Please see the ISRP comments on Proposal #198343600, in which we call for a review of the Umatilla Initiative from a larger perspective than can be gained from review of individual proposals. This project and others in the Umatilla Basin like it are individual parts of the "Umatilla Initiative." As such, none of them is a stand-alone proposal that is susceptible to scientific peer review. This proposal, for example, includes no information on the amount of water pumped from the Columbia River or on possible effects on fish. The response refers the ISRP to other proposals, such as #198802200, under which monitoring is said to take place. Our examination of that proposal and its response to ISRP comments and questions led us to conclude that information being gathered is not adequate to evaluate the effectiveness of the pumping measure in terms of providing benefits to fish. Thus the basis for scientific review, according to the standards specified for the ISRP by Congress is inadequate.

We conclude that there is a need for review of the Umatilla Initiative from a larger perspective than can be provided by review of individual project proposals, such as we have in hand. This suggests that proponents might benefit by reorganizing their efforts under a single head. That would provide a unified perspective, leading to clarification of the fact that the success of all of the individual efforts are affected by the pumping of water from the Columbia River. Monitoring and evaluation should then focus upon documenting flow manipulations and measuring the effects on fish passage and survival.