Local or MSRT Comments: OSPIT supports this new project that both the local process and LCRFB rated highly. We do hope that BI-op elements of project 200300600 may be incorporated into this project. We believe there are efficiencies that can be gained at a slightly reduced bud

In the preliminary review, the ISRP raised questions about the essential need to collect abundance data from the Grays River, since other intensive monitoring was taking place in the lower Columbia River and estuary. It was not clear to the ISRP that these data collections were called for in the subbasin or recovery plan. The sponsors clarified that the Lower Columbia Fish Recovery Board’s Lower Columbia Salmon Recovery and Fish and Wildlife Subbasin Plan serves as the "subbasin" plan for the Grays River and has been adopted by the Council and accepted by NOAA Fisheries as the recovery plan for this region. The sponsors also clarified that the Grays River is not part of the State of Washington’s Intensively Monitored Watershed program, but instead was recommended for in-depth biological monitoring by the subbasin plan, and that this proposal is consistent with that recommendation. They attached the recommended monitoring schedule.

The ISRP also questioned the basis for initiating supplementation for chum salmon in the Grays River. The sponsor response to the ISRP questions regarding the assessments on which supplementation for chum salmon is based were inadequate. They identified the biological status review and listing decision for these species, a genetic analysis of Columbia River chum salmon, the history of recent habitat disruptions from winter storms, Washington Department of Fisheries and Wildlife risk/benefit assessment for supplementation, and a completed Hatchery Genetic Management Plan. It appears that the agency position is that supplementation is necessary to avoid possible catastrophic losses because of limited spawning areas. The ISRP understands that supplementation is intended to improve the status of natural populations when spawning and juvenile rearing habitat is underseeded. What is missing from this section is any indication that the performance of the natural population can be improved based on the inherent performance of a hatchery stock. It is questionable that a supplementation program will accelerate effort to sustain wild production or maintain or improve habitat for wild fish. The supplementation portion of the proposal is probably not as important as the monitoring portion until a better understanding exists of stock status and trends. However, the issue of supplementation but can be addressed more thoroughly during a Three-Step Review.

The technical explanation for the methods for estimating juvenile and adult salmonids is adequate. The justification for the supplementation is not clear, but they are proposing to conduct a rapid Three-Step Review (all three steps at once) in the fall of 2006, so the rationale could become clear in that process.

The rationale for population estimates from the Grays River are not sufficiently demonstrated. Page 6 identifies the Grays River as an intensively monitored watershed by the Lower Columbia River Salmon Recovery Plan. However, the Washington Salmon Recovery Funding Board’s report on Intensively Monitored Watersheds (IMWs) identifies the nearby Abernathy, Mill, and Germany creeks as intensively monitored watershed sites, not the Grays River. No reference to the identification of the Grays River as being an important site for population estimation is attributed to the Council’s subbasin plan. Sponsors note that the Grays River is classified by the Lower Columbia River Salmon Recovery Plan as in intensively monitored watershed (LCFRB 2004b). But how this plans relates to the Council’s subbasin plan or other regional recovery plans or obligations is not clear.

A response is requested that clarifies the need to monitor these species in this watershed. What is needed here is the number and location of sites that are identified by Washington, Oregon, and NOAA as needed to assess the Lower Columbia River ESUs. It may be that this is an essential location for monitoring but it is not clear from the proposal.

A response is requested on the supplementation portion of the proposal that lays out the assessments conducted by the sponsors to clearly establish the need for and benefits of any supplementation efforts.