The responses to the ISRP's questions were reasonably thorough. Although we remain concerned that monitoring may not get the attention it deserves, the project proponents have satisfactorily addressed the majority of our questions. We therefore believe that this project meets scientific criteria, with the following qualifications:

Qualification 1: The Water Transaction Program should complete the development of compliance, implementation, and effectiveness monitoring protocols as soon as possible. Given the lead entity is the National Fish and Wildlife Foundation, the proponents should be able to develop their monitoring program fairly quickly.

Qualification 2: Cost monitoring is needed. Thirty six percent of the budget is to support QLEs. This is a big investment, and CBWTP should systematically evaluate how to keep acquisition and administration costs as low as possible. They could provide some analytical evidence of why this amount is needed to implement the project, because NFWF as the lead entity should be able to assess the cost-effectiveness of the various approaches. This could be summarized in the annual meetings so that each QLE can learn from the experiences of other QLEs. The Consultant’s evaluation report did not address the question of administrative efficiency or cost per acre foot of leased or acquired water under different acquisition strategies. This could include a comparison of the annualized costs for a lease (with the accompanying multiple transaction costs) and outright permanent acquisitions (with the one-time accompanying transaction).

Other comments:

The proponents provided a helpful clarification of the budget request, including a $15M+ cost share that will help lower their request to BPA. The administrative costs still seem a little high, but that may be the result of legal expenses associated with water transactions. Additional clarification is provided in the response to the ISRP's comment about transaction costs being an integral part of the program. The response to the ISRP's question about the cost-effectiveness of individual transactions was illuminating, but it would have been aided by an example how the analysis affected an individual transaction.

The proponents are making some progress toward monitoring. The response states that the flow compliance monitoring protocols have been completed, and development of biological monitoring protocols is planned for FY 2011. Adequate monitoring is essential to ensure that ecological assumptions about the impacts of flow on habitat and population responses are reasonable and sufficient to achieve desired results. The wisdom of limiting the monitoring budget to 5% of total budget should be evaluated regularly to ensure the remaining portion of the budget is invested in the best manner.

Examples of coordination with other restoration programs were given for two streams, as the ISRP requested. The coordination with regional RM&E efforts to achieve implementation and effectiveness monitoring goals was adequately addressed. The ISRP realizes that the 5% monitoring cap is still used, but we remain unsure why project proponents seem unwilling to "up the ante" in situations where the information gained would be worth the effort and expense.

We wish the logic models for priority stream reaches (to be developed by individual QLEs) were further along so we could see how one would be used. The ISRP acknowledges, however, that they have not yet been developed.

The graphs showing trends in water acquisitions through time were helpful. What assumptions are being made about the possibility that temporary acquisitions will be made permanent?

The Big Timber Creek and Teanaway acquisition examples were useful. Additionally, the explanations of how those agreements have become more sophisticated with time help us understand how they address flow-related limiting factors.

The response to the ISRP's question about QA/QC emphasized stream gauging. While this is needed, a little more discussion about quality assurance for the biological monitoring activities would have been useful.

The response clarifies the budget amount as lower than the earlier impression. However the $23.4 M budget is still large, and the $8.4 M for administration of the program is high. It is the large budget share (36%) dedicated to the transactions costs that provide the basis for the ISRP recommendation that these transactions costs associated with various approaches to water transactions be analyzed.

The response does a better job establishing the connection between the CBWTP and other regional programs concerned with improving flows. It also provides detail on the types of connections that are required to be established within each QLE transaction proposal and the process of ranking transaction proposals. It establishes contributions made by staff of QLEs to the subbasin plans.

With regard to evaluating the strengths, weaknesses, and cost effectiveness of various processes and methods employed by the QLEs, the response described a process by which the QLEs share information and learn by doing. It also references and provides a link to a biennial report produced by WestWater Research that analyzes the cost-effectiveness of various flow restoration methods and approaches. However it does not summarize the findings of these two processes. Given that program administration is such a large budget component, the proposal should contain some evaluation of lessons learned about the transactions costs and efficacy of various approaches, e.g., by evaluating the performance of program administration. The table on costs by transaction type is an example of the type of data that would be evaluated.

With regard to monitoring outcomes, the response indicates that in response to the 2007 program evaluation recommendations, compliance effectiveness protocols have been developed, to be followed by the development of biological monitoring protocols in 2011. These protocols are being developed in coordination with Council and other regional agency staff. Given the relatively small proportion (5%) of the CBWTP budget dedicated to monitoring and the limited technical monitoring capacity within QLEs, it is not clear how specifically this monitoring will be implemented.

With regard to the degree of permanence of the present acquisitions and the implications of this time horizon for future expenditures, the response states "The CBWTP funds deals of various lengths, from annual leases to permanent acquisitions. We have found that all of these transactions serve a purpose and make the portfolio of the program stronger." This is another example of an area in which an assertion would be strengthened by evaluation. For example, what purpose does the diversity of transactions serve? And how will portfolio strength be measured?

The response does address the question of future availability of water under existing contracts, but does not really answer the issue raised by the ISRP: "the program seems to face a future of declining amount of water acquired, as some existing agreements expire."

The response states, "While the amount of acre feet secured in stream does decrease through time because of the expiration of temporary deals, the program continues to increase the amount of water that will be protected instream long-term and permanently." So the question is, what is the net effect?

In response to the ISRP comment: "Likely the contribution of the CBWTP varies from subbasin to subbasin, but without knowing how it has impacted rivers during the low flow period it is difficult to judge the program's success. Again, the main difficulty arises when insufficient information is presented to permit an assessment of the impact of the water acquisitions on fish habitat quantity and quality," two specific examples are given. However, this is another area in which ongoing monitoring of the program as a whole would be beneficial in understanding program impact.

The response to the ISRP comment "The proposal asserts that CBWTP results have advanced water transactions as a cost-effective tool for restoring flow to imperiled rivers and streams, but to our knowledge the cost effectiveness of the CBWTP approach has not been fully assessed" does not really address the point, which is the lack of systematic assessment of the cost-effectiveness issue. For example, saying "CBWTP QLEs typically pay at or below market rates when acquiring water rights" is different from documenting this statement and also different from a comparison of CBWTP costs to other BPA and NRCS funded projects.

The bottom line with this response seems to have two pieces: coordination and monitoring. There appear to be many areas with which this program is coordinated with others related to stream flow, and the project proposal just needs to do a more comprehensive job in documenting, summarizing and evaluating these. With regard to monitoring, the project needs to do a better job monitoring and evaluating both cost-effectiveness and biological effectiveness program-wide, not just focus on anecdotal examples. The proponents note examples of the types of information provided in various forms but do not evaluate this information.

The ISRP is impressed with the Water Transaction Program’s goals and objectives but requests a response from the project proponent in order to address some important questions. Because of the focus on various tools of water acquisition the proposal should also provide some evaluation of various processes and methods employed by the QLEs, identifying strengths and weaknesses. It should also address the question of cost-effectiveness of various acquisition approaches rather than simply assert cost-effectiveness for the program as a whole. With a budget of almost $39 million over 4 years, the project is one of the most expensive efforts funded by the Fish and Wildlife Program. To demonstrate that the investments in water rights acquisition are worth it, the proposal should include more details about its record of success. In particular, examples should be presented that demonstrate that increases in fish habitat or various population metrics can be attributable to increased flows resulting from CBWTP acquisitions, and not from other restoration actions taking place in the same watershed. Additionally, more details need to be provided on the potential methods, metrics, and deliverables associated with Objectives 4-6 so that their scientific merits can be assessed. The project description lacks an evaluative component to justify its large expense. The proposal should contain much more information about accomplishments in terms of outcomes and impacts, rather than its present focus on transactions completed and water acquired. It should discuss the degree of permanence of the present acquisitions and the implications of this time horizon for future expenditures. 1. Purpose, Significance to Regional Programs, Technical Background, and Objectives The project has six objectives: 1. improve flow rates through identified stream reaches; 2. improve water volumes; 3. improve available habitat; 4. improve egg-to-smolt survival; 5. increase off-channel habitat; and 6. monitor species diversity and abundance. The significance to regional programs is adequately described. There is reason to believe that entry into water conservation programs has the potential to result in large gains in habitat for salmon and resident fishes (as well as some wildlife) in many subbasins, and voluntary incentive-based programs such as CBWTP appear to have had success so far. The technical background and objectives in the proposal tended to be filled with boilerplate language but without a lot of technical details. Granted, each QLE is using its own approach to monitor the effects of its water acquisitions, but additional details about why certain methods were selected are needed. An example is the use of Instream Flow Incremental Methodology (IFIM) techniques to assess habitat improvements after flow increases. Although IFIM protocols have been in widespread use throughout the west over the last three decades, other methods (including EDT and related habitat models, as well as a variety of channel classification techniques) could be employed to estimate habitat change. Have these been considered in the development of technical approaches to monitoring? It would also be helpful to have more background on need, priorities, water rights transactions and their performance as part of the technical background. The proposal does a good job of describing its significance to regional and local water conservation programs, but there was little discussion of how the CBWTP is linked to other types of restoration at the subbasin scale. Needed are details of how subbasin analyses and knowledge of limiting factors are incorporated into water acquisition priorities. Are the locations of acquired water rights influenced by other restoration actions in the vicinity so there can be improved coordination (and data sharing)? The purpose of the CBWTP is to acquire water rights to enhance instream flow to “ecologically significant” Columbia River Basin tributaries, working through various state agencies and NGOs designated as “qualified local entities.” A map and list of tributaries where transactions have taken place is provided. The CBWTP has been operating since 2003. The proposal should put these transactions within the larger context of Columbia River Basin priority needs. What is described is a process of review and evaluation of transactions proposed by individual QLEs, rather than a prioritized strategic framework for how to address the greatest needs. The program is tied to regional programs involving tributary habitat and flow issues, in particular to RPAs identified in the 2000 and 2008 Biological Opinions. The proposal provides an extensive accounting of programs and plans within the region where in-stream flow is identified as a critical factor, but does this in a general manner rather than tying the CBWTP specifically to these programs. This list establishes the importance of stream flow more than it establishes the significance of the CBWTP to regional programs concerned with improving flows. 2. History: Accomplishments, Results, and Adaptive Management The history of the Water Transaction Program was adequately described. The proponents did a reasonably thorough job of listing the water transactions that have been implemented in the recent past and describing the relationships that have resulted from the 10 local entities (QLEs) working with interested water users as well as regulatory agencies, tribes, and NGOs. Although the overall results are presented in terms of acre feet of water conserved through the program (either permanently or temporarily) through water rights agreements, it was difficult to place these water gains in a larger context. In addition to estimating acre feet of water sequestered through the CBWTP, it would be most helpful to estimate what percentages of the river flow during the irrigation season these figures represented. Likely the contribution of the CBWTP varies from subbasin to subbasin, but without knowing how it has impacted rivers during the low flow period it is difficult to judge the program’s success. Again, the main difficulty arises when insufficient information is presented to permit an assessment of the impact of the water acquisitions on fish habitat quantity and quality (e.g., x% increase in base flow, approximate increases in the area of key habitats, effect of the water acquisitions on in-stream temperatures, etc.). Limited results were presented in the proposal, but we hope there are more examples that could be included. We suspect that delays in implementing effectiveness monitoring – both habitat and biological response – have restricted the amount of available data, but the proposal really needed to include a more thorough summary of results to date. We were pleased to see that the QLEs have adopted the ISRP’s recommendations for prioritizing water transactions (ISRP 2003-1). That was a good example of adaptive management. It would also be useful to know if adoption of the prioritization criteria has resulted in any shifts in QLE approaches to working with landowners. We note that the CBWTP is holding a workshop among the QLEs to discuss monitoring methods and arrive at general monitoring recommendations, and we strongly recommend carefully examining other basinwide aquatic habitat monitoring programs (e.g., CHaMP/ISEMP, AREMP, EMAP) to determine what elements of those programs can contribute to the water acquisition monitoring efforts undertaken by the QLEs. The proposal provides a financial history and a list of cost share partners over time. The description of financial history and performance is adequate. The explanation of factors influencing the timing of deliverables is adequate. A summary of the numbers of transactions and amount of water acquired over the life of the program is presented, along with a good description of coordinated efforts with cost-share partners. One graph shows acre-feet of water acquired during each year of the program. Is the interpretation that the out years of the graph show the time horizon over which these acquisitions will be in effect? If so, the program seems to face a future of declining amount of water acquired, as some existing agreements expire. A graph indicating the total cost of water over the program’s history is presented. It would be useful to see a calculation of the cost per acre foot of water acquired. The accomplishments section also describes implementation of conservation easements, work within the regulatory frameworks of the four states, and programmatic changes. The programmatic changes include the expansion of the application of market-based mechanisms to water conservation. The proposal asserts that CBWTP results have “advanced water transactions as a cost-effective tool for restoring flow to imperiled rivers and streams,” but to our knowledge the cost effectiveness of the CBWTP approach has not been fully assessed. An adequate description is provided of the changes in the program over time to adapt to changing circumstances: mergers of QLEs, QLE prioritization of acquisitions, experimentation with new acquisition tools, implementing related programs, and the development of monitoring protocols in response to recommendations of a 2007 external program review and ISRP reviews that the biological impacts of the acquired water be evaluated. The program has a pretty good history of learning from past experience and adapting approaches on the basis of what has been learned and in response to changing conditions. The proposal describes responses to several ISRP recommendations. In response to a Council recommendation to lower overhead costs of the projects, the CBWTP refers to a conclusion of the 2007 review that observes the nature of individual transactions between rights-holders and a QLE, and states that transactions costs will always be a part of the program. Also part of that review was a Council-sponsored review of the consultant’s report, in which this perspective is challenged somewhat and a recommendation made to systematically assess the QLE actions and processes to learn general properties of successful and unsuccessful processes. Since 2002, the program has completed over 240 water right transactions and noted that they have restored over 819 cfs of flow to tributary streams using various water acquisition methods. It is impossible from the data presented to know how much of the flow improvement occurred at the key low flow time of the year (perhaps flow improvement should be summarized differently). In terms of priority localities for this activity, it was noted that stream flow was mentioned in the subbasin plans or other key documents. But, it also mentioned willing landowners and the presence of other activities in the area play an important part in the decision making process. There seems to be an approval process that would tend to eliminate less important activities. The program was independently evaluated in 2007, with a report indicating that in addition to monitoring compliance and flow, that standards be established for habitat monitoring. 3. Project Relationships, Emerging Limiting Factors, and Tailored Questions for Type of Work (Hatchery, RME, Tagging) It was apparent that the CBWTP targets both resident and anadromous salmonids, depending on location. A little more discussion of the life history stages that would likely benefit from water rights acquisitions would have been helpful (e.g., would the projects be more likely to benefit fall or spring spawners?). Although discussed under a topic above, the issue of using water acquisitions to address perceived limiting factors in areas where other types of restoration actions are simultaneously taking place suggests that close coordination will be beneficial. What is being done to promote the coordination of water acquisitions with other habitat improvement projects? The proposal addresses this question in general, but some specific examples would help. The proposal includes a good description of how climate change will affect limiting flows, with specifics of how these anticipated changes will affect the timing and quantity of water in different parts of the Columbia River Basin. It also summarizes QLE approaches to account for these anticipated changes. 4. Deliverables, Work Elements, Metrics, and Methods More details are needed on the monitoring protocols. The proposal states that the biological effectiveness monitoring methods will be developed by the QLEs, but there should be a statement of the types of methods that project proponents would consider reasonable. Additionally, the QLEs may have to rely on cooperation from ongoing effectiveness monitoring efforts in the area (e.g., the CHaMP/ISEMP project), and how the Water Transactions Program would contribute to the implementation and funding of effectiveness monitoring should be explained in greater detail. Despite having developed protocols for biological monitoring and compliance monitoring in the past year, details of these protocols or how they will be applied to monitoring or data collection are not provided. The descriptions of methods and deliverables for objectives 4-6 were not sufficiently explanatory, and the language for each objective was virtually identical (and sometimes unrelated to the specific objective itself) suggesting that methods for these three objectives had yet to be selected. More details are needed with respect to the potential methods that could be used to achieve Objective 4, Objective 5, and Objective 6, or, if not currently available, how they would be established (we assume the workshop will do this, but a few more details are needed). Although the QLEs will determine the exact procedures to be used, the proposal should present a suite of potential methods from which the QLEs can pick the most appropriate approach and metrics. This proposal, as it is currently worded, contains insufficient detail for scientific review of these three objectives. Flow monitoring will be a key component of assessing the habitat effects of water acquisition, and the proposal is reasonably detailed concerning where flow monitoring would be carried out. It would be helpful, however, for the proposal to describe how QA-QC will be accomplished on the flow determinations. This is important because some of the water acquisitions will comprise a relatively small percentage of the river’s discharge and accurate flow measurements will be needed to verify that flow objectives are achieved. It would also be helpful to describe in more detail where data related to water acquisitions and post-acquisition monitoring would be archived and made publicly available.

The Independent Scientific Review Panel (ISRP) comments to the Columbia Basin Water Transactions Program (CBWTP) proposal fall within the following four major themes: 

• Program: Comments in this theme focused on the CBWTP as a basinwide program in contrast to water transactions as individual projects.
• Data Analysis & Outcomes: Comments in this theme requested more information about outcomes from previous transactions and analysis of results.
• Prioritization:  Comments in this theme sought more information about how the Program’s Qualified Local Entities (QLEs) efforts are prioritized and integrated with basinwide priorities and other efforts.  
• Monitoring: Comments in this theme generally wanted more information about how effectiveness monitoring, particularly biological monitoring, is/will be conducted. 

The CBWTP numbered comments received by the ISRP in chronological order.  We then organized these comments under the four major themes.   Below is the CBWTP response to these comments, organized by major theme.  

Program Comments & Responses:

*3 With a budget of almost $39 million over 4 years, the project is one of the most expensive efforts funded by the Fish and Wildlife Program.  

The National Fish and Wildlife Foundation (NFWF) appreciates the significant investment in the CBWTP made through the Fish and Wildlife Program and concurs that the basin-wide program is one of the more expensive efforts currently funded by the Bonneville Power Administration (BPA).  However, the estimated $39 million transaction funding budget for the next 3-4 years is not what is proposed for funding by BPA through the Fish and Wildlife Program.  Rather, the total 4 year request for BPA funding is for $23.4 million.  Of this total, approximately $15 million is requested for funding water transactions and $8.4 million for associated transaction costs and administration and implementation of the CBWTP.  Cost-share will be sought for the balance of the actual water transaction costs which is estimated at $15.6 million.

*13 The proposal provides an extensive accounting of programs and plans within the region where in-stream flow is identified as a critical factor, but does this in a general manner rather than tying the CBWTP specifically to these programs. This list establishes the importance of stream flow more than it establishes the significance of the CBWTP to regional programs concerned with improving flows.  

The CBWTP was established by BPA and the Northwest Power and Conservation Council (Council) in 2002 in response to provision A.8 of the Council’s 2000 Fish and Wildlife Program and reasonable and prudent alternative (RPA) 151 of the 2000 Federal Columbia River Power System (FCRPS) Biological Opinion.  Since its inception, the CBWTP has worked closely with BPA, the Council, the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS) to make sure that this basinwide program is implemented consistent with the flow improvement objectives of each agency as asserted in subbasin, recovery and other plans.  CBWTP personnel are in regular communication with both BPA and the Council.  Representatives of both NMFS and FWS serve on the CBWTP’s Technical Advisory Committee (TAC) and review all transactions for consistency with the CBWTP’s water transaction criteria (ISRP approved) and their agencies’ respective flow priorities.  In addition, the QLEs must explain in the transaction proposal forms how the project satisfies the relevant subbasin and recovery plans.  In the CBWTP proposal form, QLEs are required to answer the following questions regarding their proposed transactions:

• What does the Subbasin Plan state regarding restoration of instream flows in the watershed and water right transactions as an appropriate flow restoration tool?
• What are the priority habitat limiting factors identified in the plan that will be addressed by the water transaction?
• Is there a NOAA recovery plan and/or water resource planning effort, watershed assessment or comprehensive planning effort in place to help justify the transaction?
• If so, please describe the NOAA recovery plan, assessment(s) and/or effort(s) and what it states regarding restoration of instream flows in the watershed and water right transactions as an appropriate flow restoration tool.
• Have the projected impacts of climate change on stream flow been assessed in this watershed/basin?
• What kind of water resource planning effort, if any, is occurring in the subbasin?
• Are these efforts attempting to address instream flows in any way?

Proposed transactions are scored and ranked by the TAC on a variety of elements, including points given depending on how well the project sponsor establishes the significance of the deal to regional programs concerned with flows.

Further, the flow components of most subbasin and recovery plans were developed with extensive input from the CBWTP’s QLEs.  The QLEs, working with local fish biologists and water managers, are typically leading the establishment of flow targets and priorities in their respective subbasins.  In the case of the recently developed plans for the Bitterroot and Blackfoot subbasins, staff from two QLEs (Clark Fork Coalition and Trout Unlimited-Montana Water Project) were the lead authors of the subbasin plans. 

*21 In response to a Council recommendation to lower overhead costs of the projects, the CBWTP refers to a conclusion of the 2007 review that observes the nature of individual transactions between rights-holders and a QLE, and states that transactions costs will always be a part of the program. Also part of that review was a Council-sponsored review of the consultant’s report, in which this perspective is challenged somewhat and a recommendation made to systematically assess the QLE actions and processes to learn general properties of successful and unsuccessful processes. 

The ISRP references the Council-sponsored review of the 2007 independent evaluation of the CBWTP by Hardner & Gullison Associates, LLC (HGA).  The ISRP specifically points to HGA’s Recommendation 5: Accept transaction costs as a necessary part of instream deals.  The members of the Council-sponsored review committee agreed with the importance of BPA funding transaction costs, stating: “transactions costs are an essential part of water transactions, and we agree that they are a necessary part of instream deals. CBWTP has already reduced project development and implementation costs, and there is pressure for further cost reductions.  We are concerned that this will jeopardize the ability of the QLEs to successfully complete deals and urge BPA and the Council to support project development and implementation costs as an essential component of water transactions.”

The Council-sponsored review committee also recognized the key role of the CBWTP to help QLEs increase the efficiency of their transaction work, asserting in their report that “as a single coordinating entity, the CBWTP offers the potential to reduce transactions costs over time through the development of capacity, the ability to craft flexible arrangements, and the achievement of economies of scale in administration.”

Helping QLEs improve the efficiency of their transaction work and reduce transaction costs is a key focus of the CBWTP and a critical value added of the basin-wide program.  The program provides capacity building support to the QLEs which is primarily geared to improving the work of project managers negotiating water transactions.  Once every 12-18 months, CBWTP consultant Bruce Aylward of Ecosystem Economics conducts a 3-day, multi-disciplinary water transactions class for new project managers.  This class covers a range of issues and topics that must be considered and addressed for successful project management.  Twice annually the CBWTP holds “QLE meetings” where project managers and others receive technical training on contracts, due diligence, river ecology, negotiations, strategic prioritization, water valuation and other aspects of water transaction work.  The late-summer meeting is held outside of Portland in a priority flow-restoration area and includes field sessions where transactions are either constructed or deconstructed by meeting participants to identify the general properties of successful and unsuccessful approaches and processes.  The program has supported an exchange program whereupon one QLE hosts staff from another QLE for a week or two to learn about specific transactions activities and techniques that are of interest to the visitor.  CBWTP staff and consultants are available on a case-by case basis to provide input to project managers on specific deals, draw lessons learned from previously funded transactions and connect project managers from different organizations regarding deal development and implementation. 

Finally, NFWF staff and consultants and the QLEs have worked closely since 2007 with a PhD candidate from the University of Arizona named Dustin Garrick to provide data and input for his dissertation, entitled Explaining institutional diversity in emerging markets for environmental flows: a transaction costs approach to policy evaluation in the Columbia Basin. Garrick earned his doctorate this year and is now a Fulbright scholar in Australia.  The dissertation evaluated the performance of markets for environmental flow in the Columbia Basin by measuring and explaining the transaction costs of environmental water transactions for salmon recovery.  Garrick identified institutional design principles and factors sufficient to improve performance over time and achieve increasing returns to scale.  These principles include a level of water rights reform and basin governance sufficient to support efficient market development and minimize transaction costs. Garrick presented his findings at the last CBWTP QLE Meeting in September 2010.  CBWTP personnel are evaluating his findings for future implementation in order to improve the efficiency of the program and lower transaction costs.

Data Comments & Responses:

*1-2  Because of the focus on various tools of water acquisition the proposal should also provide some evaluation of various processes and methods employed by the QLEs, identifying strengths and weaknesses.  It should also address the question of cost-effectiveness  of various acquisition approaches rather than simply assert cost-effectiveness for the program as a whole.

The 2000 FCRPS biological opinion called for testing various strengths and weaknesses of a transactional approach to flow restoration.  Thus, since program inception a culture of experimentation has prevailed.  The program is constantly "learning by doing" as documented by HGA in their 2007 evaluation of the program.  While the program has increased its emphasis on achieving specific ecological outcomes identified in recovery and subbasin plans, the Program still works closely with the QLEs to assess the strengths and weaknesses of various transactional approaches and methods to restoring flow.  QLEs are asked to describe lessons learned about proposed transactions in the proposal form.  They also provide input about lessons learned about their transactions in an annual progress report submitted to NFWF.  Innovative transactions are profiled in the CBWTP’s annual report.  CBWTP uses QLE meetings to critically assess different transactional approaches and methods.  Completed deals are deconstructed by the transaction sponsor with other QLEs while potential deals are constructed with input from other QLEs.  Thus, CBWTP allows QLEs to learn from each other by doing.

The CBWTP also works with WestWater Research to analyze the cost-effectiveness of different flow restoration approaches and methods.  WestWater produces a biennial report every other year documenting innovation and cost-effectiveness of CBWTP deals.  These reports can be found at www.cbwtp.org.  Consideration of cost-effectiveness is further described below.

*4 To demonstrate that the investments in water rights acquisition are worth it, the proposal should include more details about its record of success. In particular, examples should be presented that demonstrate that increases in fish habitat or various population metrics can be attributable to increased flows resulting from CBWTP acquisitions, and not from other restoration actions taking place in the same watershed. 

The CBWTP is a broad, basin-wide program whose primary objective is to support implementation of water transactions by QLEs.  As mentioned above, the program was established in 2001 in response to the Council’s 2000 Fish and Wildlife Program and to the 2000 FCRPS biological opinion. RPA 151 of the biological opinion required BPA (in coordination with NOAA-Fisheries) to experiment with innovative ways to increase tributary flows through willing buyer-willing seller transactions.  During development of the CBWTP in 2001, NOAA staff consistently emphasized experimentation with transactional methods over achievement of specific biological outcomes under RPA 151.  Thus, for the CBWTP’s first five years of implementation, the program was focused primarily on funding, supporting and evaluating innovative transactions and not on monitoring achievement of specific ecological objectives.  In addition, flow was being restored on streams where inadequate streamflow was identified as a major limiting factor, thus justifying flow restoration activities in those locations.

The HGA evaluation of the CBWTP in late 2007 recommended increased focus on demonstration of ecological results of flow restoration projects.  In particular, HGA recommended that the CBWTP “augment existing performance metrics to include measures of progress towards achieving biologically-based flow targets, and overall habitat restoration” and “develop guidelines and standards for habitat monitoring.”

In response, the CBWTP formed a monitoring subcommittee to develop appropriate and realistic monitoring protocols, starting with compliance monitoring protocols to demonstrate that acquired flow is actually being left instream consistent with the terms of the water right acquisition agreement.  The CBWTP has finalized its flow compliance monitoring protocols and is now focused on developing biological monitoring protocols in FY 2011.  These protocols will contain clearly defined success criteria for determining whether the relevant project objectives are met for a given transaction.  Consistent with the recommendation of the Council’s evaluation committee that reviewed HGA’s report, CBWTP is developing these protocols in coordination with Council staff and other biological experts in the basin.  Under these protocols, project objectives (and relevant success criteria) will be set by the QLEs for each priority stream reach under a developed logic model.  The QLEs are currently developing logic models for their priority stream reaches with technical support from the CBWTP.

These steps are being taken even though the CBWTP is an implementation program rather than aresearch, monitoring and evaluation project.  (CBWTP is being reviewed by the ISRP under the RM&E solicitation because of its unique basin-wide structure not because it is a monitoring project.)  In fact, the CBWTP is limiting its monitoring activities to 5% of its total budget to maximize resources invested in implementation activities.  Further, the QLEs have limited, if any, technical monitoring capacity on staff. One biologist with the Idaho Department of Fish and Game and another with the Washington Department of Fish and Wildlife (WDFW) conduct limited effectiveness monitoring of key transactions in their respective states.  Project staff at several of the nonprofit QLEs conduct basic flow monitoring and limited habitat and population monitoring.  However, such activity is infrequent and the limited data that is produced only allows for anecdotal evidence of ecological outcomes. Thus, the monitoring protocols currently under development will require that existing QLEs partner with federal, state and tribal biologists to ensure that the ecological impact of flow on habitat and population responses are adequately measured and reported.  This data will allow the CBWTP to more consistently demonstrate that increases in fish habitat or population can be attributable to increased flows resulting from funded acquisitions.

*17 Is the interpretation that the out years of the graph show the time horizon over which these acquisitions will be in effect?  If so, the program seems to face a future of declining amount of water acquired, as some existing agreements expire. (see answer for *7)  And

*7 It should discuss the degree of permanence of the present acquisitions and the implications of this time horizon for future expenditures.

The CBWTP funds deals of various lengths, from annual leases to permanent acquisitions. We have found that all of these transactions serve a purpose and make the portfolio of the program stronger.  HGA’s 2007 evaluation found that, “the volume of water transacted each year has increased, however the majority of transactions are temporary.” In FY 2010 the program secured the most flow instream since inception and also supported and funded the most permanent acquisitions (13), to date, per fiscal year.  Each year CBWTP has increased the number of permanent transactions funded. Because the trends seen in the HGA evaluation have continued and increased each year we hold their previous conclusions to still be relevant and find that, “there is no reason at present to believe this erosion will occur as long as CBWTP continues to support QLEs.”

The ISRP’s review of HGA’s evaluation also supported these trends. The ISRP review found, “that the full range of transactions types should be supported by the CBWTP for the greater operational flexibility they provide. The need for flexibility is further enhanced by the uncertain impacts of climate change and human population growth.”

 

The above graph shows the amount of water in acre-feet secured instream each fiscal year. The colors differentiate the fiscal year that the water was funded, the darker the color the earlier the year of funding. One can use this same representation to illustrate water secured through future fiscal years and into perpetuity.  The graph below shows future water restoration. While the amount of acre feet secured in stream does decrease through time because of the expiration of temporary deals, the program continues to increase the amount of water that will be protected instream long-term and permanently. 

 

*14 In addition to estimating acre feet of water sequestered through the CBWTP, it would be most helpful to estimate what percentages of the river flow during the irrigation season these figures represented. Likely the contribution of the CBWTP varies from subbasin to subbasin, but without knowing how it has impacted rivers during the low flow period it is difficult to judge the program’s success. Again, the main difficulty arises when insufficient information is presented to permit an assessment of the impact of the water acquisitions on fish habitat quantity and quality (e.g., x% increase in base flow, approximate increases in the area of key habitats, effect of the water acquisitions on in-stream temperatures, etc.). 

The CBWTP proposal form inquires about the acquired flow as a percentage of established flow targets, both in isolation and in combination with previously acquired water. The following is the response to this question from a proposal to secure 4.5 cubic feet per second (cfs) in the state of Idaho.

 

The  long term transaction described above was completed by the Idaho Department of Water Resources (IDWR) on Big Timber Creek in the Lemhi River Basin and was funded this past fiscal year (2010). The creek provides high quality steelhead and Chinook salmon habitat in the upper reaches, but is seasonally dewatered by irrigation diversions. The senior-most water rights divert water in the lower 2 miles of the creek, leaving a dry channel for most of the irrigation season (March-November). The established flow target on the creek is 6 cfs and IDWR is working towards meeting that target by securing 4.5 cfs under this transaction. Big Timber Creek is one of 17 streams in the Lemhi Basin that has been prioritized for tributary/mainstem reconnection under the draft Lemhi Section 6 Conservation Plan. Big Timber Creek is the highest ranked tributary in the plan due to the size of the watershed and the high quality habitat upstream. Question 16, seen above, is asked of every proposed transaction and provides the QLEs with an opportunity to demonstrate how the acquired flow impacts flow, habitat and populations.

Another example of a QLE seeking to achieve an established flow target is the Washington Water Trust’s (WWT) Teanaway River acquisitions. WWT is using a systematic approach to achieving the flow target by completing many smaller transactions to cumulatively secure a larger quantity of flow.

 

WWT has completed many transactions on the Teanaway River since establishment of the CBWTP that cumulatively represent 50% of the 15 cfs target that has been established by WDFW. Individually the smaller transactions don’t have much of an impact. However, as part of a larger portfolio of transactions the restored flow has had a substantial impact on the stream. WWT has more transactions pending with the program for future implementation on this river. 

*18 A graph indicating the total cost of water over the program’s history is presented. It would be useful to see a calculation of the cost per acre foot of water acquired. 

A summary of the costs per acre foot for CBWTP recommended transactions is shown below for leases (temporary agreements which can range in term from one year to 50 years), partial season leases (where the QLE leases only a portion of the water right, typically in the latter part of the season) and permanent acquisitions. Additionally, many water rights have been donated to instream flows through the CBWTP, which are not included below.

Partial season leases allow landowners to leave their water right instream for part of the growing season when that flow can be most beneficial to the  life stages of present salmonids and resident fish.  Since fish often most need restored flows during the same critical time as landowners, the hottest and driest part of the year, compensation and prices end up being higher for these transactions.  When comparing the cost per unit for lease agreements and permanent acquisitions, it is important to note that the costs per acre foot for leases are provided above are annualized whereas the acquisition costs are not.  However, extrapolating the lease price over even a 50 year period, acquisitions tend to have a lower cost than leasing.  However, the impact to and commitment by the landowner when permanently forgoing their water is a challenging choice for many irrigators.  While the CBWTP supports QLEs to develop permanent acquisitions, the Program recognizes the social and developmental benefits of lease agreements and continues to fund those where they provide benefit. 

*19 The proposal asserts that CBWTP results have “advanced water transactions as a cost-effective tool for restoring flow to imperiled rivers and streams,” but to our knowledge the cost effectiveness of the CBWTP approach has not been fully assessed.   

CBWTP QLEs typically pay at or below market rates when acquiring water rights.  In contrast, the costs associated with conserved water projects funded by BPA and others are based on the costs of installing the necessary equipment, which can be both expensive and time consuming.  A review of conservation projects funded through BPA's Fish and Wildlife Program illustrates that conserved water is typically more expensive on a per/AF basis than purchasing consumptively used water from a willing seller.  For example, a proposed irrigation efficiency project on Fifteenmile Creek cost $1,269/AF of saved water, and a proposed project on Wychus Creek cost $2,356/AF of saved water.  In contrast, the cost for permanent water acquisitions in the CBWTP has averaged $585/AF.  While there are other societal benefits of keeping land in production (and many CBWTP permanent acquisitions allow production to continue), CBWTP acquisitions are more cost-effective than other permanent flow-restoration approaches funded by BPA, NRCS and other funders.  

Prioritization Comments & Responses:

*9 It would also be helpful to have more background on need, priorities, water rights transactions and their performance as part of the technical background. 

The QLEs prioritize stream reaches for flow restoration and specific water rights for acquisition consistent with recovery, subbasin and other plans.  The priority stream reaches are verified by local federal, state and/or tribal biologists.  The priority water rights are verified by the state water resources department.  Given that the priority streams are limited from inadequate streamflow resulting from existing water right diversions and are over-appropriated (more rights to divert water than natural flow), water rights transactions are the only voluntary method for restoring instream flow.  The performance (impact) of water rights transactions is currently monitored on a case-by-case basis but will be monitored more comprehensively upon implementation of the effectiveness monitoring protocols currently under development by the CBWTP.

*10 Needed are details of how subbasin analyses and knowledge of limiting factors are incorporated into water acquisition priorities.  And 

*11 Are the locations of acquired water rights influenced by other restoration actions in the vicinity so there can be improved coordination (and data sharing)?  And  

*12 The proposal should put these transactions within the larger context of Columbia River Basin priority needs. What is described is a process of review and evaluation of transactions proposed by individual QLEs, rather than a prioritized strategic framework for how to address the greatest needs.  And

*22 There seems to be an approval process that would tend to eliminate less important activities.

The CBWTP uses criteria approved by the ISRP as part of its evaluation of proposals for funding transactions submitted by the QLEs.  Each transaction funded must demonstrate that it meets these criteria.  Each project recommended for funding by the Program must support certain biological components including that the project must provide benefits to either an Endangered Species Act (ESA) listed ESU, an ESA listed resident species, or at risk species of concern.  Nearly all transactions funded provide benefits to an ESA listed species.  Projects that benefit targeted populations under the FCRPS biological opinion are given priority.  Each acquisition funded by the Program must also satisfy certain hydrologic components including that the acquisition will secure water at a location where low flows are a limiting factor to fish survival, productivity or distribution and that the acquisition will secure water at a time of year when those flows are needed to address an identified limiting factor.  Proposals that are linked to additional habitat restoration activities that address other limiting factors, and are supported by an existing ESA recovery plan, watershed assessment or subbasin plan that identifies water transactions as an appropriate response to addressing factors limiting a specific life history stage(s) are given priority.  As the competition for acquisition funds increases, QLEs increasingly only bring forth projects that meet these additional funding priorities. 

The CBWTP holds semiannual training sessions with the QLEs to provide training on various aspects of the program, including current restoration priorities.  In addition, CBWTP staff makes annual site visits to each of the QLEs to talk about each entities’ priorities for the upcoming funding cycle.  While the CBWTP does not dictate transaction priorities, CBWTP does provide feedback during the development stages, encouraging QLEs toward those transactions that meet the priorities.  When evaluating which transactions to pursue, QLE pursue those more likely to rank higher on the evaluation matrix based on the CBWTP water transaction criteria.

*16 It would also be useful to know if adoption of the prioritization criteria has resulted in any shifts in QLE approaches to working with landowners. 

 It is hard to identify whether adoption of the prioritization criteria or the capacity building efforts of the Program have effected a shift in QLE approaches, but the types, quality and sophistication of the transactions has evolved over the course of the Program.  The early years of the CBWTP saw relatively “simplistic” transactions, largely short term and annual leases of water rights from landowners.  These transactions were often opportunistic in location.  As the QLEs have set strategic priorities in various tributaries and have reached out to partners in habitat projects, the QLEs have increasingly targeted landowners for acquisitions.  This has led to a greater level of sophistication in the types and complexity of acquisitions, including developing tools like split season leases (Standard Creek transaction in the John Day), diversion reduction agreements where landowners stop irrigating to meet target flows (Pole Creek in Idaho); and rotation agreements (Lostine River transaction in the Grande Ronde).  As acquisition targets become more strategic, the need to balance instream and out of stream water uses leads to more sophisticated agreements.

*23 A little more discussion of the life history stages that would likely benefit from water rights acquisitions would have been helpful (e.g., would the projects be more likely to benefit fall or spring spawners?).  

With 276 transactions funded to date, acquisitions have provided benefit to all life stages where flows are identified as a limiting factor.  Below is an example of a project proposal checklist. In question 13 of each transaction proposal the QLE is asked for the period of use that the instream right(s) will be in effect each year. And they are also asked when is that flow most ecologically significant during the period. Below is an example for a transaction proposal on the Lostine River by The Freshwater Trust. The QLE notes that the flow will affect adult Chinook salmon as they are migrating and spawning.

 

Further, in the biological section of the proposal form, the QLEs are asked to list the impacted species, their ESA listing and the life stages affected through the reach. The QLEs also provide information in this section about the general background of the species affected and their history and prevalence in the reach.

 

*24 What is being done to promote the coordination of water acquisitions with other habitat improvement projects? The proposal addresses this question in general, but some specific examples would help. 

The CBWTP encourages QLEs to coordinate water acquisitions with other habitat improvement projects in several ways.  First, the CBWTP encourages QLEs to develop strategic logic models in each of the tributaries where the QLEs are working.  Logic models encourage QLEs to identify the anticipated outcomes of water transactions beyond just the restored flow, and to integrate broader habitat restoration goals and partnerships.  Second, integration with other habitat improvement projects is an element of the ranking formula, which encourages QLEs to think strategically in order to rank higher in funding priorities.  Finally, as water transactions have evolved, so have the entities doing the work.  Most of the transactional QLEs that started with flow restoration specific missions have collaborated or merged with organizations with broader habitat restoration missions to provide a wider base of expertise in their project implementation. Examples of this approach can be seen on Whychus Creek in the Deschutes (Oregon) and Rock Creek in the Blackfoot (Montana).

On Whychus Creek in the Deschutes Basin, the Deschutes River Conservancy partnered with the Deschutes Basin Land Trust to enhance and preserve Camp Polk Meadow and a critical stretch of the creek that flows through the meadow. This preserve is a 145 acre meadow that contains approximately 1.4 miles of Whychus Creek with wetlands, meadows, aspen groves and ponderosa pine stands. It is home to a variety of plant and wildlife species and is one of Central Oregon’s key birding spots. This is an important project, and key partnership, because of the significant portion of Whychus Creek it protects. Historically salmon and steelhead made their way to the streams of the Upper Deschutes basin to spawn and then rear. With the construction of dams on the lower Deschutes in the 1960's, fish passage to the upper basin was blocked. Today the relicensing of these dams has provided a once in a lifetime opportunity to restore native fish to their original range. The stretch of Whychus Creek that runs through Camp Polk Meadow was historically the highest quality spawning habitat for steelhead on Whychus Creek and is once again providing habitat. 

In Montana, Rock Creek provides another example of the importance of partnering with restoration activities to create a successful transaction. Where channel and floodplain impairments are severe, it can be important to work on those impairments prior to initiating a water rights lease or other flow agreement in order to get the most effect out of the instream flow strategy. On Rock Creek, Trout Unlimited-Montana Water Project’s flow strategy has been quite successful at improving flows within the protected reach, but because the restoration of riparian woody vegetation (shade) is a slower process, temperature is still an issue at the height of summer. The QLE is working with the local the revegetation effort as the restoration matures to ensure the efforts progress as expected.

Monitoring Comments & Responses:

*5 Additionally, more details need to be provided on the potential methods, metrics, and deliverables associated with Objectives 4-6 so that their scientific merits can be assessed.

More information regarding ecological Objectives 4-6 described in the proposal has been provided by Washington Department of Fish and Wildlife (WDFW) staff below.

OBJ-4. Improve egg to smolt survival ratio

Description: Measured by redd counts to estimate egg production and juvenile screw traps to monitor number, size, and timing of out-migrating fish.  Screw traps also provide an opportunity to place pit tags into wild salmonids, which can then be used to assess their migration out of the Columbia River System (if arrays are present) and subsequent return to spawning grounds.

Individual water managers, instream flow biologists, and the QLEs rely on the information from ongoing studies to measure instream flow benefits for the egg to smolt survival ratio.  The Columbia River subbasins and drainages with ESA listed stocks vary in geographic size, which dictates the ability and feasibility to measure egg to smolt survival.  Basins that share co-management with tribes are typically the focal basins for the egg to smolt survival studies since the tribes fund the studies.  Otherwise and in all the other basins, funding resources are extremely limited for such studies.  Examples where survival studies (i.e., co-management efforts) are deployed include the Walla Walla, the Wenatchee, and the Okanogan basins.  Instream flow contributions to improvements in egg to smolt survival are compared to long-term trends in adult returns, redd counts, average fecundity (determined from hatchery programs) and smolt emigration counts.  Strong correlations become valid and appear as a trend over timeframes that very few studies take into account.  Smaller drainages that suffer the worst flow conditions, such as the Walla Walla River, may provide measurable benefits sooner than the larger basins.

 Collection of screw trap data where it occurs would be reviewed for increases in smolt production with higher instream flows and correlated with water augmentation to determine if acquisition projects are beneficial to the increased flow and subsequent smolt outmigration.  This information would be documented using excel spreadsheets and graphs to determine trends over time in increased flow versus numbers of salmonid smolt outmigration.  Possible benefits to smolt production could then be determined, especially in low water years.

 Dewatering of redds is of particular interest in low-water years and the monitoring of these redds with additional water from water acquisitions could show substantial benefit.  Salmonid redd information would be collected either through field observations or collected from entities that have the data.  Flows and wetted widths would then be measured to determine when, where, or if the redds would be dewatered.  This information would be kept in a database to use for determination of dewatering and if additional water would or does keep redds wet during the incubation period(s).

 OBJ-5. Increased off-channel habitat (OCH)

Description: Increased flow can water-up OCHs where juvenile fish can find refuge.  OCHs provide food supply, velocity refuge, cover, and cooler water temperatures with cover and ground water influence.  They can easily be measured at various flows to determine if water augmentation projects are beneficial to the rearing habitat.  Determining and documenting of OCHs within specific reaches where water augmentation will occur would be done via GPS mapping.  Field measurements of calculated flows and water temperatures for both the mainstem and chosen OCHs over time with an ascending or descending hydrograph would determine points of watering and dewatering.   Percentage of flow and time can then be assessed from acquired water to determine potential benefits to the OCHs.  These side channels can be graphed to depict flow in the mainstem vs OCH flow and evaluation of the water acquisition amount and how it would affect the OCH.  Where wetted useable area (WUA)curves occur can also give indirect habitat area with OCHs, but a field review and numerous flow measurements will indicate OCHs and how much water is needed for inundation.  Fish presence and abundance can also be measured and documented using excel spreadsheets and graphical analysis with the OCHs to show increased populations at various flows. 

Fish sampling methodology should be as non-invasive as possible.  Regarding juveniles, snorkeling is preferred, but electrofishing is often easier to measure.  Snorkeling can also supplement electrofishing techniques.  Electrofishing during the summer low flow period (July, August, and September) is recommended in order to detect cohort strength.  Regarding adults, both snorkeling and redd counts are effective at enumerating how many adults have returned to spawn.  Similar techniques can be used for detecting rainbow trout and cutthroat trout spawning activities. 

This objective could be managed with lower amount of effort than other suggested monitoring techniques.  For each reach of sampling, it would require one to two field staff sampling approximately 10-12 days.   Data entry, compilation, statistical analysis, and graphing would be another 10-12 office days.  A written report and evaluation for each reach studied and a report including all reaches would then be produced.

 OBJ-6. Species Diversity and Abundance

Description: Increased instream flow can enhance fish density, relative abundance, and species richness and diversity, which can be estimated via the following sampling techniques: screw-trap evaluation and enumeration, electrofishing and seine-net sampling via depletion (two-pass) sampling, or snorkeling observations.  One to two other nearby streams are needed as controls, to account for variability in other environmental (biophysical) variables that can affect fish parameters independently of flow restoration, notably oceanic conditions and harvesting rates. To reduce confounding (interpretive) problems of these other environmental variables, examination of all fish species makes sense, including forage (nongame-resident) species that aren’t directly subject to marine conditions and harvesting. Therefore, this type of sampling requires extensive time and effort, including partnerships with local organizations (notably Regional Fish Enhancement Groups) to help undertake the field work.  Data entry, compilation, review, and statistical analysis will be performed.  Deliverables will include graphical charts, interim and scientific reports with potential for publication.

*6  The proposal should contain much more information about accomplishments in terms of outcomes and impacts, rather than its present focus on transactions completed and water acquired.

 As mentioned in response to comment #4 above, the CBWTP is an implementation program, not an RM&E project, and has limited monitoring expenditures to 5% of its total budget.  Monitoring activities that have been funded to date have been implemented by the program’s QLEs related to specific transactions funded under the program.  The CBWTP provided examples of such effectiveness monitoring in its initial solicitation response and has provided additional examples in this response to the ISRP’s comments.  However, such effectiveness monitoring has been fairly limited to date.  We have established a monitoring committee to work with the Council and others to develop effectiveness monitoring protocols to more thoroughly measure and document biological outcomes of transactions consistent with stated project objectives.  Specific project objectives will be derived from logic models developed by QLEs for priority stream reaches.  The CBWTP provides technical support to the QLEs in developing logic models through NFWF’s evaluation officer.  Given the limited resources available for monitoring under the program, QLEs will have to partner with federal, state and tribal biologists to document such ecological outcomes and impacts.  Greatest attention will likely be given to long-term and permanent transactions where more time is available to observe and document change.

 *8 Granted, each QLE is using its own approach to monitor the effects of its water acquisitions, but additional details about why certain methods were selected are needed.

 In September, a broad qualitative survey of QLEs was undertaken to identify the unique driving factors that influence QLE biological monitoring activities in each state. The survey was intended as a stocktaking exercise to establish a foundational understanding of the key variations in biological monitoring activities among the four states. The primary monitoring personnel  of each QLE provided general information on the full breadth of biological monitoring activities and more in-depth descriptions about data collection and analysis for at least one project.

The survey revealed that biological monitoring activities vary among states due to a number of factors, but can summarized as a balance between: a) the amount of time and funding necessary to implement monitoring activities and b) the degree to which the resulting data contributes to both reporting requirements and an understanding of changing ecological conditions. Part of this balance is influenced by state agencies, either through partnerships or reporting requirements. For example, in Washington, QLEs work in close collaboration with biologists from the WDFW and the Department of Ecology (Ecology). WDFW and Ecology biological monitoring efforts are multi-faceted and include research components that endeavor to establish multiple levels of ecological understanding, from time series data that tracks changes in fish populations, flow, and temperature to establishing linkages between habitat conditions and management actions. These partnerships are significant for placing flow transactions within the broader context of ecological research. In Montana, the Department of Natural Resources and Conservation (DNRC) has well established and rigorous reporting requirements for instream flow rights. These requirements add a state-specific layer of reporting requirements to Montana transactions and are a primary driving factor in determining the level of detail and data analysis associated with flow monitoring activities. In Idaho, biological monitoring activities are both determined and implemented by state agencies. The IDWRand Idaho Fish and Game work in close collaboration to monitor flow, fish habitat, and fish populations. In several areas, they are striving to determine the ecological effectiveness of flow restoration activities by tracking time series data as compared to baseline conditions. QLEs in Oregon work closely with a wide variety of partners, including tribes, watershed organizations, and locally based conservation groups. Biological monitoring activities reflect a range of stream restoration actions, including flow transactions. Monitoring data is analyzed within the broader context of stream health and function and parameters include flow, temperature, macroinvertebrate populations, fish populations, and fish habitat, among others.

Overall, biological monitoring activities vary widely across states in terms of parameters measured, analytical methods, state reporting requirements, and partnerships (Table 1). Understanding the driving factors for these differences is essential to identifying a basin-wide biological monitoring program that evaluates flow restoration within an integrated ecological context.

Table 1. Qualitative Survey of Monitoring Activities by QLEs and partners^a

Monitoring Parameters	Idaho		Montana		Oregon		Washington
	QLEs	Partners	QLEs	Partners	QLEs	Partners	QLEs	Partners
Fish Habitatb	x	x	x	x		x		x
Fish Surveysc		x		x		x		x
Flowd	x	x	x	x	x	x	x	x
Macroinvertebrates				x		x
Temperature	x	x		x	x	x		x
Notes
a This table summarizes information from qualitative conversations with QLEs in September 2010. It is not based on comprehensive data collection or analysis and therefore reflects general trends for the majority of the program rather than specific activities.
b Monitoring techniques for fish habitat include: HabRate model analysis, critical riffle measurements, substrate pebble counts, wetted width, bank flow width, and bank stability.
c Fish monitoring techniques include: snorkeling, redd, juvenile, and spawning adult surveys, electroshocking, telemetry, and pit tagging.
d Monitoring techniques utilized for measuring flow including: USGS gages, manual. measurements, pressure transducers, Marsh McBirney devices

*15 We suspect that delays in implementing effectiveness monitoring – both habitat and biological response – have restricted the amount of available data, but the proposal really needed to include a more thorough summary of results to date.

Development of effectiveness monitoring protocols has not been delayed.  Rather than CBWTP has been systematically responding to HGAs recommendations within the limits of its monitoring budget and given its primary focus on implementation.  The CBWTP’s first priority was to develop compliance monitoring protocols. These compliance protocols were implemented starting in 2009 and are being refined based on input from the QLEs.  The next priority for the CBWTP is to develop effectiveness monitoring protocols.  As described above, these protocols are currently under development. This work may be enhanced by coordination with regional action effectiveness research of tributary habitat actions.  It is anticipated that a consultant or staff person will be hired by CBWTP to coordinate effectiveness monitoring implemented by the QLEs and their partners.

*26 Additionally, the QLEs may have to rely on cooperation from ongoing effectiveness monitoring efforts in the area (e.g., the CHaMP/ISEMP project), and how the Water Transactions Program would contribute to the implementation and funding of effectiveness monitoring should be explained in greater detail.

The current monitoring budget is limited to 5% of the total CBWTP budget. Funds must be used as effectively as possible to meet compliance, flow, and effectiveness monitoring requirements. QLEs rely heavily on partnerships to help gather, organize, and synthesize data. Collaborations are essential to ensuring that flow activities are analyzed within the broader context of research on fish habitat, water quality, and stream health. Effectiveness monitoring requires a breadth and depth of monitoring that is outside the mission and budget of most of the QLEs, so identifying specific projects to focus on and well-defined indicators to measure may be options that fit within the monitoring budget and still produce meaningful biological information.

*25 The proposal states that the biological effectiveness monitoring methods will be developed by the QLEs, but there should be a statement of the types of methods that project proponents would consider reasonable.  And

*27 More details are needed with respect to the potential methods that could be used to achieve Objective 4, Objective 5, and Objective 6, or, if not currently available, how they would be established (we assume the workshop will do this, but a few more details are needed).(similar to 25, see response to 5 above) And

*28 Although the QLEs will determine the exact procedures to be used, the proposal should present a suite of potential methods from which the QLEs can pick the most appropriate approach and metrics. (similar to 25)

Biological monitoring activities undertaken by QLEs currently fall primarily into two categories of monitoring:

- Status and Trend Monitoring which documents changes in conditions, stressors, or responses over time, without necessarily determining causes of observed results (IMST 2007); and

- Project Scale Effectiveness Monitoring which measures environmental parameters to determine if activities were effective in creating a desired change in habitat conditions (NPCC 2010).

Based on the general survey of monitoring activities across the QLEs (Table 1), flow is generally the most frequently monitored parameter. This is reasonable given the goal of the CBWTP to support water transactions that improve flows. Data sets of standardized flow measurements can offer a time series perspective of changes from the reach scale up to the basin and watershed levels. Temperature is also a frequently monitored single parameter and under certain conditions can offer a time series data set that could be considered in tandem with flow data. Both of these parameters could be used under a status and trends monitoring program. Project scale effectiveness monitoring is considerably more complex and resource intensive and only a few projects currently have monitoring activities that could be integrated into such an analysis. Table 2 highlights one project from each state that could produce information for either status and trend monitoring or project scale effectiveness monitoring.

Table 2. Example of Select Monitoring Results 

State	Project	Monitoring Technique	Result	Category of Monitoring
Idaho	Upper Big Springs-Patterson Creek	Redd Counts	Show change in Salmon Redd Counts: Sept 30, 2008 - 2 Redds Sept 24, 2009 - 69 Redds	Status and Trend
Washington	Teanaway River	Spawning Adult Counts	Show change in Spring Chinook 1997 - 0 Spring Chinook 2003 - 110 Spring Chinook	Status and Trend
Oregon	Whychus Creek	Flow and Temperature	Monitor and document relationship between flow and temperature	Project Scale Effectiveness
Montana	Rock Creek	Baseline flow, temperature, fish populations, fish habitat, and water quality	Establish baseline data to implement an integrated flow and habitat restoration surveys	Project Scale Effectiveness

 In discussions with QLEs before and during the fall 2010 QLE meeting, two potential interrelated options emerged that may offer a future direction for biological monitoring.

Option 1 would create a tiered monitoring approach across projects and basins. A range of specific conditions would define monitoring tiers and determine the degree, type, and frequency of monitoring activities within each QLE. A small handful of primary tier projects would be selected to focus on in-depth through monitoring, data collection, and data synthesis. These projects would be representative of a broad spectrum of conditions in the basin, provide in-depth case studies of the influence of flow transactions on fish habitat and ecological conditions, and be grounded in a strong network of partnerships. Secondary tier projects would be selected according to specific conditions (e.g. the type of transaction or degree of partner involvement), and tracked through less rigorous monitoring activities. Tertiary tier projects would be tracked to ensure compliance, but would provide proportionally less ecological monitoring data. This tiered approach would allow for a deeper understanding of the connections and linkages between flow transactions and changing ecological conditions in representative project locations.

Option 2 could utilize standardized ecological indicators across tiers to show change at multiple scales. The indicators could be chosen to reflect specific ecosystem attributes or management goals and would vary based on monitoring parameters, scientific rigor, and data analysis (Figure 1). Depending upon the tier (as described above), indicators could offer a snapshot of changes within a specific reach (e.g. miles of useable fish habitat along a tributary) or a snapshot of macro changes across the basin (e.g. number of streams restored from de-watered conditions). In addition to linking monitoring metrics and data with management goals, indicators could also provide information that is relevant to ecological research or public communications.

Both of these options would provide meaningful ecological data from the reach to the basin scale and allow for an in-depth understanding of the influence of flow restoration on habitat conditions through representative projects. A tiered monitoring program may also offer flexibility to adapt to partnerships, budget limitations, reporting requirements, and policy frameworks within each state and build from the foundation of monitoring activities that currently exist.

*29 It would be helpful, however, for the proposal to describe how QA-QC will be accomplished on the flow determinations.

QLEs and their partners currently employ a variety of techniques to monitor flow restored through acquisitions, including fixed gages and manual measurements using pressure transducers and other devices. QLEs have been reporting on their monitoring activities to Ecosystem Economics as part of the CBWTP’s development of effectiveness monitoring protocols.  When completed, these protocols will prescribe appropriate flow measurement techniques, depending on the quantity of flow restored relative to base flow and the flow target, the term of the transaction and other important factors.  CBWTP has observed that flow monitoring by QLEs is currently more intensive on streams where long-term or permanent transactions have been completed that restore more than a de minimis amount of flow.  For example, fixed gauging stations with constant data transmission through telemetry have been installed on a number of streams in Idaho where significant amount of water has been restored permanently or for a long-term.  The QLEs tend to take periodic measurements and calibrate gauges on streams where little flow has been acquired or flow has been acquired on a temporary basis.  Nonetheless, this data provides an important baseline for future acquisitions and monitoring efforts.   

*30  It would also be helpful to describe in more detail where data related to water acquisitions and post-acquisition monitoring would be archived and made publicly available.

QLEs propose transactions through an online proposal form that inputs all submitted information directly into the CBWTP database. The CBWTP database can be queried by a visitor to www.cbwtp.org to produce a report on one or more transactions.  Online users can customize their search to produce data of interest.  QLEs submit any post-acquisition monitoring reports to the CBWTP on an annual basis.  CBWTP maintains these reports and can make them publicly available upon request.  CBWTP is working with BPA and Council staff to integrate future CBWTP monitoring reports with the Monitoring, Evaluation, Research and Reporting (MERR) program.