The Response emphasizes the ISRP Programmatic Comment that the projects making up the Council's "Umatilla Initiative" are not susceptible to scientific peer review in isolation one from another. The Response notes, for example, that this particular project has responsibility only for operation and maintenance of facilities used by other projects, and has no information on benefits to Fish and Wildlife. It refers the ISRP to other proposals, such as #198802200, in which such information might be found. The response "agreed" with the ISRP comment that "The facilities that are maintained in this project should be called for in other projects that are referenced in this one. Justification for this project should be specifically provided in the group of individual projects that use the facilities maintained and operated by this one." (ISRP review June 2006)

Programmatic Comments on the Umatilla Initiative:

This complex Umatilla Initiative includes numerous individual projects, most of which are scientifically justifiable only in the larger context of the plan into which they fit. However, for whatever reason, they have been presented to the ISRP as individual proposals. The cross-referencing in the responses to other proposals where information may be found, is not sufficiently helpful to reviewers to make possible a meaningful scientific review. Please see the response review on 198802200. 198343600 (Umatilla Passage O&M), 198802200 (Umatilla Fish Passage Operations), and 198902700 (Power Repay Umatilla Basin Project), totaling ~$7.2M over the three years, deal with the same project and issues. It remains a difficult task to sort this project out from the others, and to obtain a coherent response on the issues and fish response, in order to conduct a scientific peer review that would lead to project approval.

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 needs to be reviewed in the larger context of a plan for restoration of anadromous fishes in the Umatilla Basin. The plan described in the Umatilla Subbasin Plan includes several major efforts, listed below: (These are drawn from recollections of the ISRP review of the Umatilla/Willow Subbasin Plan.)

1. Water is pumped from the Columbia River into the Umatilla Basin with the twin objectives of supplementing supplies for irrigation and supplementing instream flows for fish. Water is over-allocated for irrigation, which leads at times to dewatering of the lower 30 to 50 miles of the Umatilla River. The pumping system was constructed by the U.S. Bureau of Reclamation (BUREC), which continues to maintain it. However, charges for electricity to operate the pumps, are funded by BPA as recommended by the Northwest Power and Conservation Council under its Fish and Wildlife Program. The Bureau of Reclamation is developing plans for a Phase III construction project, which would enlarge the capacity of the system.

2. The Umatilla Hatchery was constructed and operates with BPA funds as recommended by the Council. Chinook salmon have been restored to the Umatilla River as a result of hatchery operations. Dewatering of the lower river at times still requires trapping and transportation of adult and juvenile fish around the lower section of the river.

3. Habitat improvement is being undertaken in the Umatilla Basin to restore its utility for spawning and rearing of salmon and steelhead. Fish produced as a result of habitat improvement there will still be affected by flow conditions, including dewatering in the lower reaches of the Umatilla River.

4. A study of lamprey is underway to identify limiting factors and find ways to restore their abundance in the Umatilla Basin. Flow conditions and other passage problems are likely to be primary limiting factors among those to be found in the Umatilla River.

Identification of Particular Subjects that Warrant Review:

Our curiosity has been especially aroused with regard to the water pumping measure adopted to improve instream flows in the Umatilla River (Proposal #198902700 Power Repay). We find that virtually no attention has been given to evaluation of effectiveness of this measure in achieving one of its primary stated objectives to improve stream conditions for fish. For example, the ISRP, in our review of June 2006 asked the proponents if there is a cap to the volume of water that might be requested to be pumped, and if so, what is the cap? It appears that the answer to that question is not straightforward, or perhaps not available. We are told in the response to proposal #198802200 (pages 2 and 3) that requests for pumped water, made by this project, (or by the Stanfield Irrigation District?), are made to the Bureau of Reclamation through the Oregon Water Resources Department (OWRD). The latter agency does the accounting for both the exchange and storage portions of the Umatilla Basin Project (UBP of BUREC). The responses describe a complex system for deciding when and where to pump the water and release it, but the most complete description, found in proposal #198802200, explains only that "The volume of water to be pumped depends on which "phase" of the UBP is being exchanged." (page 2)

The Response to #198802200 also notes "Currently, there is no M & E specific to the passage program being conducted although an updated passage conditions assessment has been proposed for 07-09 under project 19000501. However, this passage assessment component is not identified for funding at this time." (page 2). The ISRP has previously called attention to the need for a monitoring and evaluation plan to be described in each proposal. Without inclusion of M & E information, the ISRP is unable to discover to what degree or whether anadromous fishes actually benefit from actions proposed. Nor have we been able to identify a proposal that would monitor and/or evaluate the effects on fish of the passage facilities in the Umatilla River.

It remains unclear why the total cost of the Power Repay Project #198902700 ($1.5 million) is charged to the Council's Fish and Wildlife Budget, when the pumped water is shared "bucket for bucket' with irrigators.

Conclusions
Although a rigorous pursuit of Congress' charge to the ISRP would result in a conclusion of "not fundable" based upon the criteria we are instructed to use and the information we have been given, we conclude that would be disruptive rather than constructive at this particular time. However, we strongly urge Council to pursue a scientific peer review of the Umatilla Initiative, as soon as possible.

There is a need for review of the Umatilla Initiative from a larger perspective than can be provided by review of individual project proposals, such as we have in hand.

Firstly, for the ISRP review we recommend that a unified proposal be developed that would encompass the four major efforts listed above. It would address each of the 10 subjects listed in the standard proposal form that then form the basis for ISRP review. In particular, specific plans for monitoring and evaluation are needed in order to establish expected or measured benefits to fish. This suggests that, for example, the proponents might benefit by reorganizing their efforts under a single head. That would provide a unified perspective, leading to clarification of the fact that the success of all of the individual efforts are affected by the pumping of water from the Columbia River. Monitoring and evaluation should then focus upon documenting flow manipulations and measuring the effects on fish passage and survival.

Secondly, we recommend that the Council ask the Independent Economic Advisory Board to conduct an analysis of the Umatilla Initiative to address specifically two key questions:
1. Since pumped water is shared "bucket for bucket" between irrigators and fish, what is the appropriate charge to Council's Fish and Wildlife Program of the cost of pumping water from the Columbia River into the Umatilla Basin? (Presently estimated at $1.5 million per year.)
2. Are there more cost-effective measures that could restore water for fish into the Umatilla River; e.g., what might be the relative cost/benefits of purchase of lands and their associated water rights versus the present cost of electricity to pump water from the Columbia River?