Proposal 199206105: Albeni Falls Wildlife Mitigation - Kootenai Tribe O, M and E

1. Administrative
2. Location
3. Species
4. Past accomplishments  
5. Relationships
6. Objectives
7. Work elements   
8. Budget
9. Future
10. Narrative

Organization: Kootenai Tribe of Idaho

Short description:
Protect, restore, enhance, and maintain wetland and wildlife habitat in Pend Oreille and Kootenai Subbasins as ongoing mitigation for impacts associated with the construction and innundation of the Albeni Falls hydroelectric project.

Contacts

Contact nameRoleAddressPhoneEmail
Scott Soults Project Lead Kootenai Tribe of Idaho
County Rd. 38A P.O. Box 1269
Bonners Ferry ID 83805
208.267.3620 soults@kootenai.org

Section 2. Location

Province: Intermountain Subbasin: Pend Oreille

Specific locations

Lat/longLocation descWaterbody (lake or stream)County/StateSubbasinResolutionPrimary?
48.8442, -116.4000 Trout Creek Peninsula - KTOI Kootenai River Boundary Kootenai point No
48.7597, -116.0976 Perkins Lake - KTOI Perkins Lake Boundary Kootenai point No

Section 3. Species

Primary: Wildlife: All Wildlife

Additional species: Bald Eagle, Black-capped Chickadee, Canada Goose, Mallard, Muskrat, Redhead, White-tailed Deer, and Yellow Warbler

Section 4. Past accomplishments

FYAccomplishment
1988 Completed Albeni Falls Protection, Mitigation, and Enhancement Plan as part of UCUT.
1998 KTOI started wildlife mitigation program as part of the Albeni Falls Wildlife Mitigation Project Work Group.
1999 Assisted in Work Group activities in which the members participate include: 1) coordination, preparation, and review of project proposals; 2) as needed meetings; scope of work and budget development; and, 3) public open houses.
2001 Initiated, organized and facilitated the citizens group called the Kootenai Valley Resource Initiative and assessed of vegetation communities on the Kootenai River riparian system and finalized Albeni Falls Wildlife Mitigation Project M&E Plan.
2002 Protected 211 acres and 185.38 HUs of wetland and riparian habitat in Boundary County, ID.
2003 Developed a process to designate restoration and conservation priorities and models for wetland/riparian restoration and conservation, finalized HEP survey and report.
2004 Integrated HEP reports into site-specific management plans.
2005 Developed the Conservation Alternatives Plan, and work with UCUT to plan UWMEP coordination.
2007 Assisted in the development of a water elevation model to calculate river elevations on mitigations sites related to restoration activities, and implement UWMEP for M&E and budget calculations for each AFIWG member.
2008 Finialized Appraisal, ESA phase 1 (w/BPA), Cultural Survey, reviewed Engineering survey, and submitted PSA for acquisition in early 2009.

Section 5. Relationships to other projects

Funding sourceProject IDProject TitleRelationship
BPA 200800700 UCUT Wildlife Monitoring and Evaluation Project Implement field crew, surveys of reference sites, permanent sample sites and collect HEP and HU data for Albeni Falls Wildlife Mitigation Project member lands related to wildlife mitigation crediting.
BPA 199106000 Pend Oreille Wetlands Acquisition Partial mitigation (~ 1,300 HUs) for Albeni Falls Dam losses
BPA 200103300 Hangman Watershed Acquisition 2004 and 2005 one time habitat acquisitions charged to Albeni Falls Dam
BPA 200201100 Kootenai River Floodplain Ecosystem Operational Loss Assessment, Protection, Mitigation, and Rehabilitation Data, surveys, research overlap with Albeni Falls Wildlife Mitigation Project mitigation areas.
Other: Avista Clark Fork Dams Clark Fork Delta habitat protection/enhancement Like actions to protect/enhance wetland and riparian habitats in the Clark Fork Delta
BPA 199004400 Coeur D'Alene Reservation Habi Provided floodplain and instream habitat enhancements that benefited AFD wildlife project HU contributions to BPA

Section 6. Objectives

Objective titleDescriptionRelevant subbasin planRelevant strategy(ies)Page number(s)
1) Protect 2,200 ac. of in-kind habitat by FY 2012 1a) Coordinate the Albeni Falls Interagency Work Group, 1b) Identify willing landowner participants, 1c) Coordinate with the AFIWG, UCUT, BPA, NPPC, FERC and CBFWA members, 1d) Identify cost-sharing partnerships, 1e) Complete federal compliance requirements (appraisal, environmental survey, cultural resource survey, etc.), 1f) Complete NEPA requirements, 1g) Complete HEP report, credit BPA with HU’s and develop site management plan. (All) INTERMOUNTAIN - Identify and protect habitat through fee title acquisition, conservation easements, lease, or management agreements. KOOTENAI: RP3-Secure mgmt rights, implement mgmt agreements to conserve, maintain and restore riparian/floodplain areas. ISBP p18-31 & KSBP p79
2) Enhance >904 acres of inkind habitat by FY 2012 2a) Reestablish native vegetation, 2b) Conduct prescribed burns to increase forage and vegetative diversity, 2c) Create nesting islands to increase nesting habitat, 2d) Restore hydrologic function to increase and enhance riparian and wetland habitats, 2e) Construct fences and gates, remove interior fences to control access and reduce human and livestock disturbance, 2f) Inventory and control noxious weeds, 2g) Increase riparian and wetland diversity and density, 2h) Stabilize shorelines to reduce erosion, 2i) Review enhancement designs, 2j) Complete permit applications and environmental compliance documentation, and 2k) Coordinate with the Albeni Falls Interagency Work Group. (All) INTERMOUNTAIN - Develop/implement mgmt plans consistent w/CBFWA Guidelines for Enhancement, Operation, & Maintenance Activities for Wildlife Mitigation Projects KOOTENAI: WB1 Cooperate/coordinate effort to protect, enhance & rehabilitate riparian habitat. ISBP p18-13 & KSBP p73-74
3) Maintain 3,100 acres through FY 2012 3a) Control noxious weeds to maintain habitats suitable for populations associated with the target species, 3b) Maintain brood pastures, 3c) Maintain habitat improvements, 3d) Maintain gates and fences, 3e) Maintain water control structures, 3f) Control nuisance animals, 3g) Manage public access and minimize human disturbance, 3h) Implement seasonal closures, 3i) Maintain open water and pasture for brood habitat, 3j) Debris removal, and 3k) Coordinate with the Albeni Falls Interagency Work Group. (All) INTERMOUNTAIN: Ensure long-term protection, enhancement, & monitoring of habitat units through secured funding for O&M. KOOTENAI: RP3 - Secure mgmt rights, implement mgmt agreements to conserve, maintain and restore riparian/floodplain areas. ISBP p18-32 & KSBP p79
Monitor & evaluate wildlife/habitat/mgmt to FY2012 4a) Conduct 5-year HEP to determine increase in HUs from enhancement activities, 4b) Monitor burned areas at regular intervals, 4c) Monitor vegetative response to herbivory, planting prescriptions and water level manipulations, 4d) Amend and update management plans as necessary and 4e) Coordinate with the AFIWG and UWMEP project. (All) INTERMOUNTAIN: Ensure long-term protection, enhancement, and monitoring of habitat units through secured funding for O&M. KOOTENAI: AP2-Provide for adequate regional participation & feedback in decision making processes that will impact fish and wildlife. ISBP p18-32 & KSBP p90

Section 7. Work elements

Work element nameWork element titleObjective(s)Start dateEnd dateEstimated budget>Sponsor performs work?
Coordination 1a) Coordinate the Albeni Falls Interagency Work Group 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 43,522 Yes
Description: Coordinate activities with and between AFIWG members. This will include rotational meetings, minutes, agendas, ranking projects, maintaining records, etc.
Conduct Pre-Acquisition Activities 1b) Identify willing landowner participants 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 21,755 Yes
Description: Identify willing sellers and pursue projects based upon landowner response.
Coordination 1c) Coordinate with the AFIWG, UCUT, BPA, NPPC, FERC and CBFWA members 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 26,112 Yes
Description: Coordinate activities with local and regional entities to best implement project goals and objectives.
Identify and Select Projects 1d) Identify cost-sharing partnerships 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 4,351 Yes
Description: Identify and secure cost share when appropriate and feasible, while maintaining strict guidelines for BPA crediting
Conduct Pre-Acquisition Activities 1e) Complete federal compliance requirements (appraisal, environmental survey, cultural resource survey, etc.) 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 108,777 Yes
Description: Meet BPA federal requirements to purchase management rights which includes appraisal, ESA site assessment, cultural resource survey, title report, engineering survey, PSA, etc.
Produce Environmental Compliance Documentation 1f) Complete NEPA requirements 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 52,213 Yes
Description: NEPA checklist/compliance for pre-acquisition.
Produce Other Report 1g) Complete HEP report, credit BPA with HU’s and develop site management plan 1) Protect 2,200 ac. of in-kind habitat by FY 2012 10/1/2010 9/30/2012 95,723 Yes
Description: Identify, survey and report HU’s onsite, and develop site-specific management plans to outline goals and objectives for enhancements, O&M, M&E and related activities.
Plant Vegetation 2a) Reestablish native vegetation 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 43,500 Yes
Description: Use native plant and seed materials to plant denuded areas on project sites to minimize erosion and noxious weed invasion. Use native plant materials to change altered habitats to native habitat types by increasing deciduous tree density/diversity (i.e., supplemental planting, aspen release, cottonwood release), riparian reforestation (active and passive), and shoreline/grassland revegetation (i.e., shrub and grasses).

Metrics:
# of riparian acres treated: 25 annually

Conduct Controlled Burn 2b) Conduct prescribed burns to increase forage and vegetative diversity. 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 15,000 No
Description: Burn approximately 50 acres each fall/spring.

Metrics:
# of upland acres treated: 50 annually

Create, Restore, and/or Enhance Wetland 2c) Create nesting islands to increase nesting habitat 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 15,000 No
Description: Add wetland nesting features to project sites according to approved management plans. Add diversity and density to project wetlands.

Metrics:
# of riparian acres treated: 1 ac annually

Enhance Floodplain/Remove, Modify, Breach Dike 2d) Restore hydrologic function to increase and enhance riparian and wetland habitats 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 142,500 No
Description: Consistent with site-specific management plans, restore hydrologic function by plugging ditches, installing upgraded culverts, installing water control structures, etc.

Metrics:
# of riparian acres treated: 25 annually

Install Fence 2e) Construct fences and gates, remove interior fences to control access and reduce human and livestock disturbance 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 30,456 Yes
Description: Build 1 miles of exterior boundary fence and gates, remove 5 miles of interior fence to protect each project property

Metrics:
# of fence miles treated in a riparian area: 2 miles annually

Remove vegetation 2f) Inventory and control noxious weeds 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 54,000 No
Description: Spray, pull, mow or by other means remove noxious weeds from properties as required by local laws and regulations.

Metrics:
# of upland acres treated: 200 annually

Enhance Floodplain/Remove, Modify, Breach Dike 2g) Increase riparian and wetland diversity and density 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 31,328 Yes
Description: Using hand and mechanical equipment and methods, increase riparian and wetland diversity and density on project lands.

Metrics:
# of riparian acres treated: 20 annually

Enhance Floodplain/Remove, Modify, Breach Dike 2h) Stabilize shorelines to reduce erosion 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 135,000 Yes
Description: Where necessary stabilize 900 feet of eroding shoreline with bio-engineered designs. Where non-renewable resources exist, provide for hard stabilization techniques. Add large woody debris to project for habitat value and floodplain roughness. Where feasible stabilize shorelines in the Kootenai River to protect habitat from wind-wave erosion and damage and reduce ongoing and future riparian losses.

Metrics:
# of riparian acres treated: * # of feet of shoreline: 300 annually

Provide Technical Review 2i) Review enhancement designs 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 26,100 Yes
Description: Review and comment on designs for enhancements for all AFWG members.
Produce Environmental Compliance Documentation 2j) Complete permit applications and environmental compliance documentation 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 30,457 Yes
Description: Complete applications for local, state and federal permits necessary to complete enhancement actions. Provide information and permits to BPA for environmental compliance.
Coordination 2k) Coordinate with the Albeni Falls Interagency Work Group 2) Enhance >904 acres of inkind habitat by FY 2012 10/1/2010 9/30/2012 8,704 Yes
Description: Coordinate all work group activities for enhancing BPA project lands to maintain consistency and meet broader habitat goals.
Maintain Vegetation 3a) Control noxious weeds to maintain habitats suitable for populations associated with the target species 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 43,511 Yes
Description: Maintain low levels of occurrence by noxious weeds by various methods of control.
Maintain Vegetation 3b) Maintain brood pastures 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 13,053 Yes
Description: Mow or burn pasture to maintain optimum brood rearing pasture height between 4 and 16 inches.
Maintain Vegetation 3c) Maintain habitat improvements 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 30,464 Yes
Description: Maintain plantings in riparian, wetland and near shore areas.
Install Fence 3d) Maintain gates and fences 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 8,700 Yes
Description: Maintain boundary fence on project lands

Metrics:
# of fence miles treated in a riparian area: 5 miles maintained annually

Operate and Maintain Habitat/Passage/Structure 3e) Maintain water control structures 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 26,107 Yes
Description: Operate and maintain water control structures with moist soil management principles.
Remove or Relocate Non-predaceous Animals 3f) Control nuisance animals 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 7,832 Yes
Description: Trap, remove and/or relocate nuisance animals that detract from project goals.
Manage and Administer Projects 3g) Manage public access and minimize human disturbance 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 23,496 Yes
Description: Provide for information and signage to control public access and identify seasonal closures and property specific rules for access.
Investigate Trespass 3h) Implement seasonal closures 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 6,962 Yes
Description: Minimize human disturbance to nesting waterfowl and other target and non-target species during critical life history periods.
Operate and Maintain Habitat/Passage/Structure 3i) Maintain open water and pasture for brood habitat 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 30,457 Yes
Description: Maintain open water complexes and pasture heights for waterfowl brood rearing habitat.
Remove Debris 3j) Debris removal 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 17,404 Yes
Description: Remove posts, junk, tires, etc. from shorelines, roads and general project lands to maintain safety and habitat value.
Coordination 3k) Coordinate with the Albeni Falls Interagency Work Group 3) Maintain 3,100 acres through FY 2012 10/1/2010 9/30/2012 30,450 Yes
Description: Coordinate O&M activities between and among the AFIWG members to reduce duplication, transfer knowledge and increase cost efficiencies.
Prepare HEP Report 4a) Conduct 5-year HEP to determine increase in HUs from enhancement activities Monitor & evaluate wildlife/habitat/mgmt to FY2012 10/1/2010 9/30/2012 41,755 No
Description: Conduct HEP on 5-year intervals to collect and interpret data and submit report to BPA for enhancement crediting in association with UWMEP contract.
Collect/Generate/Validate Field and Lab Data 4b) Monitor burned areas at regular intervals Monitor & evaluate wildlife/habitat/mgmt to FY2012 10/1/2010 9/30/2012 22,626 Yes
Description: Monitor annual prescribed burns for timing and effectiveness. Use observations and vegetative sampling techniques to determine effectiveness of burning and potential modifications to timing and technique.

Metrics:
Secondary R, M, and E Type [Status and Trend Monitoring, Action Effectiveness Research, Uncertainties Research, Project Implementation/ Compliance Monitoring]: Monitor 50 acres annually following prescribed burning

Collect/Generate/Validate Field and Lab Data 4c) Monitor vegetative response to herbivory, planting prescriptions and water level manipulations Monitor & evaluate wildlife/habitat/mgmt to FY2012 10/1/2010 9/30/2012 20,885 Yes
Description: Monitor vegetative response using standard techniques and alter hydrologic management strategies consistent with information acquired for increased long-term vegetation success.

Metrics:
Secondary R, M, and E Type [Status and Trend Monitoring, Action Effectiveness Research, Uncertainties Research, Project Implementation/ Compliance Monitoring]: Monitor reestablishment of vegetation

Provide Technical Review 4d) Amend and update management plans as necessary Monitor & evaluate wildlife/habitat/mgmt to FY2012 10/1/2010 9/30/2012 30,460 Yes
Description: Based upon HEP and M&E plan data update, review site-specific management plans and in association with UWMEP.
Coordination 4e) Coordinate with the AFIWG and UWMEP project Monitor & evaluate wildlife/habitat/mgmt to FY2012 10/1/2010 9/30/2012 13,053 Yes
Description: Coordinate M&E activities between and among AFIWG members in association with UWMEP.
work element budget total: 1,251,713

Section 8. Budget

Item Note FY 2010 cost ($) FY 2011 cost ($) FY 2012 cost ($)
Personnel Project personnel 1.5 FTE and 2.5 FTE in 2012 55,288 56,671 105,262
Fringe Benefits Average ~60% fo salaries 34,519 35,382 57,777
Overhead Indirect: Only applied to salaries and fringe benefits (adjusted annually) 53,731 55,076 97,546
Travel Travel for project management, training and implementation 2,521 2,521 2,921
Other Equipment maintenance (repair vehicles, fuel, tires, oil change, etc.) 2,395 4,395 13,795
Other Rent/Utilities: Facilities rental, communications and utilities 5,400 5,400 5,400
Supplies Office/field supplies and materials related to enhancement, O&M and M&E 8,128 17,380 10,400
Capital Equipment One-time equipment purchase (tractor, implements, etc.) 26,000 9,000 9,000
Other Weed Control Services 21,000 18,000 15,080
Other Contract to re-establish vegetation 8,750 10,850 12,875
Other Pre-acquisition costs: appraisals, cultural resource surveys, engineering surveys, title reports, etc. 23,000 25,000 25,000
Other Contract for M&E and HEP surveys and services (UWMEP #200800700) 18,250 18,250 18,250
Other Contract hydrology assessment, restore wetlands and shoreline erosion control 97,500 117,500 77,500
Other Contract for legal services 15,000 15,000 18,000
Other Contracts for prescribed burning, water tender, and road maintenance 7,000 7,000 7,000
Itemized budget totals: 378,482 397,425 475,806
Type of funding source Funding source or organization Item or service provided FY 2010 est value ($) FY 2011 est value ($) FY 2012 est value ($) Cash or in-kind? Status
federal EPA Section 319 funds - shoreline stabilization 10,000 10,000 10,000 Cash Under Development
tribal Kootenai Tribe Legal Services 5,000 5,000 5,000 In-Kind Confirmed
tribal Kootenai Tribe Computer, GIS and Training 2,000 2,000 2,000 In-Kind Confirmed
Cost share estimate totals: 17,000 17,000 17,000

FY 2010-12 total cost share estimate: 51,000

Section 9. Project future

Outyear budgets 2013 2014 2015 2016 2017 2018
487,700 487,700 439,700 400,000 400,000 400,000

Note
Project costs include O&M, enhancements, M&E, and acquisition of land to meet HU mitigation for Albeni Falls Dam.

Likely project termination/end date: 2105

Termination notes:
Project will terminate 50 years after the decommissioning of the Albeni Falls Dam Project.

Final deliverables:
Annual reports, HEP reports, Management Plans, M&E reports and database management

Reviews

ISRP final recommendation: Meets Scientific criteria? Yes

This is a well designed and implemented project. Taking the time upfront for the types of planning and prioritizing demonstrated will ultimately make the project much more effective. Choosing to involve the public and to cultivate partnerships is also a wise investment in project success. This project demonstrates not only sound science, but sound planning practice as well. 1. Technical justification, program significance and consistency, and project relationships: These sections are well organized and make a compelling case. The project is related to subbasin plans and other relevant plans and programs. 2. Project History and Results This is a very useful history with sufficient results in terms of data and interpretation to illustrate scientific credibility of the project. This could be used as an example in the Albeni Falls group for results reporting. 3. Objectives, work elements, and methods These are well described, and the choice of methods is based upon work that is often site-specific. Adaptive management is already evident. We suggest looking at more recent references for noxious plant management – there has been great progress since 1988. For example biological control, targeted grazing and new understanding of plant life histories should be considered. The problems with funding options to purchase and reaching traditional agricultural land owners with education on easements might be assisted by the American Farmland Trust, if you have not investigated this possibility already. Also UI Forestry Extension does easement workshops for landowners and might be a good partner in this effort. 4. M&E The sponsors monitor burned area vegetation response and evaluate water level response of vegetation. The same new approach as other Albeni Falls tribal projects, working with UWMEP, is proposed. However, they have some specific objectives for Trout Creek parcel including 4 sampling locations and present some data including avian point count data 2005-2008, invertebrate data 2005-2008, fine scale habitat data (p.34). The sponsor's strong commitment to M&E is obvious from the beginning of the project, in spite of logistic changes along the way. Results reporting in project history and appropriate discussion of monitoring in other sections demonstrate a sophisticated understanding of the value of monitoring in long-term projects. These data will contribute to increasing project effectiveness and efficiency over time.

from May 19, 2009 ISRP 2009-17 report

ISRP preliminary recommendation: Meets scientific criteria? Yes

This is a well designed and implemented project. Taking the time upfront for the types of planning and prioritizing demonstrated will ultimately make the project much more effective. Choosing to involve the public and to cultivate partnerships is also a wise investment in project success. This project demonstrates not only sound science, but sound planning practice as well. 1. Technical justification, program significance and consistency, and project relationships: These sections are well organized and make a compelling case. The project is related to subbasin plans and other relevant plans and programs. 2. Project History and Results This is a very useful history with sufficient results in terms of data and interpretation to illustrate scientific credibility of the project. This could be used as an example in the Albeni Falls group for results reporting. 3. Objectives, work elements, and methods These are well described, and the choice of methods is based upon work that is often site-specific. Adaptive management is already evident. We suggest looking at more recent references for noxious plant management – there has been great progress since 1988. For example biological control, targeted grazing and new understanding of plant life histories should be considered. The problems with funding options to purchase and reaching traditional agricultural land owners with education on easements might be assisted by the American Farmland Trust, if you have not investigated this possibility already. Also UI Forestry Extension does easement workshops for landowners and might be a good partner in this effort. 4. M&E The sponsors monitor burned area vegetation response and evaluate water level response of vegetation. The same new approach as other Albeni Falls tribal projects, working with UWMEP, is proposed. However, they have some specific objectives for Trout Creek parcel including 4 sampling locations and present some data including avian point count data 2005-2008, invertebrate data 2005-2008, fine scale habitat data (p.34). The sponsor's strong commitment to M&E is obvious from the beginning of the project, in spite of logistic changes along the way. Results reporting in project history and appropriate discussion of monitoring in other sections demonstrate a sophisticated understanding of the value of monitoring in long-term projects. These data will contribute to increasing project effectiveness and efficiency over time.

from Mar 26, 2009 ISRP 2009-7 report