Comments on the Pacific Northwest Aquatic Monitoring Partnership's (PNAMP) Draft Recommendations for Monitoring in Subbasin Plans

At the Council staff and PNAMP's request the ISRP/AB reviewed PNAMP's draft "Recommendations for Monitoring in Subbasin Plans" which is intended to provide guidance to help support the design of the monitoring element of the subbasin plans being developed under the Fish and Wildlife Program of the Northwest Power and Conservation Council (Council). The ISRP/AB completed this review in less than a week with the understanding that time was of the essence to allow for revisions and timely distribution of the PNAMP document. Given the time constraints, this review is intended to spot key issues and provide quick feedback on how the guidance document can be improved to best serve subbasin planners. The review is limited to the draft document at hand and in no way constitutes a larger review of the PNAMP or subbasin planning efforts.

Summary

The ISRP/AB agrees with PNAMP on the benefits of consistent, coordinated monitoring in the Columbia River Basin. Consistency and coordination across subbasins will generate ongoing value for the region. The issue is how best to achieve these benefits. As written, this document may damage, rather than promote, coordination.

The ISRP/AB recommends that the PNAMP revise its "Recommendations for Monitoring in Subbasin Plans" to present a more collaborative approach designed to build incentives for coordinated monitoring across subbasins. The document could be more effectively structured as a forward-looking strategic framework plan to work not only with current members of the "Partnership", but also with subbasin planners to develop region-wide monitoring that generates value to all. The document could include a discussion of the benefits at each scale (subbasin, province, state and region) of a collaborative approach.

We recommend that in revising the document the authors explicitly address these general issues as well as the specific raised below.

1. Authority and tone of the document: The tone of the document should be softened to convey collaboration. Also, the document should clearly indicate what authority, if any, PNAMP has over M&E in the Columbia River Basin. Despite some statements acknowledging that both bottom-up and top-down processes are in play (cf. p.4), the document is nevertheless full of directives to subbasin planners. While the ISRP/AB has recognized the need for a more top-down approach in planning for monitoring, the political reality is that both exist. The document could acknowledge the general difficulty of making changes in ongoing monitoring programs (including those that may be introduced in plans as a result of the ground-up approach in subbasin planning). There should be a more substantive plan for Tribal and State representatives to the Partnership to coordinate with subbasin planners.2. The timing of the document: From the beginning of the subbasin planning process, subbasin planners have been provided with technical guidance for the content of assessments, inventories and plans. Unfortunately, the technical guidance was probably inadequate to promote the consistent, coordinated monitoring that is obviously needed for the combination and contrast of data at the Tribal Lands, States, Provinces, and Columbia Basin levels. We believe that PNAMP documents could provide needed guidance at these scales if relationships with, e.g., the Northeast Oregon Hatchery M&E Plan, the Action Agency's RME Plan, the Yakima Supplementation M&E, and NOAA Fisheries' proposal for pilot status and trend monitoring in three subbasins were more clearly presented. Parts of these documents could provide useful models for the type of M&E program being promoted by PNAMP, and coordination of new monitoring efforts (e.g., subbasin plan elements) with these existing plans and actions could economically produce larger-scale coordinated sampling programs. However, for the PNAMP document to be delivered in its present form without adequate integration with other plans and at the last stage of the planning process may be counter-productive. The document may be viewed as an unattainable last-minute attempt to add value to the subbasin planning process for those charged with ESA monitoring responsibilities at multiple subbasin scales.

The May 28 submission deadline for subbasin plans is near. The document will probably be more effective if it acknowledges up front that its recommendations are too late to be considered in the first submission of subbasin plans.

3. The "bottom-up" and "top-down" relationship: The relationship between the two should be clarified. As written, the document may be viewed as strictly a top-down message from PNAMP. However, the subbasin planning process was presented from the outset as a bottom-up process. Various concerns including those of the ISAB/ISRP have been raised throughout the process about the potential difficulties of "rolling up" and coordinating the 62 plans developed through bottom-up processes into internally consistent province-wide and basin-wide approaches. These concerns have been acknowledged by the Council, which has at the same time reaffirmed the bottom-up approach. Technical guidance and Council coordination has been provided to subbasin planners as a means of encouraging cross-basin consistency.4. The scope of monitoring: The document notes that the original focus of PNAMP was to coordinate monitoring of watershed condition, but has recently expanded to include status/trend and effectiveness monitoring in relation to anadromous fish. In addition the statement is made that at some future date PNAMP may be able to coordinate monitoring of resident fish and wildlife. Although this statement is a bit premature and authoritarian in tone, much of the general guidance provided is equally applicable to monitoring of resident fish and wildlife and their habitats. The document should more clearly indicate where general principles of sampling and monitoring of terrestrial and aquatic species/habitat leave off and extremely specific recommendations applicable to anadromous species and their habitats take over.5. Checklist: PNAMP recommendations on the review Checklist are often vague. The detailed technical considerations are difficult to understand, and perhaps inadequate to introduce planners who are not trained in statistical methods to the needed logical framework or terminology.6. Confusing and Premature Information: The basis or references for some information should be given. For example, a list of core attributes (indicators) to monitor is given without references, and also with a caution that this set of attributes has not been reviewed by PNAMP. Similarly, it is stated that PNAMP is hoping to evaluate competing measurement protocols without reference to what alternative protocols would be compared and in 2005, which is presumably too late to influence plans developed in 2004. The document also at times gives specific guidance that appears to be premature, given the current lack of coordinated design and effort. For instance, the definitions of "reach" that are stated appear to imply distinct sampling designs and efforts for effectiveness and status/trends monitoring, but it seems likely that a more efficient monitoring design could be developed to allow the same samples to contribute flexibly to both effectiveness and status-trends monitoring.7. Implementation of document recommendations: The process might usefully begin with a workshop at which critical uncertainties identified in each subbasin plan are identified and a plan is collaboratively developed to address those uncertainties that cross subbasins. Workshop emphasis could be on identifying commonalities and crafting an approach to monitoring that identifies respective roles and responsibilities and provides motivation to the subbasins through benefits to be gained from collaboration.

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