Comment:

This is a well-written proposal and a well-conceived program that provides important benefits to fish. The CBWTP has shown impressive results in addressing the very contentious issue of water rights. It is being accomplished through an innovative partnership where work is strategically focused on priority subbasins and stream reaches. The proponents have been responsive to ISRP feedback, implementing a tiered monitoring program that effectively utilizes scarce monitoring resources. Prioritization of projects within the CBWTP is established locally but linked to broader subbasin and recovery plan efforts. The proponents also have a strong dissemination plan. They hold two conferences per year where they share information and approaches among the Qualified Local Entities (QLEs).

The ISRP has two concerns. First, it is not clear when the program will be complete or how the proponents will know if they have achieved their objective. Second, the CBWTP needs to be more specific about project benefits. Is the scale of the recovered instream flows measurable relative to the overall flow and the scale of habitat loss and other issues in the basin? Given the large budget, simply reporting million-acre feet (MAF) does not effectively communicate the impact of the program. Water alone is likely not the best metric to describe the full suite of beneficial outcomes associated with the work. One alternative could include stream miles re-watered. Monitoring data and/or models could also be used to estimate changes in the numbers of redds, spawning fish, or smolts produced. The ISRP is aware that this monitoring is being conducted at some sites but found it difficult to use that information to discuss impacts of the program. The proponents need to do a better job at using that information to communicate tangible outcomes of flow restoration. In addition, it would be useful if the proponents could track any increase in efficiency in water transactions associated with program activities? Finally, the website could be improved to more effectively communicate benefits and elevate the profile of the program.

The ISRP welcomes the opportunity to continue a dialogue with the proponents on the new resiliency criterion that the proponents are developing for projects, particularly with respect to understanding the impacts of climate change. Related to this, it may be worthwhile to ask if the CBWTP should be focusing efforts in subbasins with strongholds of healthy fish populations. Climate change and human development will impact subbasins in different ways and with different effects. Are efforts prioritized to maintain subbasins that will remain in reasonably good condition for the long term? It appears that funds are spent opportunistically (to some degree) depending on willing water owners/sellers

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

The objective for the program—restored stream flows to ecologically significant Columbia Basin tributaries—needs to be more quantifiable. While the work is clearly and compellingly justified, the objective (and goal) are not written in such a way that success in meeting the objective can be measured and assessed. Apparently, the proponents had more specific and ecologically oriented objectives when they were reviewed as a RM&E program (listed on page 5), and they consolidated them in the current proposal. How will they know if individual projects are significantly contributing to the program's overall objective? Are very small amounts of restored stream flows in a priority reach expected to contribute to ecological significance? Having a more clearly defined objective would help the proponents assess progress toward their objective and communicate benefits of the project. The seven deliverables provide more detail regarding project activities and expected results, but the linkage to an overarching flow restoration objective makes it hard to determine the significance of these activities.

Generally, the program is well conceived and certainly has relevance to regional programs. The collaboration with and support of QLEs makes a lot of sense. The work seems to be the right mix of actual transactions, capacity building, and monitoring. Using local recovery and restoration plans for prioritization is both efficient and appropriate. The development and implementation of the Flow Restoration Accounting Framework (FRAF) is a strength of the program. The four tiers make logical sense and use resources as effectively as possible and represent a reasonable attempt to link results to the program objective, once it is more quantitatively defined.

The proposal directly addresses relevance to regional programs, including specific RPAs under the BiOp, Fish and Wildlife Program, as well as several more local scale plans.

2. Results and Adaptive Management

Despite the lack of a quantitative project scale objective, the CBWTP has achieved important results and the proposal is prepared in a way that those results are clearly documented. The proposal included plots of results over the program overall, as well as a handful of specific case studies with data (e.g., redd counts, redd distributions, WUA estimates, max temp data) to provide evidence of ecological benefit. The ISRP is grateful to the proponents for preparing such a professional proposal that was easy to read and included data. Key results of the program to date include over 540 water rights transactions and 1.6MAF of water returned to priority reaches. Another noteworthy achievement is that the distribution of projects is evenly distributed across the Columbia Basin, with a total of 232 active projects in thirty-two HUC-8 subbasins. Also noteworthy is the contribution of the program to fostering the improvement of state and QLE administrative rules and policies for allocating acquired water to instream use more effectively. A number of informative, stream specific accomplishment reports were provided which described good examples of work accomplished and results observed. The ISRP also recognizes the importance of providing transactional and capacity building support to the QLEs, including providing training and workshops to QLE project management staff in all aspects of water transactions.

While there is not a formal adaptive management strategy, the proposal provides details of the lessons learned and how it has improved and responded to ISRP feedback over the years. In this regard, the program represents the type of strategic feedback loop that is likely to be effective across other projects in the program. Grounded in science, responsive to feedback, and with a clear sense of reflection, this program has made important improvements since its initiation in 2003. Changes made to improve the project include developing and launching the FRAF and improvements in the tracking and management of transaction costs including a new database system launched in 2018. In addition, the proponents launched a water temperature logger "network" in 2019 to help collate temperature data that is being collected, though there were limited details on what this network will physically look like or how results will be analyzed to provide statistically valid findings. Also, the proponents note that QLEs are responding to climate change by prioritizing instream flow for headwater reaches. Taken together, even though it is not through a formal adaptive management program, these changes indicate the program is doing the self-reflection needed to adapt the program and that the adaptations are tangibly improving the program over time.

Regarding sharing of program results, the proponents report that the data are available by request, but that there is not a great demand for it. However, the ISRP emphasizes that better access to the project accomplishments and data are needed. The website is only marginally informative and could provide a more appealing and useful documentation of program results. Their FRAF is available on monitoringmethods.org, and there is a good deal of accomplishments in project reporting, some, but not all, of which is found on their website. While the proponents are clearly working hard to develop relationships that secure more water, the nature and extent of public outreach that is happening with the scientific community or other audiences is not clear. More emphasis on this could help elevate the profile of the program.

3. Methods: Project Relationships, Work Types, and Deliverables

Project relationships appear to be numerous and working well. A major function of this project is building relationships. Some of the benefits of these relationships are demonstrated by the significant level of cost share for this program. The work types are clearly defined and appropriate.

The outcomes (33,650 acre-feet and over 165 cubic feet per second to low flow tributaries in new/renewed transactions annually) and seven deliverables are explicitly described. Some of these deliverables (DEV 3, DEV 6) are measurable, while others represent important activities but for which it will be hard to measure the level of success or quality as a deliverable. The ISRP appreciated that the proponents identified factors that will limit success in producing each of the deliverables. In addition, the ISRP agrees with the proponents that a third-party evaluation of the program is a valuable use of resources that is likely to benefit the program. The ISRP agrees with the proponents that deliverables directed to increase the skills and knowledge of QLE staff should be a priority.

Based on how the objectives are written, it is easy to conclude that they are meeting the objective of restoring instream flows, but the causal linkages to ecological benefits are not always clear. It may not be necessary to demonstrate that their flows result in a measurable change in biological outcomes, via post-project monitoring or by modeling, given all the other stressors in these systems.

The ISRP is supportive of the logical and efficient approach for tiered monitoring (FRAF) and shares the proponents' concerns regarding the current 5% cap on monitoring by BPA. This seemingly arbitrary restriction makes it difficult for proponents to demonstrate compliance and effectiveness for individual projects, so they can show they are meeting their objectives and providing a broader benefit to the Fish and Wildlife Program. The proponents note that the cost of monitoring is rising and are requesting that BPA raise the 5% limit on monitoring to 15%. This appears reasonable given their prior experience and formal monitoring strategy.