See comments under 198343600 and 198710001, and in particular, 199000501, as well as others from this subbasin.

The Umatilla ecosystem and the human intervention within it remains complex, and the ability to comprehend the interactions of habitat work, as proposed, and flow augmentation, power repay, adult and smolt migration, etc. remains confusing. One concludes that it is adult and smolt migration within the Umatilla as the key limiting factor (particularly, in this case, from Birch Creek to the Three Mile Falls Dam site). Nonetheless, habitat husbandry is a requirement, and the response has clarified several areas of the proposal.

There remains the need to develop an adaptive management experiment to evaluate the effectiveness of habitat improvement techniques, ultimately to the smolt yield stage. ISRP has recommended to Council that some assistance to subbasins may be required to standardize and establish this process within the basin, and we remain hopeful that Umatilla projects will form part of that exercise. Success should be measured in terms of increased smolt production in the system. Sponsors should by now be able to defend their work on the basis of similar treatments by others or results of their own. Absent these results there is no scientific basis for continuing the work. They incorrectly reject the idea that smolt production is the best measure of habitat productivity for anadromous fish. They seem to believe that EDT is the final answer to habitat quality and not merely a basis from which to develop a testable hypothesis. There has been no test of such hypotheses and therefore no basis in science to support continuation of these projects.

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.