The ISRP commends the proponents for a sound proposal along with a strong record of accomplishments and progress toward program goals. Past restoration actions performed by the project have helped reduce fish passage barriers, enhanced habitat complexity and availability, and improved water quality. Proposed work is scheduled to occur in the upper tributaries and forks of the Walla Walla River. Ten new projects are scheduled for the next funding period. As with previous work, these projects are focused on removing migration barriers, restoring watershed functions via fencing, culvert removal, bank sloping, riparian planting, floodplain and side channel reconnections, and pool creation. In one project, Beaver Dam Analogs or BDAs will be used to slow and spread water during periods of moderate to high flows to reconnect floodplains, encourage riparian plant growth, and gradually deliver water to the channels after high flows.

Project site selection is based on numerous criteria. The proponents follow the hierarchical strategy of Roni et al. (2002, 2018, and references therein) and focus on restoration with an appropriate set of techniques at multiple scales. Methodologies and standard practices for implementation objectives were provided from BPA’s HIP and screening protocols. The links to implementation monitoring methods published in MonitoringResources.org along with brief descriptions of methods in the text were especially helpful. Finally, the incorporation of concepts of resiliency and incorporation of climate change more explicitly in their work were noteworthy.

The ISRP’s recommended Conditions are listed below. The proponents need to assist with development of an M&E Matrix during the response loop (September 24 to November 22, 2021) and to provide information to address the other following Conditions in future annual reports and work plans:

1. SMART objectives. Proponents should continue to work toward framing their objectives to align more with the SMART format (see proposal instructions) in future proposals, work plans, and annual reports. The implementation monitoring objectives generally lacked some elements of SMART objectives. 
   
   
2. Explanation of objectives. We note there was also some disconnect with the presentation of Progress by Objective. Specifically, in the diagram Objectives are listed as A-G (n=7), while in the Progress section they are listed as 1-10. Given that BPA is no longer funding a couple of previous objectives, ISRP recommends that the proponents provide a crosswalk of the different set of objectives for improved clarity in the final work plan or next annual report. 
   
   
3. Links between implementation, outcomes, and monitoring. The ISRP recommends a couple of refinements to the descriptions of implementation methods and subsequent monitoring to include in the work plan or next annual report. Specifically, the proponents could list each of the projects by objective and then present methods for the restoration activities (e.g., plant X trees in the riparian zone) and then follow-up with the monitoring. Ultimately, each of the monitoring methods poses a similar kind of question, i.e., can we detect a physical or hydrological change(s) due to restoration activities? While this may appear to be a simple question, there is the issue of separating signal (effect of restoration) from the noise (all the other things going on). There are also issues associated with scale (e.g., local reach v. subbasin-wide) which complicate detecting an effect. If for example stream temperatures do not change, does that suggest there is a problem with the objective or approach? Or is some other explanation likely. While the ISRP recognizes these points are not fatal flaws for the project, it would be useful for the monitoring to have some expectations for effects from the project(s) and over what time scale. 
   
   
4. M&E matrix - support. As habitat projects and monitoring projects are not presented as part of an integrated proposal or plan, the need for a crosswalk to identify the linkages between implementation and monitoring is extremely important for basins or geographic areas. The ISRP is requesting a response from the Walla Walla Sub-Basin Salmonid Monitoring and Evaluation Project (200003900) to summarize the linkages between implementation and monitoring projects in the basin. In the response loop, we ask this project to assist them in creating the summary and provide information to them about what is being monitored for this implementation project and where and when the monitoring occurs. A map or maps of locations of monitoring actions would be helpful in this regard. 
   
   
5. Explanation of aquifer recharge activities. The ISRP recommends adding some brief text to clarify the aquifer recharge (MAR) activities. The proposal mentions that water conservation efforts have reduced groundwater recharge. The reason for this was not obvious until discussed during the presentation. This should be explained more clearly in future annual reports and proposals. Also during the presentation was a discussion of recharge projects, including last year’s effort as the largest to date. These apparently are not funded by BPA and other local funding sources are being sought. These appear highly relevant to the project’s passage and flow goals and should be briefly discussed in that context. 
   
   
6. Climate change and prioritization. The proponents provided an excellent discussion of how climate change will likely affect the Walla Walla Subbasin and to recovery of imperiled species in this system. The CTUIR fish habitat project (199604601) also included a strong presentation on climate change, which indicates considerable thinking on this topic and how it will affect the subbasin. What was not clear, however, is how the climate change analysis is used to screen specific project actions. A high priority action under present or past conditions, for example, might be quite different from those under likely climate change scenarios. The ISRP encourages the proponents to continue to refine their projections, coordinate with other projects, and adjust project activities accordingly.

Q1: Clearly defined objectives and outcomes

The proposal focuses on Walla Walla Basin Watershed Council’s set of actions in the upper tributaries of the subbasin (especially North Fork Walla Walla, Couse, Cup Gulch, and Big and Little Meadow Canyon creeks). Proponents frame the problem(s) in the subbasin very well, especially in relationship to current hydrological and geomorphic challenges compared with historical conditions.

An overview of the substantial changes that occurred in the Walla Walla subbasin caused by agriculture, forestry, grazing, and human development was provided. These changes have brought about a suite of deleterious effects, including reductions in stream flow, increases in the occurrence of fish passage barriers, decreases in water quality (e.g., increases in water temperatures, sedimentation, and toxics), isolation of floodplains and side channels, and simplification of stream habitats. In aggregate these alterations from historical conditions have impaired the subbasin’s native fish populations. The proponents, along with other groups working in the subbasin, are engaged in efforts to correct and improve conditions in the subbasin for salmonid fishes.

The proponents do a commendable job of linking their proposal to a broader set of 14 plans and documents with a good description of how the proposal fits in (e.g., Walla Walla Subbasin Plan to Council’s Fish and Wildlife Program addendum, and others). The project’s four overarching goals, to increase fish passage for salmonids; enhance habitat complexity; restore floodplain and riparian functions; and improve water quality are clearly expressed. A hierarchical flow diagram depicting the goals and objectives of the project shows how the project’s proposed implementation and monitoring objectives are linked to each of the project’s overarching goals.

In the Progress to Date section, the proponents provide a description of outcomes to date. They frame this by laying out their 10 Objectives along with the implementation metrics and benchmarks. This was well presented and framed although the Objectives as presented are stated as broad topical goals, although the SMART framework is interwoven (see Condition 1 above). A couple of previous activities are no longer funded by BPA (e.g., irrigation efficiency and MAR projects in the basin), the rationale for which was not provided.

In the Goals and Objectives Section, the diagram on pages 22-23 that connects four goals with seven objectives is easy to follow and a nice presentation. However, there was also some disconnect with the presentation of Progress by objective. Specifically, in the diagram Objectives are listed as A-G (n=7), while in the Progress section they are listed as 1-10 (see Condition 2 above).

Q2: Methods

The general approach taken by the project, to address the core causes of habitat loss by restoring watershed processes and functions, is far-sighted and commendable. Implementation methods are appropriately described at a brief and basic level. The proponents provide links to documents for proposed actions (e.g., NRCS 2003, OWEB 1999) that further embellish standard methodology for actions/objectives.

For the implementation monitoring methods, it looks like basin-scale and project-scale monitoring is the focus (see Condition 3).

The proponents also indicate that they regularly deposit and share data with subbasin partners. Interpreted summary data are publicly available on the wwbwc.org website.

Q3: Provisions for M&E

The proponents plan on using an adaptive management process described by Wheaton et al. (2019). A schematic of this method is provided, and it was developed to address adaptive management in projects using process-based habitat restoration. Therefore, it should be suitable for the project. Both annual and periodic (once every 5-year) assessments are planned, and adjustments will be based on the results of their effectiveness monitoring. The WWBWC project committee, landowners, and BPA representatives will participate in the adaptive management process. Federal, state, and Tribal agencies will be invited to evaluate project designs. All adjustments will be made through consensus. Quarterly and annual reports will be used to document the decisions and evaluations made.

The ISRP notes that the specifics of what is being biologically monitored for each objective needs some additional coordination and clarity in the final work plan and next annual report (see Condition 4 above).

Q4: Results – benefits to fish and wildlife

The chief beneficiaries of the proposed actions are ESA-listed summer steelhead, bull trout, and reintroduced spring Chinook. These benefits can be observed by way of subbasin biomonitoring (e.g., Project 200003900 or others). While the project addresses elements of the limiting factors in the subbasin, connecting the actions to these factors would complete the presentation. The ISRP recommends including linkages to subbasin biomonitoring (e.g., Project 200003900 or others) to how the activities benefit target species.

Previous and recent restoration actions by the project have helped remove passage barriers, improved habitat complexity by reconnecting floodplain and side channels, planted riparian vegetation to create shading to reduce water temperatures, and worked with landowners to increase irrigation efficiency to improve river flows. Many of the proponents’ water conservation projects have also been paired with managed aquifer recharge sites or MARs (see Condition 5 above). In past site visits, the ISRP has been impressed with the benefits generated by MARs which capture water in the winter/spring months and through infiltration will recharge groundwater sources. BPA, however, has decided to discontinue funding MARs. Fortunately, the proponents have secured outside funding that can be used to continue to support these sites and their eventual delivery of relatively cool waters to springs and other outlets. The project has also collected and managed hydrologic data that is used by many of its restoration partners.

The ISRP commends the proponents and others in the subbasin that are trying to understand what the effects of future climate change in the basin may be by doing some modeling and forecasting. There are opportunities to extend and coordinate these considerations as the project progresses (see Condition 6 above).

This project is clearly addressing a factor that is limiting fish production in the Walla Walla Basin: limited instream flow. There is very good evidence that they have made significant progress in addressing this issue. For example, the project has performed useful fish passage and habitat restoration in the Walla Walla subbasin and has identified additional sites where irrigation efficiencies, aquifer recharge actions, fish passage improvements and restoration of floodplain processes should occur. The project has a strong RM&E component and is using the information generated to modify restoration plans. In future proposals, the project sponsors should include additional information on project relationships in the Walla Walla Basin. A little more detail on how fish movement and presence/absence data will be collected would have been helpful. Also, some additional information on the bank stabilization deliverable below the Nursery Bridge grade control structures should have been included in the proposal.

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

This project is significant regionally as seasonal lack of instream flow impacts listed fishes in the Walla Walla River. The activities proposed are consistent with the Walla Walla Subbasin Plan, the priority actions listed in the Bi-State Habitat Conservation Process, and in the Draft Bull Trout and Steelhead Recovery Plans. The project has three goals, to restore up- and downstream passage for juvenile and adult salmonids; to recharge aquifers to sustain and augment river, tributary, and spring flows; and to implement irrigation efficiency programs to increase stream flows. Ten objectives, including improving water quality, providing additional instream flows, promoting water conservation, protecting conserved water via Oregon and Washington Water Trust laws, monitoring and management of hydrologic data, expanding the size and duration of cold water refugia, and improving base river flows through floodplains are being used to address these goals. The objectives are appropriate for this project. They all focus on restoring appropriate flow conditions and water quality throughout the Walla Walla River watershed.

The history of the water projects on the Walla Walla is described sufficiently. Efforts to enhance flow in the river have been ongoing for over a decade with some notable successes. Previously dewatered reaches now have year-round flow. The extensive hydrology monitoring network enabled the identification of declining groundwater levels (partly due to increased efficiency of the irrigation system). Reduced ground water levels have eliminated many springs, which had made an important contribution to summer base flow and provided thermal refuge. They have been experimenting with various methods of enhancing groundwater storage in the basin and have had some success.

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

The Walla Walla Basin Watershed Council (WWBWC) and partners developed a water monitoring network in 2001 to understand the role that ditches and irrigation practices had in aquifer maintenance in the subbasin. Results from this monitoring work have guided future restoration actions. For example, during the past eight years the WWBWC has worked with multiple partners to develop aquifer recharge projects, for example the Hulette Johnson, Hall-Wentland, and Stiller Pond sites and the Anspach and Trumbull projects. Also the WWBWC recently completed a Walla Walla Basin Aquifer Recharge Plan. Additionally, the WWBWC collects groundwater and surface water data and distributes it to basin partners and local, state, and federal agencies. Some of these data were used to develop the TMDL for water temperature in Oregon’s part of the Walla Walla River.

A thorough discussion of project history is provided in the proposal along with links to other project related documents. The project has been using adaptive management processes to improve its program of flow enhancement. Initially the project focused on areas where immediate short-term savings in water would occur. Now, projects are taking place in areas where water savings can improve stream flow later on. Experiments were performed that evaluated the effectiveness of four water distribution systems in an aquifer recharge area. One distribution system that was identified as being the most effective is now being used in other aquifer recharge projects. Additionally, the newly completed Walla Walla River Alternatives Analysis and Conceptual Design Milton-Freewater Levee and Habitat analysis is being used to identify opportunities for fish passage and fish habitat improvements. The analysis includes some HEC-RAS modeling which performs channel flow determinations and floodplain identification.

Evaluation of Results

Prior to this proposal submission, the Walla Walla Basin Watershed Council, Walla Walla Conservation District, Gardena Farms Irrigation District, CTUIR, and WDFW had projects funded by this project. Previous work involved establishing over 100 monitoring wells, 60 stream flow gauges, the production of a hydrologic data base called AQUARIS, the creation of 124 miles of Conservation Reserve Enhancement Program (CREP) riparian buffers, the installation of over 300 fish screens by ODFW and WDFW, removal of 15 significant fish barriers, over 18.6 miles of ditch piping in Oregon, 85 on-farm water efficiency projects, aquifer recharge research and implementation, the enactment of soil retention practices on 80% of the steep wheat land in Columbia County (WA), and the completion of the Walla Walla Basin Aquifer Recharge Strategic Plan. This work has helped restore fish passage, instream flows, and recharge shallow aquifers.

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

The project is linked to the Walla Walla River Basin Fish Habitat Enhancement, Walla Walla River Juvenile and Adult Passage Improvements, Walla Walla River Basin Monitoring and Evaluation, Walla Walla River Hatchery Operations and Maintenance, and Umatilla Fish Passage Operations projects. Partners include ODFW, WDFW, CTUIR, OWRD, WDOE, OSU, USDA, Hudson Bay District Improvement Company, Walla Walla Irrigation District and Fruitvale Water Users Association, ODEQ, Walla Walla County Conservation District, and private landowners. However, how this project and the other projects mentioned above coordinate with one another is incompletely described. Some additional discussion of how this project interacts with the habitat restoration and fish monitoring efforts in the watershed would have been useful.

The sponsors have established a very thorough hydrological monitoring system in the watershed. Detailed data on river and stream flow, groundwater level, water temperature and water chemistry are being collected. The proposal also demonstrates that these data are being used to inform restoration project designs. There is a good data storage system in place and the data are available online. Maintaining this system is critical to ensure compliance with water agreements.

Climate change was recognized as an emerging limiting factor. A climate change projection specifically for the Walla Walla Basin has been produced and results indicate that there will be an increase in cold-season flows and a decrease in late spring-summer stream flows. They are planning for such changes by shunting higher winter flows into aquifer recharge areas so that summer flows can be augmented from the recharged aquifers. Additionally, new piping is being installed to reduce seepage and improve irrigation efficiencies, so this emerging limiting factor is being addressed. There was no discussion, however, of how future development or changes in agriculture could influence water availability. Some consideration of these factors should be included in the project. Additionally, it is not clear if the hydrological model has been used to forecast what happens under extreme events? For example, suppose that drought conditions occur in two or more consecutive years, can the model be used to forecast water availability under this circumstance? And if so, have plans been made on how water will be allocated to irrigators as well as for fish passage?

4. Deliverables, Work Elements, Metrics, and Methods

The project has seventeen deliverables; fourteen of them are directed toward specific projects in the Walla Walla subbasin. The general goals of the specific projects are to improve irrigation efficiency and fish passage, restore floodplain processes, and start aquifer recharge programs. In several instances, engineered drawings or other plans have already been developed for these projects. The remaining three deliverables have more general goals. In one case, the objective is to monitor irrigation flows via telemetry and use automation to open and close valves or gates to improve water management. In another instance the sponsors wish to establish water right “maps” in project areas so that easements or other arrangements can be made to protect instream flow enhancements. The project has also used hydrologic mapping and monitoring to help determine where restoration projects should occur. The sponsors wish to continue this work to monitor status and trends in water temperatures and flow. Additionally, these data will be connected to fish presence and movement information to see how fish react to water flow and temperature improvements. Some information on how fish movement and presence/absence data are collected should have been included in the proposal.

The deliverables are mostly appropriate for the objectives of this project, and the work elements are described adequately. The deliverable for channel stabilization below the Nursery Bridge grade control structures, however, does not contain enough detail on the nature of the bank stability issue or the measures that are planned to address the problem. More detail on this deliverable should be included.

Specific comments on protocols and methods described in MonitoringMethods.org

Three major RM&E protocols are listed and all were developed by project personnel. Most are largely complete and are appropriate for the types of data being collected.

This project is clearly addressing a factor that is limiting fish production in the Walla Walla Basin: limited instream flow. There is very good evidence that they have made significant progress in addressing this issue. For example, the project has performed useful fish passage and habitat restoration in the Walla Walla subbasin and has identified additional sites where irrigation efficiencies, aquifer recharge actions, fish passage improvements and restoration of floodplain processes should occur. The project has a strong RM&E component and is using the information generated to modify restoration plans. In future proposals, the project sponsors should include additional information on project relationships in the Walla Walla Basin. A little more detail on how fish movement and presence/absence data will be collected would have been helpful. Also, some additional information on the bank stabilization deliverable below the Nursery Bridge grade control structures should have been included in the proposal.

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

This project is significant regionally as seasonal lack of instream flow impacts listed fishes in the Walla Walla River. The activities proposed are consistent with the Walla Walla Subbasin Plan, the priority actions listed in the Bi-State Habitat Conservation Process, and in the Draft Bull Trout and Steelhead Recovery Plans. The project has three goals, to restore up- and downstream passage for juvenile and adult salmonids; to recharge aquifers to sustain and augment river, tributary, and spring flows; and to implement irrigation efficiency programs to increase stream flows. Ten objectives, including improving water quality, providing additional instream flows, promoting water conservation, protecting conserved water via Oregon and Washington Water Trust laws, monitoring and management of hydrologic data, expanding the size and duration of cold water refugia, and improving base river flows through floodplains are being used to address these goals. The objectives are appropriate for this project. They all focus on restoring appropriate flow conditions and water quality throughout the Walla Walla River watershed.

The history of the water projects on the Walla Walla is described sufficiently. Efforts to enhance flow in the river have been ongoing for over a decade with some notable successes. Previously dewatered reaches now have year-round flow. The extensive hydrology monitoring network enabled the identification of declining groundwater levels (partly due to increased efficiency of the irrigation system). Reduced ground water levels have eliminated many springs, which had made an important contribution to summer base flow and provided thermal refuge. They have been experimenting with various methods of enhancing groundwater storage in the basin and have had some success.

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

The Walla Walla Basin Watershed Council (WWBWC) and partners developed a water monitoring network in 2001 to understand the role that ditches and irrigation practices had in aquifer maintenance in the subbasin. Results from this monitoring work have guided future restoration actions. For example, during the past eight years the WWBWC has worked with multiple partners to develop aquifer recharge projects, for example the Hulette Johnson, Hall-Wentland, and Stiller Pond sites and the Anspach and Trumbull projects. Also the WWBWC recently completed a Walla Walla Basin Aquifer Recharge Plan. Additionally, the WWBWC collects groundwater and surface water data and distributes it to basin partners and local, state, and federal agencies. Some of these data were used to develop the TMDL for water temperature in Oregon’s part of the Walla Walla River.

A thorough discussion of project history is provided in the proposal along with links to other project related documents. The project has been using adaptive management processes to improve its program of flow enhancement. Initially the project focused on areas where immediate short-term savings in water would occur. Now, projects are taking place in areas where water savings can improve stream flow later on. Experiments were performed that evaluated the effectiveness of four water distribution systems in an aquifer recharge area. One distribution system that was identified as being the most effective is now being used in other aquifer recharge projects. Additionally, the newly completed Walla Walla River Alternatives Analysis and Conceptual Design Milton-Freewater Levee and Habitat analysis is being used to identify opportunities for fish passage and fish habitat improvements. The analysis includes some HEC-RAS modeling which performs channel flow determinations and floodplain identification.

Evaluation of Results

Prior to this proposal submission, the Walla Walla Basin Watershed Council, Walla Walla Conservation District, Gardena Farms Irrigation District, CTUIR, and WDFW had projects funded by this project. Previous work involved establishing over 100 monitoring wells, 60 stream flow gauges, the production of a hydrologic data base called AQUARIS, the creation of 124 miles of Conservation Reserve Enhancement Program (CREP) riparian buffers, the installation of over 300 fish screens by ODFW and WDFW, removal of 15 significant fish barriers, over 18.6 miles of ditch piping in Oregon, 85 on-farm water efficiency projects, aquifer recharge research and implementation, the enactment of soil retention practices on 80% of the steep wheat land in Columbia County (WA), and the completion of the Walla Walla Basin Aquifer Recharge Strategic Plan. This work has helped restore fish passage, instream flows, and recharge shallow aquifers.

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

The project is linked to the Walla Walla River Basin Fish Habitat Enhancement, Walla Walla River Juvenile and Adult Passage Improvements, Walla Walla River Basin Monitoring and Evaluation, Walla Walla River Hatchery Operations and Maintenance, and Umatilla Fish Passage Operations projects. Partners include ODFW, WDFW, CTUIR, OWRD, WDOE, OSU, USDA, Hudson Bay District Improvement Company, Walla Walla Irrigation District and Fruitvale Water Users Association, ODEQ, Walla Walla County Conservation District, and private landowners. However, how this project and the other projects mentioned above coordinate with one another is incompletely described. Some additional discussion of how this project interacts with the habitat restoration and fish monitoring efforts in the watershed would have been useful.

The sponsors have established a very thorough hydrological monitoring system in the watershed. Detailed data on river and stream flow, groundwater level, water temperature and water chemistry are being collected. The proposal also demonstrates that these data are being used to inform restoration project designs. There is a good data storage system in place and the data are available online. Maintaining this system is critical to ensure compliance with water agreements.

Climate change was recognized as an emerging limiting factor. A climate change projection specifically for the Walla Walla Basin has been produced and results indicate that there will be an increase in cold-season flows and a decrease in late spring-summer stream flows. They are planning for such changes by shunting higher winter flows into aquifer recharge areas so that summer flows can be augmented from the recharged aquifers. Additionally, new piping is being installed to reduce seepage and improve irrigation efficiencies, so this emerging limiting factor is being addressed. There was no discussion, however, of how future development or changes in agriculture could influence water availability. Some consideration of these factors should be included in the project. Additionally, it is not clear if the hydrological model has been used to forecast what happens under extreme events? For example, suppose that drought conditions occur in two or more consecutive years, can the model be used to forecast water availability under this circumstance? And if so, have plans been made on how water will be allocated to irrigators as well as for fish passage?

4. Deliverables, Work Elements, Metrics, and Methods

The project has seventeen deliverables; fourteen of them are directed toward specific projects in the Walla Walla subbasin. The general goals of the specific projects are to improve irrigation efficiency and fish passage, restore floodplain processes, and start aquifer recharge programs. In several instances, engineered drawings or other plans have already been developed for these projects. The remaining three deliverables have more general goals. In one case, the objective is to monitor irrigation flows via telemetry and use automation to open and close valves or gates to improve water management. In another instance the sponsors wish to establish water right “maps” in project areas so that easements or other arrangements can be made to protect instream flow enhancements. The project has also used hydrologic mapping and monitoring to help determine where restoration projects should occur. The sponsors wish to continue this work to monitor status and trends in water temperatures and flow. Additionally, these data will be connected to fish presence and movement information to see how fish react to water flow and temperature improvements. Some information on how fish movement and presence/absence data are collected should have been included in the proposal.

The deliverables are mostly appropriate for the objectives of this project, and the work elements are described adequately. The deliverable for channel stabilization below the Nursery Bridge grade control structures, however, does not contain enough detail on the nature of the bank stability issue or the measures that are planned to address the problem. More detail on this deliverable should be included.

Specific comments on protocols and methods described in MonitoringMethods.org

Three major RM&E protocols are listed and all were developed by project personnel. Most are largely complete and are appropriate for the types of data being collected.

Modified by Dal Marsters on 6/11/2013 1:14:29 PM.

This is one of three closely linked passage proposals in the Walla Walla subbasin. Most of the proposal is well done. The proposal would be improved by reporting results from the subbasin level M&E project in summary format. The project needs to make the connection to biological data collected in the M&E project. This was a similar concern with previous ISRP reviews, and while there has been some improvement, it should be clear by now that projects must indicate results of past efforts clearly, particularly after 10 years of efforts. The efforts and results must be linked to subbasin plans, and this was not a strong area of the proposal. What data will be collected by other entities to evaluate success (or failure)? What are the key reference points from this data that will affect management decisions?