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# Review of Draft: "An ecosystem-based restoration plan with emphasis on salmonid habitats in the Columbia River Estuary" (Draft Estuary Plan Review)

## 

        - Sep 8, 2003
        - Erik Merrill
        - ISRP 2003-13

Authors:

In response to Bonneville Power Administration's July 15, 2003 memo from Christopher Furey, the ISRP reviewed the draft report, "An ecosystem-based restoration plan with emphasis on salmonid habitats in the Columbia River Estuary." We appreciate the opportunity to review a draft report; hopefully some objective feedback can assist to improve the clarity and focus of this report.  The BPA initial memo suggested some questions to address.  In this review, we present our summary comments first and then address the questions.  We have chosen to limit the number of editorial comments on the text as our primary concerns are at a higher level of content.

**Summary**

Overall, there are project planning and process aspects of this report that the ISRP liked, and we support the overall intention to address Columbia River Estuary (CRE or estuary) habitat restoration from an ecosystem perspective.  However, we have several significant concerns with this draft that limited our ability to fully review or appreciate the objective of this work.  We believe these would also limit the utility of this report for subbasin planners, and others in the Columbia River Estuary community.  Our principal concerns were:

1) The intended purpose of the report is unclear.  The report is clearly not a "Restoration Plan" (as it is referred to frequently); possibly it is a planning document to establish such a plan or it may be an administrative guideline for project prioritization and selection.  The uncertainty about the report's purpose was the overwhelming concern of the reviewers who concluded that without a clear objective it was difficult to provide constructive advice on the content.

2) While Section 2.0, Scientific Basis, discussed several aspects of ecological restoration, the material lacks an adequate description of the various fish resources and the priority they may have under RPA 159.  We do not see how a habitat plan that "addresses RPA Action 159" (page 1) can be developed, projects selected, etc. without a detailed understanding of what resources can be "addressed" in the estuary, or how to select projects without specific goals for recovery of these fish resources.  What species use the estuary, what priority should be assigned to those species, and how is life history diversity related to use of estuary habitats?  The document has minimal discussion of the species but does refer to life history types (ocean versus stream fishes).  It does not provide much information on the habitats used by the species and life history types.

We have a concern that life history variation is equated to genetic variation (although not explicitly stated).  It is possible that the life history diversity that people presume is lost (loss of genetic variants) is actually not observed because of a limited opportunity for expression and the lack of habitat complexity or types.  This is vaguely referred to as a research issue on page 32.  If one assumes that the diversity has a genetic basis, and that assumption is wrong, the cost of this assumption is that the diversity and resulting production may never recover as the necessary habitat restoration may not occur (no fish remaining to use it!).  Consequently, unless a stronger basis for such a presumption is available, we would encourage the authors to emphasize habitat restoration first, provide the opportunity for expression, and then to assess diversity over time.  The genetic basis of the observed diversity may be very difficult to determine, but the first concern should be to restore the numerical productivity of these listed salmon species/stocks.

While we support the intention to improve ecosystem function and restore habitats, to properly prioritize projects for addressing RPA 159, we believe it is necessary to assess the priority fish stocks of concern and what can be accomplished.

3) There are controlling factors in the estuary that are recognized in this plan and that will limit the ability to restore certain habitats (most notably river flow control, the navigation channel, and lands permanently lost to the estuary system).  These limitations should be included in the scientific basis and may have been planned for inclusion, if the conceptual foundation material was completed and the necessary diagrams included in the draft.   The conceptual model appears to be a useful way of organizing the processes influencing system structure and dynamics. However, critical figures displaying the specific elements of the model were omitted from the document. This omission is a serious shortcoming that hampers the review process.

While we encourage the development of conceptual models, the authors need to explain specifically how the conceptual model should be used by subbasin planners.  For example, the restoration comparison is frequently made to the historical or pre-development habitats.  While this may be a reasonable comparison for change, is it a reasonable comparison for restoration goals?  This committee is, of course, familiar with this issue and some members were involved in developing the normative river concept included in the Independent Scientific Group's report "Return to the River".  The reality of restoration to some intermediate habitat stage is acknowledged in several locations in this text but the normative concept is not identified.  An obvious question then is whether the normative concept was considered and rejected, or is it the intention of this plan to use historical habitat standards as their goal?

4) For practical use, this document would be more effective if it were more concise and clearly written.  The text is heavy on landscape and restoration theory and classification of terms but far too light on the success and failures of these in application to actual estuary programs, although some major programs are noted in Table 1.1.  The estuary plan should be more than a treatise on ecosystem and landscape theory. The plan should explicitly apply the theory to restoration.  The science foundation is burdened with excessive theory that the authors do not clearly or practically relate to development of subbasin plans generally or the estuary specifically. The terminology is needlessly complex, and the strategies are poorly distinguished. Reviewers felt strongly that the terminology developed for restoration strategies (Table 2.3 & 3.1) overly emphasizes classification as opposed to actions that have actually worked in other restoration programs.  Further, while some reference is made to restoration activities in the Columbia River Estuary, discussion is needed on what has been learned from these activities and whether fish benefits were gained.

For example, all of the project types listed in Table 3.1 would benefit biodiversity, which is considered by the authors to be an exclusive strategy called "conservation." The authors define "enhancement" as improvement of one or several attributes of the system while "restoration" entails improvement of the whole system directed toward returning the system to some previously existing condition (p. 58) such as the pre-disturbance or historical conditions. This distinction appears illusory. It is difficult to imagine for a complex, open, and dynamic system, any enhancement activity, if it is substantive, that will not affect the system as a whole. In fact, this should be the goal. The immense difficulties of returning a system to its historical, pre-disturbance condition aside, the project types listed for enhancement and restoration in Table 3.1 are essentially interchangeable between the two strategies. It is unclear how the project types listed for "restoration" will benefit the whole system and return it to a pre-disturbance state while the types listed for enhancement will lead only to improvement of single attributes. We do acknowledge, however, that several other reports have also tried to develop and differentiate these strategies.

Distinguishing different kinds of general restoration strategies is difficult to accomplish satisfactorily and without generating unnecessary confusion. Ecologists have distinguished between active and passive restoration, a more common distinction than the five types provided in this report. Active restoration would encompass project types listed under the "creation" strategy and some "enhancement" project types (Table 3.1).  In our opinion, a more practical justification for differentiating the classes of strategies would be preferred, and more useful for their eventual application.

The choice of restoration strategies depends on assessing the degree of disturbance (Fig 2.1) at the site and the landscape level (Figure 2.3) (although Figure 2.19 refers to disturbance levels in the subarea and the subsystem). What constitutes a site, a landscape and a subsystem is not clear. Nor is it clear how each of these levels relates to the controlling factors of hydrodynamics, bathymetry, and salinity. The report assesses disturbance as low, medium, or high but it does not explain how these disturbance levels are determined from the data. What distinguishes a low level of disturbance from a medium or high level? In fact, the degree of disturbance should be assessed in terms of how much the habitat changes have reduced salmon survival and growth, although the data needed to make this assessment probably are lacking.  This issue merits inclusion in the research priorities.  As one reviewer asked, do these descriptions and classifications extend our knowledge beyond logical common sense?  It may be more effective to present the theoretical basis in simple logical diagrams (such as Fig. 2.1) and leave the specifics of spatial scales to those who understand the specific-site and how it is connected to the landscape it is in. 

5) While the draft plan refers to the need for communication, collaboration, and coordination, it lacks social or community context.  Further, a presentation by NOAA staff to the ISAB/ISRP in late June implied to us that these aspects of this plan's development have been lacking.  We clearly cannot support a process that results in two restoration paths being developed for the estuary.  Further, any plan that must involve changes to land use, ownership, or simply a change in resource use, must involve the people and communities affected by these changes. In a technical context, a description of land use and lands effectively removed from the estuary should be included in this text and considered in the project evaluation process.  Ironically, the estuary has a rich and informative record of habitat changes over time, but the record of changes in land use and people is conspicuously omitted (at least from this draft plan).  The other issue associated with both the habitat records and community developments is the much more limited ability to assess change in the Tidal Freshwater system.  The ISRP is aware of data limitation for that region, but we are concerned that it may be a serious bottleneck in the survival of salmonids produced up-stream of that region.  A further clarification needed about this plan is how much of the Willamette River is included in this plan and whether it will be considered in the RPA 159 actions?

**Consideration of Questions Posed**

1) Are the goals of the plan clear, appropriate, and usable?

As we stated in point 1 above, we have trouble providing a direct answer to this question since we are uncertain of the specific objective of this text.  As stated, the reviewers concluded that the goal was weak and process-oriented rather than outcome oriented.  It is expressed in terms of activities (implementing well-coordinated, scientifically sound projects?) rather than outcomes. The goal statement should be expressed in terms of outcomes (the effect of the inputs and outputs, as distinguished from inputs and outputs themselves). Some of the outputs (enhance, preserve conserve and restore and create tidal wetlands and other key habitats) embedded in the goal statement could lead to intended outcomes.  What conditions do they want to achieve in the lower estuary? What will success look like?

We note the statement of intent at the beginning of section 1.3. 

"The intent here is to develop science-based protocol for determining priorities and strategies to improve ecosystem functions in CRE."

This statement does seem to be consistent with the content of the report and could form the basis of a more "outcome" oriented goal statement, but we note it remains vague on the actions to address RPA 159 and salmonid habitats (as stated on page 1 of the Plan).

We feel strongly that the objective of this report must be made much more apparent, and the text focused on that, in order for it to be useful for others involved with subbasin planning generally and Columbia River Estuary restoration specifically.

2) Is it evident how the plan relates to subbasin planning [does it meet the requirements of a subbasin plan]?

No. In some ways the plan distances itself from subbasin planning by stating that the plan was developed "to assist the BPA and COE to address the habitat needs of listed salmonids in the CRE" rather than presenting the plan as the strategic framework for people in the subbasin to achieve desired outcomes. Reference is made to the habitat restoration plan being only one piece of a broader scale effort (2nd paragraph, page 77).  This paragraph generated confusion about the role of this document in these other activities.  To some extent, this plan seems to be the "cart before the horse" given these other activities. 

The ISRP has stressed that a subbasin plan should involve an inventory or assessment of the habitats and fish and wildlife resources, an analysis to identify the factors limiting production of these resources, and a process for assessing priority restoration activities. 

This document actually does address aspects of these contents.  It provides
          - an assessment of habitat changes, but not the fish resources involved in RPA 159;
          - a limited identification of habitat losses without directly relating these losses to fish species, etc.;
          - an acknowledgment of the uncertainty in outcomes and the need for monitoring and evaluation (treat each restoration project as an experiment);
          - a proposed project planning cycle with some good advice on project content and how to relate to the ecosystem basis of recovery;
          - an emphasis on the need for community involvement for decisions on restoration programs to be implemented, although such a decision process has not yet been implemented.

While the document is referred to as a habitat restoration plan, it is clearly not.  It provides a recommended scientific basis for application of ecosystem-based habitat restoration and outlines a content and process for project development.  As such, this document may be a useful guide to the development of subbasin plans and to the evaluation of proposals. 

Two subbasin issues are apparent from this document:

a) the lack of an agreed-upon co-coordinating body or organization, and

b) the lack of a central data management and processing organization. 

Both of these issues will be important to address in a subbasin planning process, but are not addressed in this text.

3) Does the plan provide a sound scientific basis for habitat restoration in the lower Columbia River Estuary? What are its strengths and weaknesses?

The response to this question involves all of the discussion above, which will not be repeated.  While the review has been critical of the organization of the plan and its omissions, the plan has strengths that can provide a sound scientific basis for habitat restoration in the estuary, including the Tidal Freshwater sub-area.  Most of our concerns address the clarity of objective, presentation of material, and integration with other activities.  But the basic intention of establishing an ecosystem-based approach to restoration is, in our opinion, a sound approach particularly given that the plan includes:
          - explicit acknowledgement of uncertain outcomes and use of experimental approaches;
          - the essential need for monitoring and assessment, including the use of reference sites (use available disturbed and/or undisturbed for temporal comparison);
          - a role for adaptive management given these uncertainties;
          - a need for a central data management and information center; and
          - identification of many of the critical uncertainties and research needs.

The authors attempted to present the "plan" in an orderly approach proceeding from goals, to scientific basis, to implementation but, put simply, the important message for planners seems to have been confused in detailed terminology and the lack of a clear objective for this document.

Many of the comments on weaknesses in the document are also included above but a few others were noted:
          - While doing a good job of presenting the biophysical context, the plan is surprisingly absent of any information about the economic, social, or political context of the lower estuary and its relation to past and current uses. Some reference is made to institutional and legal constraints in the final summary section, but for this document to be useful for subbasin planning these should also be part of the general contextual description in section 2. Ecological restoration does not take place independent of other human activities.
          - The plan is substantially weaker on the Tidal Freshwater region than the other Columbia River Estuary regions. This likely reflects the availability of information, but the ISRP views this area as a critical one that has been neglected.
          - The implementation meaning of conservation biology and ecological terms and concepts are unclear.
          - The plan does not contain priorities; only lays out considerations for prioritization.
          - While emphasizing coordination and collaboration, the plan focuses on evaluating individual projects on their own merits without stressing that each project should fit into the overarching (and specifically measurable) goals and objectives for the estuary.
          - The plan pays lip service to adaptive management but really lacks a strategic element that would demonstrate an adaptive management approach. 

The ISRP is again concerned about the term "adaptive management" as applied in Basin programs.  This document actually, in various locations, notes the components of adaptive management better than many others we have reviewed.  But, adaptive management is not simply the accumulation of understanding provided by "the very act of restoration" as stated in section 3.3.5.  It is important that adaptive management be understood to be a structured experimental process that is adjusted as information is collected over time, and alternative hypotheses are tested.   In a complex, open, and highly dynamic environment such as the estuary, we expect that adaptive management practices could be invaluable in testing various restoration methods and testing how to best assist the recovery of these species.

On an editorial note, it was not apparent why Data Management and Dissemination (Section 3.3.4) were not included in Table 3.5.  We agree with the issue presented in Section 3.3.4, but also note that data standards for each project and some requirement for data sharing should be included in any restoration program, especially if these programs are truly integrated and using an adaptive management design.

**Specific comments provided by reviewers**

These are listings of comments by various reviewers but not in any order of priority.

P.3: Goal needs to be expressed in measurable outcomes.

P.4: The objectives and tasks are describing activities that are back a level from strategic actions of a plan — they are more a "plan to do a plan."

P.5: Is there a more recent annotated bibliography of the Columbia River Estuary than Morgen et al. 1979?

P.6: Update NPPC name to Northwest Power and Conservation Council (NPCC).

P.7: How will this program compare in scale (spatial and $) to the other major U.S. coastal and estuarine restoration programs?

P.12: Figure 2.1 needs more elaboration. What do "optimal structure," "optimal function" and "optimal biodiversity" mean, specifically? What defines "acceptable"? Why does the figure label the point of optimal ecosystem function and optimal ecosystem structure "desirable"?  If "optimal" represents pre-disturbance conditions, is this achievable? With regard to "survival of salmon being dependent on the return of the estuary to a 'less altered state'", can this be expressed more specifically?

P.15: Would "improved ecological condition" be a better phrase than "superior ecological condition"?

P.15, para 2: the consideration of current and future conditions at a site points to the need for specific measurable objectives for restoration.

P.16, restoration definition: again, a need to be more specific about "historic" or "pre-existing" conditions

P.19: "As long as the primary processes".are still effective? if so, would the system be considered degraded? This statement is apparently inconsistent with the bottom of p.23

P.19, para 2: "Indirect" with respect to what?

P.19: Discussion of sustainable development is pretty thin — could also include recognition of the connection between "no let loss" concept and the need to increase the stringency of restrictions as population increases. Also should acknowledge with more detail why predictable development has not taken place.

P.19: What is really the value of the sustainable development discussion, not used again?

P.21: What is the reason for the conclusion that enhancement is the strategy best suited to restoration of target species? "opportunistic site use" is repeated.

P.23: The Columbia River Estuary model is difficult to use as a framework to make decisions for restoration planning because it doesn't contain strategic priorities.

P.23, bottom: The key to "degraded or negatively altered" is that it has gone beyond some threshold.

P. 28, 2nd paragraph: Several inaccuracies in this paragraph -- be more accurate in comparisons.

P. 32 Critical uncertainties: These never seem to be referred to again?

P.33: More could be said about how the information on historic habitat structure will be used under present conditions.

P. 34 to 43, Map figures: Several reviewers commented on the difficulty in comparing figures and inaccuracies (omissions) in come figures (especially these 1992 figures).  The varying captions make comparisons between time periods difficult. Maps for Tidal FW system are essentially useless given the scale used.

P.34: More should be said about why it is relevant to examine historic habitat types and compare them to existing types.

P.45: Does this summary pertain to the Tidal FW system also?

P.47: Why would you assume that historic conditions represent the optimal conditions for a particular site? Reconcile this with the sentence that "optimal" under present conditions may be different than "optimal" under historic conditions? (Be more explicit about the meaning of optimal.)  Why assume that restoration to historical conditions is the best strategy? Do all changing human uses of the estuary constitute "damage"?

 P.52: If the recommendations are guidelines only, and should not necessarily preclude others, how can they be considered priority?

P.62: Calculation of an IBI sounds very subjective. Is this the case?

P.64: "Areas of historic habitat loss": Areas where habitat loss is the greatest should be considered for restoration — doesn't this depend on the nature of the loss and the alternative uses presently at the site?

P.65: Is "connectance" a word?  Probably should be "connectivity"

P.70: Individual project goals should tie to specific estuary restoration goals.

P.70: Coordination and outreach: the potential to learn from stakeholders (e.g. involving landowners in problem solving) should be mentioned here.

P.72: Performance criteria: a project's progress toward meeting its stated goals should also be tracked in terms of its contribution to estuary outcome goals.

P.74: How is restoration a developing "technology"?

P.78: "Federal institutional differences:" Are financing rules the key differences between federal agencies?

P.78: Other restoration initiatives:  more specifics should be given as to how to ensure collaboration, since the plan has no authority.

P.78: Knowledge base: the identification of critical uncertainties is a strength of this plan

P.79: Outcome uncertainties: OK, but the plan still should have target outcomes.

P.79: para 3: but the plan presents no strategy for prioritization.

P.79, bottom: but can't wait for this research to be completed before developing the restoration plan.

P.80: Project selection guidelines: need a priority list, and for this need to have measurable objectives for the estuary.

P.80: the implications of the project credit proposal are not entirely clear.

P.81: data: would this be a separate data system? Who are the stakeholders referenced?

P.81, bottom: the plan is an "optional guide" rather than a coordinating document.

**A reviewer's comment on ecosystem process, function, and structure**
> 
The concepts of ecosystem process, function, and structure are poorly distinguished, excessively confusing, used interchangeably, and are not a critical part of the estuary restoration plan. These concepts receive far more attention in the document than they deserve and will do little more than confuse the planning process. For example, the authors state that nutrient cycling is an ecological function. One could argue convincingly that nutrient cycling is the process by which chemical compounds containing nutrients such N, P, C are converted into forms useable by plants. It involves individual processes or chemical reactions such as nitrification, ammonification, nitrogen fixation, and so forth. However, nutrient cycling also has a function or role in an ecosystem. One such role or function is to produce N, P, and C in useable forms. Thus, nutrient cycling is a process and it functions to provide plant nutrients in ecosystems and thus is critical in food web development and maintenance. The same argument could be advanced for primary production or indeed any production process, which the authors deem functions. This argument simply highlights the confusion that can surround these terms. 

Another example of this confusion is evident in Figure 2.1, the graph that relates ecosystem function on the y-axis to ecosystem structure. The number of ducks nesting in a pond-wetland interface is considered a function by the authors but ducks numbers are more appropriately part of ecosystem structure, even by the definition of structure given by the authors in the glossary. Ducks however may function as predators on invertebrates or as prey for certain raptors and humans. Again, this example illustrates the confusion that can arise from excessive use of these terms. Phrases such as "under optimal conditions of structure and function" and "predictable functional condition" are vague, difficult to assess if they even exist in a dynamics system, and irrelevant to the estuary plan and the subbasin planning process. Figure 2.1 is unnecessarily confusing, is not critical to the plan, and the figure and its accompanying discussion should be omitted. The same could be said for Table 2.1.

These comments provided by one reviewer provide examples of the need for clear use of terms, particularly for the understanding of peoples not immersed in ecological terminologies.  This concern is not limited to one reviewer and is supported generally by the ISRP.

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