. The prescriptions are large rock and large wood jam structures, with no mention of use of woody vegetation for bank stabilization or channel narrowing. The relatively hard engineering approach proposed here is unlikely to achieve the stated objectives.

The concern is that this proposal will result in inappropriate alteration of a riparian corridor to a narrowed channel, with a resulting lack of spawning gravels in the channel owing to excessive sediment transport capacity. In this situation you might want to give more room for flood flows, not less; the flushing of sediments approach could scour the channel bed, resulting in headcutting.

This proposal does not provide enough information to justify the proposed actions. Of specific concern is that the project does not seem to address the cause of the problems. If flood flows are given proper access to the floodplain, then lower velocity flows will result in sediment sorting that will replenish spawning gravels by hydraulic forces. This can be achieved best by the use of bioengineered structures such as willow baffles for bank protection and finer sediment retention, connected with brush mattress design on the floodplain banks. This kind of approach will significantly increase habitat functions sustainably and cost-effectively, but a level of expertise is needed that is not evident on the team.

This project is essentially a band-aid on some other problems. In fact, the following quotes are from sections of the CGTB watershed plan and indicate an entirely different approach:

1. Restoration of degraded channel habitat in Rock Creek may require action outside the targeted reach, often extending into riparian and hillslope (upland) areas that are believed to influence the condition of aquatic habitats.

2. Sediment conditions in Rock Creek will remain moderately impaired to impaired until headwaters sediment sources are addressed.

The County should be complimented for their intent to increase fish habitat and asked to ensure the more watershed-based, passive approach indicated in 1 and 2 above.

In more detail, Table 8. “Prioritized measures for the Columbia Gorge Tributaries Basin” lists measures to improve fish habitat conditions. The 1st location is the lower mainstem Rock Creek up to Rock Creek Falls (RM 1), for anadromous access. However, the prioritized submeasures for Measure #1, Protect stream corridor structure and function are:

A. Protect floodplain function and channel migration processes

B. Protect riparian function

C. Protect access to habitats

D. Protect instream flows through management of water withdrawals

E. Protect channel structure and stability

F. Protect water quality

G. Protect the natural stream flow regime

Floodplain function and channel migration processes must be maintained together with increasing riparian structure and function. Protecting channel structure and stability should follow achievement of the previous priorities, especially by addressing the excessive sediments being delivered to the lower mainstem from upstream logging-related roads and landslides.

Rather than concentrate flows by altering channel structure in the best habitat reach in order to flush sediments through this lower reach, the published priorities would imply instead some type of a revegetation/ soil bioengineering approach to restore the stream systems' sediment sorting and storage capabilities. This can be achieved while decreasing the lower channel width/depth ratio and rebuilding the lost floodplain by trapping sediments. In addition, watershed restoration should address upstream logging- related landslides and road crossings.

Table 7 summarizes the Limiting Factors for habitat conditions on Rock Creek. The list does not include the proposal proponents' assertion that channel instability is the primary problem.

Considering the relatively high cost of the project, the likelihood of continued maintenance, and some questions about (1) applying these particular restoration procedures to this channel type, and (2) whether a passive restoration approach would be more appropriate and cost-effective in the long term, this proposal needs a better scientific justification and some prediction of the effects of the project on salmonid productivity.

Other review comments:

Relationships to other projects are inadequately described; the proposal does not seem to be integrated with fish and wildlife programs. More details, and references to ongoing salmon enhancement projects of similar intent in the Columbia Gorge, are needed.

The other work described is for maintenance and replacement of a bridge, already initiated by Skamania County. There does not appear to be any interdependency or collaboration between the two proposed projects.

The objectives are clear in terms of the number of instream structures that will be placed and streambanks that will be replanted with native trees, but there are a number of unanswered questions.

It appears that this proposal will attempt to turn a plane bed channel into a forced pool-riffle channel (using the classification terminology of Montgomery and Buffington). If, in fact, the Rock Creek watershed continues to experience episodic high intensity erosion events, it seems very likely that the hard engineered structures will require frequent, expensive maintenance as the stream naturally tries to return to a sediment-rich plane bed channel. Is the high initial cost and possibly frequent maintenance the best use of restoration dollars?

The types of structures described in the proposal are typical of a Rosgen-type restoration project where the objective is to create better salmonid rearing habitat but it seems the real target species is chum salmon, which may not really benefit from the pool habitat that may be created. The proposal mentions potential benefits for coho, Chinook, and steelhead but do we know whether these species actually use Rock Creek?

The objective of getting rid of the non-native riparian plant species and replacing them with native species is a good one. What will be done to ensure these native plants survive?

To achieve the objectives stated, the equipment and personnel are probably adequate, but again the size and number of large machines required are such that there will be a substantial impact on the local environment, compared with the alternative suggested above.

Plans appear to be limited to annual reports to BPA, with occasional presentations to the public. There is no mention of data archiving, or storage of time-series photos, and possible volunteer actions outside the scope of the project (photographs to be supplied to the client by schools taking part).

Unless funding for long-term maintenance of the engineered features of Rock Creek is guaranteed, benefits are likely to be short term and harm may possibly result. If the stream sinuousity is indeed “fixed” by this proposal, it will persist over the long-term, but this may be deleterious to the fish population.

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