Dear Mr. Ruckelshaus:
The Chehalis Basin Partnership (CBP), as the Lead Entity for WRIA 22 and 23 in the Chehalis River Basin offer the following comments and recommendations on the process used by the Salmon Recovery Funding Board (SRFB) to select restoration projects. Many of the comments and recommendations developed by the CBP were also Lead Entity concerns and discussion topics at the April 7 th workshop.
Before getting into the specific suggestions, we think it is appropriate to review an underlining intent of the enabling Legislation. The intent is that for salmon restoration to be successful it must have the support of the local property owners, local government entities, and local restoration groups. The process so far actually alienates many of the local entities for the reasons noted below. We ask that as the SRFB goes forward, they encompass changes that will foster local cooperation and support. We are doomed to failure without that support.
SRFB emphasized the necessity of long-term recovery plans. The CBP supports developing long-term recovery plans. However, the SRFB seemed to expect the completed plan before funding current projects. The legislature understood that the time line to complete the limiting factors analysis was a matter of scale so they directed the SRFB to implement restoration in a timely manner knowing that all the salmon recovery plans for every watershed would not be completed. Because the legislature directed the SRFB to implement projects in a timely manner, requiring recovery plans at this stage is impractical and will delay good projects that could provide immediate benefit to fish resources. The CBP agrees that a strategic salmon recovery plan is needed for the basin, but we realize that this cannot be accomplished until the limiting factors analysis for the entire basin is complete. We concur with the April 7 th workshop comments that the SRFB should provide technical assistance to Lead Entities to develop strategic recovery plans that consistently address habitat needs identified in limiting factors analyses.
SRFB reviewers expressed the opinion that the Chehalis Basin projects were opportunistic rather than developed following a recovery strategy. The CBP believes the SRFB's judgment of our projects was unfounded and failed to take into consideration tile work that has been done and the size of the watershed. The Chehalis Basin is the second largest in the state and the limiting factors analysis for the entire basin will not be complete for at least another year. A limiting factors analysis will be completed for each of 15 subbasins in the watershed. As sub-basin limiting factors Analyses are completed the Lead Entity will be able to establish an interim recovery strategy and eventually a comprehensive strategy for the entire Chehalis River Basin. All projects submitted for ftinding referenced the Limiting Factors Report for the completed Lower Chehalis sub-basins, the 1992 USFWS report or one of the Watershed Analyses completed in the basin to identify habitat restoration needs.
SRFB failed to emphasize the use of limiting factors analysis as identified by the enabling Legislation under SB 5595, SEC 2, 5 and 9. The decision not to fund culvert replacement projects or restoration of fish access projects was outside the intent of SB 5595 and RCW 75.46 and the SRFB's own policies and procedures. Limiting factors identified in the 1992 Chehalis Basin Fisheries Resources Status, Trends and Restoration Goals, Watershed Analyses done since 1995, and limiting factors analyses completed to date all identify passage barriers at culverts as a critical factor limiting access to miles of salmon habitat. As you know, there was considerable discussion at the workshop regarding the SRFB's decision not to fund culvert replacement projects. We feel that reestablishing access to historic salmon habitat will be one of the most cost-effective means to salmon recovery.
The SRFB Review Panel stated that many of the proposed projects would not need their funding if existing land management regulations were fully enforced. This comment applied to WRIA 22 and 23 as well as statewide. In many situations there are existing circumstances that enforcement will not correct. For example, in the case of culverts that are fish barriers, many are not required to be replaced until necessitated by normal maintenance schedules. If a culvert is due for replacement, only then is it required to meet fish passage standards. Where regulations are not being enforced, it is not realistic for the project sponsors to take on the responsibility of ensuring agency enforcement of existing laws. Monitoring and stewardship plans for each project would identify compliance problems in land management practices.
Recommendations
The CBP understands the difficulty the SRFB has in making these funding decisions. We also understand the SRFB is using the adaptive management concept in their funding decisions and will leam from comments provided after each funding cycle. We recommend that the SRFB adapt their funding criteria to favor the recovery of salmon especially in those watersheds that have the greatest likelihood for success. Watersheds that are more rural in nature have a greater probability of recovering salmon than more urban basins.
> The IAC/SRFB staff should work with Lead Entities to develop standards of what will be required in a Salmon Recovery Strategy . In the big picture, it is obvious that the intent is for the Lead Entity to formulate restoration strategies that are scientifically strong, locally supported, and monitored for success. However, the two entities need to work together to develop a recovery strategy. The SRFB could provide assistance to Lead Entities in developing a strategy that will work for each WRIA and is acceptable at both the state and local level. This assistance could be IAC/SRFB staff time or allocating funding to Lead Entities to hire staff to develop a strategy. This strategy must then be the accepted approach to recovery both at the local and state levels, and proposed projects must confon-n. Once this is established grant project sponsors will have a clear idea about the type of projects to develop and there will be a clear pathway to recovery.
Again, there was considerable discussion of this point during the workshop, especially the need for SRFB to provide both financial and technical support to Lead Entities to develop a recovery strategy for their watershed. We agree with the suggestion that the SRFB work with Lead Entities to establish monitoring protocols and identify who is accountable to monitor projects, Consistent monitoring will allow us to learn from past failures and successes and provide adaptive management of recovery strategies.
Accept local evaluation committcc project rankings as long as they follow guidelines described in the SRFB application and RCW 75.46. The local committee members know the watershed, have the expertise, are familiar with habitat degradation in the basin, and are experienced in local restoration successes and failures. Many local dollars and thousands of volunteer hours were committed to this grant process. Working with IAC/SRFB staff we spent countless hours coordinating projects, completing grant applications, developing a local review process and finally locally prioritizing our projects. Then we were hit with changes in evaluation standards and edits from top decision makers that appear to contradict the intent of the legislation. A common theme expressed during the workshop was the need for the SRFB to clarify the process and consistently adhere to that process from start to finish.
The IAC/SRFB's current practice of issuing contracts only on a cost-reimbursable basis needs to be reconsidered. In some cases, this requirement forces the sponsor to obtain a substantial line of credit thereby eliminating many nonprofit groups, volunteer groups and private citizens from participating. If the IAC/SRFB would adopt a policy of paying on receipts due, as with other granting organizations, then the complexity would be eliminated and it would be easier for volunteer and other organizations to participate. Another possible solution that was presented during the April 7th workshop was the allocation of funds through a block grant program.
We appreciate the opportunity to provide comments for your consideration of our recommendations in modifying the review process for the next phase of funding.
Robert Spahr
Chairman, Chehalis Basin Partnership
Chehalis Basin Partnership
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Meeting Summary- March 24, 2000
Introduction
Mayor Spahr welcomed members and opened the meeting.
Aftendance: Fourteen designated members or their alternates attended this meeting.
There were twenty additional partners, citizens, or visitors that attended.
Lead Agency Update (Agenda Item #1)
Contract with Envirovision for the Level 1 Assessment
Grays Harbor County is negotiating a contract with Envirovision for the remainder of the work the Partnership selected them to do. The first portion of the work (identifying existing information) has been completed under the proposed budget. The scope of work we are working on now will result in a evaluation of existing information and identification of gaps in existing information that need to be filled before we can develop a meaningful plan to manage water in the Chehalis Basin.
Salmon Recovery Funding Board
The final results from the SRFB are in, and two of the eight projects submitted for the Chehalis Basin will be funded. The first project is an off-channel habitat restoration project in the Newaukum River sub-basin. This project was ranked number 1 on the list the Partnership submitted to the SRFB. The second project that was funded is an estuarine habitat acquisition project in Grays Harbor off the mouth of the Humptulips River. This project was ranked number 6 on the Partnership's priority list.
There was a lengthy discussion about the results of the SRFB project selection process. Emphasis was placed on the following issues:
- - The level of dissatisfaction with the local and state processes used to select projects. Critics of the local process stated that they anticipate that steps will be taken that will address their concerns about the local prioritization process, however, they are very concerned about the state process and feel that it is completely unacceptable as it is currently being implemented.
Representatives from the Chehalis Basin Fisheries Task Force handed out a lengthy report they had prepared documenting the projects they proposed, explaining the problems they have with the process used to select projects and the reasons for their . dissatisfaction with the outcome. They will be sending this report to local legislative representatives and build support for legislative changes to the process.
There are strong concerns about the apparent bias against funding culvert replacement projects. Many feel that this is one of the quickest ways to open up habitat for fish that is currently inaccessible.
The state process was difficult to anticipate because it seemed to be changing as it was implemented.
There is a level of discomfort about the emphasis being placed on habitat acquisition. Public ownership will result in loss of tax revenue to local government and public access.
Appreciation of the work put into developing recovery project proposals by individuals and organizations, recognition of their concerns about the process, and the need to focus on developing a better process rather than placing blame.
The results support the importance of preparing both a detailed salmon recovery plan for the basin and a work plan to guide the Partnership in its implementation of the goals identified in the intergovernmental agreement used to form the Partnership. These plans would balance short-tem and long-term actions with anticipated results.
There will be an opportunity to provide oral and written comments to the SRFB about the project selection process. Grays Harbor County acting as administrative Lead Entity for the Partnership will coordinate preparing a comment letter.
2514 Watershed Planning Prooect Work Plan
A draft project work plan was distributed at the meeting. The Technical Advisory Committee (TAC) has been working on developing this Project Work Plan to help guide implementation of 2514 efforts and to help track results. Several possible formats have been examined. Two of those versions -- a schematic summary and a narrative description -- are being distributed today. The TAC needs direction from the Partnership. Is this type of document helpful, and should the TAC continue to develop the Project Work Plan? The Partnership agreed the having a Project Work Plan was very useful and that the TAC should continue work on it.
A brief discussion was held about the Technical Advisory Committee. The TAC is where the real detailed work on basin issues is done. The Partnership provides guidance to the TAC and approves its recommendations. If people want to be involved in the actual work they should become involved in the TAC. Margaret Rader is the Chair of the TAC. For more information contact Margaret (360) 273-6697, or Lee Hansmann (360) 249-4222.
Update on 2496 Limiting Factors Analysis (Agenda Item # 2)
Carol Smith presented information on the status of the 2496 Limiting Factors Analysis (LFA). The purpose of 2496 is to address salmon habitat restoration in a coordinated fashion. Limiting Factors are "conditions that limit the ability of habitat to fully sustain populations of salmon." Limiting Factors does not include the effects of hatcheries, hydropower generation, or harvest. A Technical Advisory Group (TAG) has been working with Carol but participation in the TAG by groups that should be involved has been limited.
Because the Chehalis Basin is so large, it was sub-divided into fifteen sub-basins for the purpose of preparing Limiting Factors Analysis. LFAs have been completed for the Satsop Sub-basin, the South Fork of the Chehalis Sub-basin, and the Upper Chehalis Sub-basin. Draft Limiting Factors Analysis for the Humptulips and the Estuary are being prepared. Common Limiting Factors include access to habitat, sedimentation, channel stability, presence of large wood in the stream to provide habitat and stabilize the system, and water quality.
Carol displayed a sample of the type of maps that would be generated after the LFA is complete. The plan is for the completed LFA to be available on a CD for general use.
CCWF/SRF Project Ranking (Agenda Item #3)
Water Quality project applications for state fiscal year 2001 grant/loan funds are due to the Department of Ecology by 5:00 p.m. on February 29th . Ecology has an established process for evaluating and ranking the proposals. In addition to this established ranking process, beginning last year each project is eligible for up to 1 00 additional points based on how the project is prioritized at the local level. Ecology uses these additional points when it calculates the project's overall rank on the state priority list. This local prioritization in optional, but if the Local Planning Unit (the Partnership) chooses not to do it then the projects from the Upper and Lower Chehalis will not receive the additional points. This puts them at a disadvantage when they are ranked on the statewide priority list.
Ecology's grant guidance establishes WRIA's as the geographic basis for determining which projects will be compared during the local ranking process. The Chehalis Basin contains two WRIAs (22 and 23) so we have to opportunity to develop two priority lists. At the January meeting the Partnership established a subcommittee to look at the local prioritization issue. The subcommittee recommends that the Partnership take on the responsibility of performing the local prioritization. Based on last years experience the subcommittee also recommends that projects from each WRIA be evaluated and ranked by a group made up of representatives from the other WRIA. For example, the projects in the upper basin (WRIA 23) would be ranked by a group of people who come from the lower basin. This will help to avoid the appearance of conflicts of interest that could occur when project proponents'are on the ranking committee.
The Partnership agreed by consensus that the local ranking should be done so basin projects benefit from having the additional points. A committee of six was appointed to carry out the local ranking and report the results back to the Partnership at the April meeting. The Partnership also agreed that the Chair (Mayor Spahr, Chehalis) should sign the letter submifting the local ranking so we can meet the April 14 deadline. A copy of the local priority list should be sent to all grant applicants and the five required entities identified in Ecology's guidance.
Report from Citizen's Advisory Committee (Agenda Item #4)
J. Roach arranged for DNR to present its work on Geographical Information.System (GIS) projects at the March 8 th CAC meeting. The Citizen's Advisory Committee recommends that the Partnership become formally involved in the Framework Process that DNR described at the February meeting. This would help support the move towards statewide GIS data compatibility and availability, and it would help the Partnership stay prepared to take advantage of the increasing ability to share GIS data/information.
At the March 8 th meeting the CAC members also discussed establishing a more formal organizational structure for the commiftee. This will be included on the agenda for the April 12 CAC meeting along with a discussion of "buffers." Any one interested in attending the April 12 meeting to hear about buffers is welcome. The meeting location has not been determined. If you are interested contact a CAC member or Kahle Jennings.
The Partnership agreed by consensus to become formally involved with the Data
Framework process. J Roach will be the primary contact.
Update on Flood Projects (Agenda Item #5)
Lewis County sent letters to its local legislative representatives urging them to coordinate the House and Senate Budgets to that the Upper Chehalis Flood project is funded. The Senate budget includes $1.55 million for the project.
Open Comment (Agenda Item # 6)
Nancy Winters (SAIC) announced that a demonstration of SAIC's web-based information clearing house that allows information/data to be accessed over the internet, displayed and analyzed will be held at the Ecology building on April 26 th from 9:00 until noon. For information on the meeting location contact Nancy Winters (360) 357-7377 or Kahle Jennings (360 407-631 0. The staff that developed this package will be in town to demonstrate it.
Wrap-up/Adjourn
The next Chehalis Basin Partnership meeting will be held on Friday April 28, 2000 at the Chehalis Tribal Center from 9:00 to 11-:30 a.m.
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April 12, 2000 Citizen's Advisory Committee Meeting Suffimary
Present: - -
| >(Thurston County) | Margaret Rader, J Roach, Earl Emerson |
| (Lewis County) | Rob Schanz, Bill Barmettler |
| (Grays Harbor County) | Floyd Ruggles, Jim Welch, Brian Blake |
| (Mason County) | Jim Bottorff |
| (General) | Kahle Jennings |
| Guest Speaker: | Dick Wallace |
Buffers: - - Dick Wallace, currently working for Ecology's Water Quality Program, represents the agency interests with various entities such as the State Forest Practices Board and the Agriculture, Fish & Water negotiations, so his knowledge of buffers is wide-ranging. Dick set more information in front of us than can be effectively summarized, so I'll try to hit the main points.
Dick explained that SPTH (site potential tree height) and LWD (large woody debris) are two determinants of buffer size. These two go hand in hand. The amount and size of LWD is determined by several factors, such as SPTH, and the size and energy of the stream. LWD is beneficial in fish-bearing and non-fish-bearing streams.
Recently, recommendations have been finalized under the Forest & Fish Agreement. The F&F Agreement uses new definitions for stream types, but uses the old definitions. Types 1-3 (fishbearing streams) will have different protections than Types 4-5 (non-fish bearing).
Types 1-3 will have three zones:
ú - - A 50' no-cut zone closest to the CMZ (channel migration zone)
ú - - An inner zone (for streams > 1 O' wide, 3/4of SPTH, streams < 1 O', 2/3 of SPTH)
ú - - An outer zone (20 trees remaining per acre).
For Type 4, there is a 50' wide no-cut zone for 50% of the total length of the stream (the first 500' at the transition to fish-bearing waters must be buffered), and a 30' wide equipment exclusion zone throughout.
For Type 5 there is a 30 'wide equipment limitation zone.
In both cases, special sites (springs, unstable grounds, and amphibian habitat) are identified
which may receive greater protections.
Agriculture/FishMater negotiations are ongoing, and Dick emphasized that talk is centering on function, not just size, The Tri-County Agreement (Piece, King, and Snohomish counties) will have specifications for buffers. The Tri-County Agreement is largely driven by the ESA listings.
There were questions about differences between agricultural land and forestland buffers. We talked about CREP (Conservation Reserve Enhancement Program), the voluntary program that compensates private landowners for moving agricultural activities outside of riparian zones. We also discussed programs that might motivate NIPF (non-industrial private forest) owners to set aside, and in some cases actively rehabilitate, riparian zones.
The group discussed intentional replacement of LWD in streams, and hardwood vs. conifer LWD. During this discussion it was mentioned that new information suggests hardwood LWD, such as alder, may be more beneficial than previously believed. We talked about temperature TMDL'S, which because they involve restoration of shade along riparian areas will be more complicated to fix than the more common TMDL's which address some specific source of pollution.
There was some discussion of buffers and the potential for blowdown. There appears to be some level of skepticism amongst the public regarding buffers, especially when the first windstorm knocks all the trees down. It was explained that this was largely a result of the earliest buffers, which were 25' foot strips without any transition from clear-cut to trees.
The group thanked Mr. Wallace for his excellent information. There are two documents that we
may want to look into obtaining for the Partnership Library. One is widely known as the
"ManTech Report", TR-4501-96-6057, written for NMFS. The best starting point might be NMFS's website. The other is "Riparian Area Management", BLM Technical Reference 1737-15 1998. Copies are available from: BLM National Business Ctr., BC-650B, POB 25047, Denver, CO 80225-0047. BLM's website may be a better place to start.
The group turned to establishing a chair, vice-chair, and secretary. We examined the CBP interim by-laws. Section VII, "Advisory Committees", third paragraph, first sentence, appears to limit the position of chair to Partnership members. We interpreted this to indicate that our choices were limited to the four voting members on the CBP. The CAC would like to have the freedom to appoint any citizen member to the chair, but we're not sure if we have the freedom to do so. There was also some discussion of Section 11, "Partnership Composition and Quorum". The wording is not very clear, but we agreed that this section doesn't affect the CAC directly, so we moved on. Rob Schanz, Lewis Co. citizen, was appointed chair. J Roach, Thurston Co. citizen, was appointed vice-chair. Bill Barmettler, Lewis Co. citizen, was appointed secretary. We did not discuss length of terms. We can address that later. There was some discussion of how we will approach consensus, using the guidelines in the by-laws as a starting point. It was agreed that we are not bound by these guidelines. Consensus may not be attainable in some cases.
Next month: The agenda will include work-plan/strategic planning for CBP. Jim Bottorff will attempt to line up a speaker who has been involved in a Skagit Valley Watershed project. He'll contact Rob and Kahle with a "yea" or "nay". Tentative date is May 1 olh, 9:00 AM, Centralia/Chehalis area. Kahle will line up a room and send out announcements
Jim Boftorff gave us a review of "Salmon without Rivers", by Jim Lichatowich. This led to talk about salmon recovery in general and hatcheries in particular. It was suggested that we might look into lining up a speaker who could address issues related to hatcheries.
Recorder: Bill Barmeftler
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