While the restoration actions proposed in the project description seem reasonable, the proposal (together with the response to the ISRP's specific questions) does not provide enough detail for us to conclude that the work is scientifically grounded and will be guided by feedback from habitat monitoring and fish population assessments.

The proposal does not clearly establish goals for physical habitat improvement, that anticipated habitat restoration work will be sufficient to achieve required habitat improvement, or that the habitat improvement will lead to improvement in steelhead abundance and productivity. The ultimate numeric goal improving steelhead abundance appears to be only partially decided. The response indicates that the recovery goal in the NRCS Watershed Plan is 1545 steelhead, but presumably this number refers not just to Omak Creek but to an aggregate of streams, as elsewhere in the response, habitat within Omak Creek is estimated to be sufficient for 90 spawners in currently accessible habitat and for 90 more spawners in habitat further upstream that would be made accessible by the project. Thus, the significance of Omak Creek to the recovery of this steelhead ESU remains unclear.

In order to provide sufficient evidence of scientific justification for the work, the ISRP asked the sponsors for more information about the accompanying monitoring program. We realize the CCT asserts that environmental monitoring in Omak Creek will be handled by partnering organizations, but we asked for more information about how and where the monitoring would be conducted, as well as how environmental data would be analyzed, reported (and by whom), and subsequently incorporated into future restoration actions. That information should have been included in the response, even if only in simple summary fashion.

We also remain concerned about the validity of the data used to support the project prioritization and implementation process. The response repeatedly references the 1995 NRCS Watershed Plan, which is now 18 years old. In addition, the road density and stream crossing information provided in Table 1 is 8 years old, and the V-Star (sediment) data show no obvious trends from 2000-2010, although the downstream site seems to possess different V-Star values from the upstream site. However, without additional description of the sites and what restoration treatments were being evaluated, we are not sure how to interpret Table 2. The point is that greater confidence would have been placed in the need for specific restoration actions if site selection and restoration choices had been based on more current information. It is possible that more up-to-date information is in fact available, but clear summaries of the results of more recent monitoring were not provided in the response.

The response did not address our questions about the monitoring, evaluation, and adaptive management aspects of the project, stating that the sponsor was not required to include protocol methods or data from monitoring projects in this proposal, and that monitoring projects are identified in the project relationship section of the proposal form. The essence of the question from the ISRP was not for specific details of individual field and laboratory protocols and standard operating procedures but rather for a reasoned explanation of how many sites were being monitoring and the type of design, who will do the monitoring (what projects and agencies), and how the monitoring and evaluation data will be used to guide future restoration decisions. The ISRP believes that even for projects that are not collecting or evaluating data, the project leads and managers need to understand and agree on metrics that indicate success of particular actions, expectations for improved status of steelhead and other focal species, and have a framework for implementing restoration alternatives if more work is needed in the future.

Again, the ISRP believes that many of the proposed actions might be well justified; however, we are unable to determine if the project meets scientific criteria without a more detailed, scientifically supported project description.

Evaluation of Results

Insufficient information is provided in the proposal to develop a cogent analysis of whether the project is making reasonable progress toward watershed, subbasin, and basin-level goals for steelhead or other focal species.

The ISRP requests a revised proposal in order to establish that the project:

1) is based on sound science principles;

2) has clearly defined objectives and outcomes;

3) has provisions for monitoring and evaluation of results.

The purpose of this project is to remedy habitat problems in Omak Creek, which holds a remnant run of steelhead. According to the proposal, this work will involve riparian re-vegetation, large wood additions to the stream, removing passage barriers, and reducing sediment inputs. Later in the proposal, it is stated that the specific locations of many of these actions have not yet been identified but will become apparent after environmental assessments.

The proposal describes work that is likely needed and will also likely benefit endangered steelhead as well as other native fishes, but there was insufficient detail in several sections of the proposal form. In order to judge the scientific adequacy of the proposed work the ISRP needs:

1) A more comprehensive introductory section describing how this project will contribute to the goals of the Upper Columbia recovery plan for steelhead and a problem statement establishing the physical habitat and biological status of steelhead to provide context for justifying the project. The problem statement needs to start with fish abundance, the goals they want to achieve, and limiting factors.

2) A more detailed description of how various environmental assessments will be carried out, including how specific restoration locations will be prioritized for treatment.

3) More details on the actual restoration methods, by restoration category. For example, what types of plants will be used in the riparian re-vegetation projects, how will large wood be reintroduced to the stream, for example by use of individual pieces or engineered log jams that are anchored, and what techniques will be used to reconnect Omak Creek with its floodplain?

4) More information on how the sites will be monitored, who will do the monitoring and what methods will be used, and how the results of monitoring will be incorporated into continued restoration planning.

See the comments on individual proposal component for more detailed suggestions.

We were unable to understand how the projected budget was derived given that the assessments have not yet been completed and the number and scope of restoration actions for Omak Creek has not yet been specified.

Finally, the benefits of this project are likely constrained by land use in the watershed. Timber harvesting and the associated road system need to be managed in a manner that complements and aids self-sustaining restoration. Fixing symptoms of ecosystem degradation without addressing land use that drives watershed level processes is likely to require more effort with less benefit. A thorough road inventory of the entire Omak Creek watershed, with special focus on river crossing and identification of critical road components is needed. Road maintenance to lessen/mitigate impacts to fish and wildlife could be included in their timber sale contracts. Sustainable timber certification could be explored to increase their markets.

1. Purpose: Significance to Regional Programs, Technical Background, and Objectives

Significance to Regional Programs: Apart from discussing the cultural significance of Omak Creek, the proposal did not explain sufficiently how this project fit into regional restoration programs. The Okanogan Subbasin plan and the Upper Columbia Spring Chinook Salmon and Steelhead Recovery Plan are cited, but the linkage is not clearly summarized. Specifically for the recovery plan, a description of the TRT assessment of viability and the contribution expected from Omak Creek toward delisting the steelhead ESU needs to be included. Is the Omak Creek steelhead population considered an independent population essential for delisting the steelhead ESU? Is the population part of an MPG? How will restoration of the creek's steelhead population contribute to CCT, State of Washington, and Fish and Wildlife goals for VSP statistics for steelhead abundance, productivity, spatial structure, and diversity?

Problem Statement: Inadequate; the information provided is too brief. A more complete picture of the objectives for steelhead VSP parameters, limiting factors, and how they are going to be addressed is needed. Background should be provided about the current status and abundance of steelhead in the project area to support inferences about whether production is currently limited by too few spawners perhaps due to past depletion or continuing out-of-basin factors, or too many spawners for the available habitat resulting in low productivity perhaps due to habitat limitations within the subbasin.

The purpose of this project is to remedy a number of habitat problems in Omak Creek. According to the proposal this work will involve riparian re-vegetation, large wood additions to the stream, removing passage barriers, and reducing sediment inputs. Later in the proposal it is stated that the specific locations of many of these actions have not yet been identified, but will become apparent after environmental assessments. The proposal should include an explanation of the priority of addressing the limiting factors.

Project Objectives: Inadequate. The proposal states that the objective is a self-sustaining population of steelhead. The proposal should identify the abundance and productivity goals, and a timeframe for meeting the goals. The proposal does not provide any information on how success will be evaluated.

The objectives are not presented as part of an overall strategy, although it is mentioned under Adaptive Management that the “long-term goal” is to first provide passage above Mission Falls and then improve habitat there. No history of Mission Fall is provided, but that strategy sounds like one of expanding range above a longstanding barrier, which presupposes enough spawners will be available to colonize the new habitat.

2. History: Accomplishments, Results, and Adaptive Management (Evaluation of Results)

Major Accomplishments: A list of accomplishments was given in a table describing contracted deliverables from 2004 to the present, but details about those efforts were not summarized nor were the biological results of the restoration actions discussed. These achievements include culvert replacement and rock removal to improve passage, road improvement or decommissioning to reduce sedimentation, fence installation, riparian planting and placement of large woody debris to improve stream complexity. What is lacking is a concise summary of these achievements and evidence to show that the efforts have actually improved fish access, habitat quality, and fish abundance or productivity.

The results reported in the proposal are too vague to evaluate, and there is no evidence that an evaluation has been attempted by the sponsors. The first paragraph of the results section contains no results. The second mentions activities to improve passage over the falls, but seems to indicate that passage is not yet possible. The third paragraph justifies efforts to improve riparian vegetation, but it is not clear whether the measurements of canopy closure (8.4% in 2001 and 30% in 2002) represent improvements or measurements in different areas. The fourth paragraph justifies road decommissioning to reduce sedimentation and mentions that road densities have been determined from orthophotographs and that a new strategy has been developed by a Technical Advisory Group, but it does not indicate what improvements have been achieved to date. This proposal would have benefitted from before and after photos of some of the restoration actions. Other proposals have done this effectively, and it is recommended that project sponsors do so here unless more quantitative pre- and post-restoration habitat data are available.

Response to ISRP Comments: The information presented in the proposal does not address the question/suggestion the ISRP raised about using spring water as a source for off-stream cattle water. This needs to be added.

Adaptive Management: The proposal does not directly answer the questions in the proposal instructions. The entry under Adaptive Management refers to a long term goal but does not indicate how that goal might have changed as a result of monitoring and evaluation. In other words, this section does not obviously relate to either active or passive adaptive management. The project sponsors claim that monitoring has occurred in Omak Creek, although no information on what has been learned from the monitoring or how it has been applied to other work was given. The lone exception was an attempt to improve adult steelhead passage at Mission Falls, which apparently yielded unsatisfactory results. The project sponsors believe they now know how to increase fish passage at the falls, yet few details were provided.

Evaluation of Results

Insufficient information is provided in the proposal to develop a cogent analysis of whether the project is making reasonable progress toward watershed, subbasin, and basin-level goals for steelhead or other focal species.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions

Project Relationships: “None” was the answer in Taurus, but this seems at odds with the 2012 annual report. Consequently, insufficient information was provided in the proposal to judge the scientific soundness of this effort in terms of project relationships. The proposal text needs to provide an adequate answer to how this project interacts within the upper Columbia Province and similar habitat work in the region. Elsewhere the proposal mentions support from Okanogan Habitat Land and Water acquisition funds, but the nature of that relationship is not explained in any detail.

Emerging Limiting Factors: The section on emerging limiting factors merely lists again the factors that have already been noted as limiting salmon production; it does not include any significant discussion of factors that are newly emerging or that have been noted elsewhere as warranting attention in the future. In a TAURUS proposal, "Emerging Limiting Factors" means new environmental problems, for example climate change that are only now becoming apparent, not factors that are clearly known to be problems.

4. Deliverables, Work Elements, Metrics, and Methods

Deliverables: Nearly all of the nine deliverables call for an assessment or inventory of Omak Creek before specific restoration actions can be undertaken. Therefore, the ISRP was unable to determine what the work elements, metrics, and methods will be. The proposal needs to provide the inventory methods for assessments relating to each of the deliverables and then a summary of the approaches to be used to approach problems. For example, the ISRP needs more information than "add large woody debris to the channel to increase habitat complexity," or "replant riparian areas that have been overgrazed" in order to determine whether scientifically sound approaches will be used. Because this project is more than 10 years old, it seems somewhat surprising that problem areas have not already been identified.

Further, the proposal does not indicate any specific level of work to be accomplished over the time period of funding. Classes of work and work elements are presented, but the level of effort in each area is not provided. Some sort of over-arching summary of the anticipated accomplishments is required. And, there needs to be an explanation of why this sort of work was chosen, and what the anticipated benefits will be for focal species.

The map is inadequate as it does not indicate the relevance of the shading, the location of Mission Falls, or the location and extent of the habitat being made accessible or improved.

Specific comments on protocols and methods described in MonitoringMethods.org

Although the proposal states that monitoring has taken place and will occur in Omak Creek, no details were given. There were no references to monitoring protocols in MonitoringMethods.org.

1.  Revised Problem Statement/Technical Background

Steelhead in the Okanagon Subbasin of the Upper Columbia have experienced a dramatic decline resulting in a listing for protection under the authority of the Endangered Species Act (ESA) in 1997.  Although historic escapement estimates for Omak Creek are not available, photos taken in the early 1900’s show drying racks and catch nets suggesting that it once had a robust annual return of steelhead large enough to support harvest.  From 2004 to 2011, the mean number of adult steelhead in Omak Creek has been 3 and 165 (Figure 1; adult steelhead returns), while the recovery goal with habitat improvements is estimated at 1,545 (NRCS 1995).The 2013 estimate from EDT suggests a capacity of 564 adult steelhead in the United States portion of the Okanogan River (CCT unpublished data).    With Omak Creek’s estimated capacity of 94 steelhead in the lower reach and 94 more in the (currently inaccessible) upper reach, this system has the potential to make a large contribution to the recovery of steelhead in the U.S. portion of the Okanogan Basin if habitat improvements continue to be made.  The Watershed Plan (NRCS 1995), which is described below, has guided the restoration work in Omak Creek Watershed.

Figure 1.  Adult steelhead returns to Omak Creek 2004-2011 (2011 Summer Steelhead Annual Report).

2.  Detailed description of environmental assessments and prioritizing treatment areas

In 1995, the Natural Resources Conservation Service (NRCS) completed a Watershed Plan that assessed the resource conditions and problems (limiting factors) in the Omak Creek Watershed (NRCS 1995).  The report specifically identified instream temperature, fish passage barriers, and sediment loading as critical elements that are limiting the productivity of steelhead in the Omak Creek Watershed.

Omak Creek has had a legacy of poor landuse practices including logging, grazing, road construction, and industrial use.  A mill site located near the mouth of Omak Creek reduced the condition of important habitat in a highly productive and low gradient section of the stream at river mile 0.5 with a culvert that was 1,600 feet in length.  This barrier was removed in 1999.  At river mile 5.1, rock material that was deposited from the 1920’s construction a narrow gauge railroad continues to block fish passage, and instream work in 2013 will remove this barrier. Grazing in the lower portion of the watershed has reduced the integrity of natural riparian conditions and has created an environment with stream temperatures that were inhospitable to salmonids.  Forest practices in the Omak Creek watershed have resulted in high sediment loads due primarily to high road density (Table 1). 

Since the Watershed Plan was completed, efforts to implement the prescriptions prioritized in the plan have been implemented, including:  20 culvert replacements (including 4 bridges), more than 50 miles of decommissioned roads, 32 miles of livestock exclusion fence, 29 spring developments for offsite cattle watering (CCT unpublished data).  Additional fish passage improvements of removal of loose rock debris and boulders at Mission Falls will add 17 river miles of habitat for steelhead returning in 2014.

Table 1.  Summary information of 2004 road density and stream crossings by Watershed Management Unit (WMU) in the Omak Creek watershed (CCT 2011).

3.  Details on restoration methods

Prescribed treatments to mitigate the negative impacts of grazing include riparian revegetation, cattle exclosures with fencing, spring development (offsite watering), and streambank and shoreline protection (NRCS 1995).  Riparian revegetation included plantings of willow, cottonwood, alder, and other native species of cultural importance in.  Specifications for species and densities are outlined in construction plans for each project.  Fencing cattle out of riparian zones and offering them an offsite watering alternative prevents streambanks from being denuded and reduce overgrazing around cattle watering sources and crossings.  Activating disconnected side channels and connecting isolated wetlands will allow a middle reach of Omak Creek to naturally meander.  Large wood that has been introduced to the stream has been anchored as a means for streambank protection at prescribed locations. 

Since 1998, CCT has addressed the site-specific passage and temperature concerns.  CCT Omak Creek habitat staff work closely with NRCS staff to prioritize areas for restoration actions.  Following canopy closure in the lower reach and removing fish passage barriers, the remaining habitat work in the Omak Creek Watershed is the ongoing maintenance of existing plantings and fencing, adding off-channel livestock facilities , and continued sediment abatement efforts. 

As a part of the Colville Tribes’ Natural Resources Project Proposal Process team, Omak Creek staff review projects of other tribal departments who conduct activities in the watershed.  Stream crossings and road decommissions are prioritized are coordinated with CCT’s Forestry, Environmental Trust, and departments on an opportunistic basis.  This commitment is exemplified by the Tribe’s Integrated Natural Resource Management Plan’s mandate of no net increase in road density across the Reservation (CCT 2000).  Additionally, livestock exclusion fencing and watering facilities  are coordinated with the CCT Range department. 

4.  Monitoring

Following project implementation, Colville Tribes Fish and Wildlife staff return to project sites to visually inspect that the prescriptions are functioning as intended.  V-Star sediment data is collected every five years to monitor the response of sediment abatement efforts longitudinally (Table 2). 

Table 2: V-Star sediment data in 2000-2010 (CCT unpublished data)

Additionally, “Consistent with the BPA Programmatic Action Effectiveness Monitoring (AEM) program reviewed by the ISRP (ISRP 2013-2) and recommended for implementation by the Council on June 17, 2013, it is not the responsibility of this project to provide data or document protocols of other projects for RM&E as part of this proposal.  Although this project is not tasked with implementing AEM, it does align with the Programmatic AEM approach.  Project monitoring will be carried out by other projects focused on collecting data to support the Programmatic AEM approach. The known RM&E projects associated with this project are referenced in the “Relationship to Other Projects” section in the proposal form, or were referenced as part of the programmatic processes previously provided to the ISRP and ISAB by BPA for review of the Programmatic AEM approach.  However, this project will continue to work with BPA and Council staff to identity whether restoration actions proposed under this project may be candidates for use in the AEM program.   In accordance with the ISRP and Council recommendation, BPA will provide the ISRP updates on the ISEMP (IMWs fish and habitat relationships), CHaMP (Status and Trends), and the AEM program (with updated list of actions and related projects that contribute to the AEM program).”

REFERENCES

CCT 2000.  Colville Indian Reservation Integrated Natural Resource Management Plan 2000-2014 Final Environment Impact Statement.  Colville Confederated Tribes.  Nespelem, Washington.

CCT 2011.  Water pollution non-point source assessment report.  Colville Confederated Tribes, Environmental Trust Department. Nespelem, Washington.

CCT 2012.  2011 Summer Steelhead Annual Report.  Colville Tribes Fish and Wildlife Department.  Omak, Washington.

NRCS 1995.  Omak Creek Watershed Plan/Environmental Assessment.  U.S. Department of Agriculture, Natural Resources Conservation Service.  Spokane, Washington.